By Brandt Mannchen
I. Introduction
This “History of the Sierra Club and East Texas Wilderness Areas Management” is Part 2 of East Texas Wilderness History. Part 1, dealt with, “East Texas Wilderness Designation”. There are many viewpoints about wilderness, from the U.S. Forest Service (FS), Texas Conservation Alliance (TCA), Texas Forest Service, Texas Forestry Association, etc. But this is a Sierra Club viewpoint about wilderness.
This history is for all the people in the Sierra Club who fought for wilderness, others who helped, and those in the future who will fight the good fight. Some of those who have given of their time, expertise, and effort include:
Tom Maddux, George Russell, Hubert Davis, Jerry Akers, Cathy Akers, George Smith, Terry Smith, Bill Wilson, John Glover, Sedge Simons, Mary Van Kerrebrook, Roger Brown, Frank Blake, Evelyn Merz, Leo Reitan, Gail Fraizer, Joerg Freiberg, Wiley Beal, David Boyd, Brandon Sanchez, Claudette Vinson, Terry Vinson, Jerry Greene, Mike Schultz, Jane Schultz, Mary Rawlins, Gary Rohan, Bob Mahley, Ola Humphries, Kel Rynnagh, Bill Schriever, Carol Shriever, and many others. Thanks to all!
The Sierra Club is a many-headed beast. To keep in perspective what entity of the Sierra Club is referred to, I use NSC, for Sierra Club national; LSC, for the Lone Star Chapter of the Sierra Club; and HSC, for the Houston Regional Group of the Sierra Club.
“History of the Sierra Club and East Texas Wilderness Areas Management” deals with the National Forests and Grasslands in Texas (NFGT), is incomplete, and comes from documents in my personal files. I have plagiarized my sources relentlessly and thank them for their knowledge, which if not recorded, would make this effort impossible. This is, of course, my view of what happened buttressed by the documents that I have listed under “References”. Any mistakes are mine alone.
There is no other East Texas Wilderness Areas (ETWA) management history available that outlines the Sierra Club’s role. This document will suffice until someone comes along, takes more time, finds more sources, and makes a better effort. Good luck to them!
II. East Texas Wilderness Areas
There are five East Texas Wilderness Areas (38,667 acres total) in the NFGT, managed by the FS, that will be discussed. They include:
1. Little Lake Creek Wilderness Area (LLCWA), 3,855 acres, Sam Houston National Forest (SHNF).
2. Big Slough Wilderness Area (BSWA), 3,639 acres, Davy Crockett National Forest (DCNF).
3. Indian Mounds Wilderness Area (IMWA), 12,369 acres, Sabine National Forest (SNF).
4. Turkey Hill Wilderness Area (THWA), 5,473 acres, Angelina National Forest (ANF).
5. Upland Island Wilderness Area (UIWA), 13,331 acres, ANF.
The LSC is the policy-making body in most of Texas (except for a part near El Paso and the surrounding area which is in the Rio Grande Chapter). The LSC deals with wilderness issues within Texas and sets policy and takes positions as long as they don’t conflict with NSC wilderness policy and positions.
Not by any means, do I have all LSC policies/positions that deal with wilderness, but I do refer to the policies/positions that I do have, and set the stage for “History of the Sierra Club and East Texas Wilderness Areas Management”. I thank Ken Kramer for his work in the collection and collation of these LSC policies/positions which include:
1. January 27, 1968, the LSC answered an inquiry by the Conservation Federation of Texas about several issues and approved the following:
“The Chapter favors the use of expert planning studies, including those which have already been made as well as future studies, in the selection of sites for state parks. Wilderness and scenic areas should be included as well as recreational and historic sites.”
2. March 14, 1970, “… recommends that the entire Guadalupe Mountains National Park be maintained as a roadless wilderness area except for the existing road ending at the gate to McKittrick Canyon.”
3. January 16, 1971, “The first hearing on a Wilderness area for Big Bend may be this year. The Sierra Club proposal has been adopted by the Board of Directors, but someone was needed to head a task force for the Chapter. Cass Germany volunteered, and will have assistance from the El Paso and Llano Estacado groups.”
4. January 16, 1971, the LSC passed a resolution about state parks which stated, in part, “… augment revenue bonds now available to purchase areas in Texas to be preserved in their natural wilderness undeveloped state … The Lone Star Chapter of the Sierra Club recommends that the legislature authorize and direct the Parks and Wildlife Commission to include in its Master Plan for State Parks the identification and purchase for the purpose of preservation natural and wilderness, as well as other undeveloped, areas in addition to present development plans for recreation areas.”
5. March 13, 1971, the LSC reported that, “An information meeting has been held by the Padre Island National Seashore managers … to get opinions on designation of part of the island as a wilderness area … the Lone Star Chapter of the Sierra Club believes and urges that an area extending from Little Shell Beach to Mansfield Cut should be declared a wilderness-like area.”
6. July 10, 1971, the LSC approved a National Issues Platform which stated, “18) Implement to the full, the Wilderness Act, including areas in Big Bend and Guadalupe Mountains National Park.”
7. September 11, 1971, “It was suggested that the Chapter initiate a program of wilderness areas in Texas National Forests. Kindschy agreed to contact John Courtenay, Supervisor of the National Forests in Texas to get the program started.”
8. March 11, 1972, “The Lone Star Chapter of the Sierra Club believes it desirable and urges that an area extending from Little Shell Beach to Mansfield Cut to Padre Island be declared a wilderness area.”
9. May 19, 1973, “13. Kindschy asked for and obtained Chapter support on a. Senator Bentsen’s Guadalupe Wilderness Bill, and b. Senator Bentsen’s Rio Grande Wild River Bill.”
10. July 17, 1976, “In 1972 the Chapter surveyed three national forests in Texas and made a wilderness proposal to the Forest Service. The Service stopped all management activity except beetle control in the eight areas pending the holding of Charettes for determining future management of the national forests in Texas.”
“The Four Notch area was one that the Chapter proposed for wilderness. In order to stop timber sales already begun in an adjacent area to the Sierra Club proposal and to extend the Monongahela decision to Texas on clearcutting, the Texas Committee on Natural Resources filed suit against the Forest Service in July. A temporary injunction was granted. TCONR proposes a larger Four Notch wilderness area than the Sierra Club. Gordon Robinson, a forestry consultant often identified with the Sierra Club, is scheduled to testify in a hearing for a permanent injunction the end of July. After discussion, the following was MSC (moved and seconded motion):
“(a) That the Lone Star Chapter stands by its previous wilderness proposal of 1800 acres for wilderness designation in the Four Notch area and does not endorse any expansion at this time:”
“(b) That the Lone Star Chapter will pay air fare for Emil Kindschy or his designate to Washington to testify on the wilderness bills when and if asked to do so:”
“(c) That Emil Kindschy and Howard Saxion will talk to Gordon Robinson about his appearance in the lawsuit;”
“(d) That a statement will be filed with the court that Robinson is not testifying for the Sierra Club and a copy of this resolution will be sent to the clerk of the court;”
“(e) That the Chapter will not become a litigant in the clearcutting suit at this time;”
“(f) That the person testifying in Washington will be instructed that if any inquiries are made regarding the clearcutting suit he may not speak in any manner on the subject.”
11. January 21, 1978, “The Forest Practices Committee is meeting with the Texas Forestry Association about wilderness in the national forests. MSC: That the Chapter approves the negotiations with Texas Forestry Association and will consider the recommendations of the Forest Practices Committee.”
12. May 20, 1978, “MSC: That the Big Thicket Association flyer on the pine bark beetle be printed as a supplement to the Lone Star Sierran with the following provisos:” “The flyer specify that it is directed toward the Big Thicket and wilderness preserves (not commercial forests). The flyer includes a disclaimer that it is for the purpose of information and does not necessarily represent Sierra Club policy (John Glover would prepare comments in this regard), The name of the Big Thicket Association be put at the beginning of the supplement to the Sierran.”
From these policies/positions that the LSC approved, it’s obvious that the LSC was committed to and supported wilderness. But was the LSC ready to move into wilderness protection and management after designation of wilderness areas in Texas?
IV. Sierra Club National Policies on Wilderness Areas and Fire
For a volunteer led organization, it can be difficult to understand what NSC policies require of wilderness and forest protection advocates/activists.
The NSC has several policies that address fire in wilderness areas. The July 8, 1995, “Wilderness Management” NSC policy (originally adopted on November 5-6, 1977) addresses fire in several ways. This policy states:
“Within the context of the Wilderness Act, the primary wilderness management objective should be to protect “an enduring resource of wilderness” from significant degradation by human influence and use.”
“Each wilderness possesses individual characteristics. The application of wilderness management techniques should reflect the individuality of each wilderness within the context of requirements to preserve the wilderness resource. Wilderness management plans should provide for flexibility in meeting conditions that vary with location and time … In wilderness management, natural ecological processes should be allowed to operate freely to the maximum extent feasible to promote, perpetuate, and where necessary, restore the wilderness character of the land. Minimal manipulation may be allowed in order to restore human-disturbed environments or offset human-induced restrictions on natural processes … Restraint should be applied to and by the managing agencies … so as to protect the resource and experience.”
Another NSC policy that applies to fire and wilderness is the “Fire Management on Public Lands” policy that was adopted on March 17-19, 1989. This policy states:
“Fire is a natural, integral, and valuable component of many ecosystems … Areas managed for their natural values often benefit from recurring wildfires and may be harmed by a policy of fire suppression.”
“In areas included in or proposed for the National Wilderness Preservation System, fires should be managed primarily by the forces of nature. Minimal exceptions to this provision may occur where these areas contain ecosystems altered by previous fire suppression, or where they are too small or too close to human habitation to permit the ideal of natural fire regimes. Limited planned ignitions should be a management option only in those areas where there are dangerous fuel accumulations, with a resultant threat of catastrophic fires, or where they are needed to restore the natural ecosystem.”
“Land managers should prepare comprehensive fire management plans. These plans should consider the role of natural fire, balancing the ecological benefits of wildfire against its potential threats to natural resources … Land managers should rely on natural revegetation in parks, designated or proposed wilderness areas, and other protected lands.”
These policies are well meant but include contradictory words/phrases which obscure how wilderness will be managed as little as possible. This “History of the Sierra Club and East Texas Wilderness Areas Management” shows how difficult it is to apply these policies on designated wilderness areas.
V. Sierra Club, East Texas Wilderness Areas, and Fire
Fire in wilderness areas may be the most controversial issue in wilderness area management.
Section 2. (a) of the “Wilderness Act”, states:
“In order to assure that an increasing population, accompanied by expanding settlement and growing mechanization, does not occupy and modify, all areas within the United States and its possessions, leaving no lands designated for preservation and protection in their natural condition, it is hereby declared to the policy … to secure for the American people of present and future generations the benefits of an enduring resource of wilderness.”
Development and active management specifically are what the “Wilderness Act” doesn’t envision:
“Section 2. (a), “… and these shall be administered for the use and enjoyment of the American people in such manner as will leave them unimpaired for future use and enjoyment as wilderness, and so as to provide for the protection of these areas, the preservation of their wilderness character”.
Section 2. (c), “A wilderness, in contrast with those areas where man and his own works dominate the landscape, is hereby recognized as an area where the earth and its community life are untrammeled by man, where man himself is a visitor who does not remain.”
Section 2. (c), “An area of wilderness is further defined to mean … an area of undeveloped Federal land retaining its primeval character and influence, without permanent improvements or human habitation, which is protected and managed so as to preserve its natural conditions and which (1) generally appears to have been affected primarily by the force of nature, with the imprint of man’s work substantially unnoticeable; (2) has outstanding opportunities for solitude or a primitive and unconfined type of recreation; (3) has at least five thousand acres of land or is of sufficient size as to make practicable its preservation and use in an unimpaired condition; and (4) may also contain ecological, geological, or other features of scientific educational, scenic, or historical value.”
These sections of the Wilderness Act of 1964 appear clearcut, pardon the expression, about protection and a low level of management for wilderness areas until you read Section 4. (d)(1), which states:
“… such measures may be taken as may be necessary in the control of fire, insects, and diseases, subject to such conditions as the Secretary deems desirable.”
This is the management rub that has caused untold controversy and difficulty in leaving wilderness areas to evolve on their own. East Texas Wilderness Areas (ETWA) have had a bumpy ride because management is often antithetical to the existence of wilderness and its wildness. The LSC has been concerned about this human-made conflict for decades, as we will see.
When the “Wilderness Act” became law in 1964, “control of fire” dealt with wildfires that burned and were a hazard to humans or human structures and needed to be controlled and or put out.
As time passed, this emphasis changed to active manipulation (management) of wilderness areas to perpetuate or create certain native fire tolerant ecosystems with “prescribed burning”. The use of fire in wilderness areas may be illegal, is controversial, and is fraught with mixed interpretations of what management is and isn’t allowed in wilderness areas. This and the FS propensity to disallow the burning of natural wildfires in wilderness areas (suppression) has set up a conflict with the LSC that continues to this day.
The LSC foresaw this conflict before the signing of the October 30, 1984, “Texas Wilderness Act of 1984” by President Ronald Reagan. George Russell, LSC Chair of Texas Wilderness and Forest Practices, sent to the LSC Executive Committee a draft resolution on October 25, 1984, “Wilderness Management Policy”, that addressed purposeful burning in the ETWA. This draft resolution stated:
“Be it resolved that the Lone Star Chapter Sierra Club is opposed to any artificial manipulation or management of the ecosystems in our five Texas National Forest wildernesses to include prescribed burning and entry for the control of southern pine beetles (spb).”
“It is understood that this “Leave it alone” management policy in no way prevents or prohibits oil drilling activity.”
“In the event that the U.S. Forest Service insists on buffer cutting for spb control then any such cutting should take place outside the wilderness boundaries.”
“Report of Study: Burning of Texas National Forests” and “Fire Policy Statement on East Texas Wildernesses” were included as additional material in support of this draft resolution.
The concern was that the FS would use its purported authority under Section 4. (d)(1), to prescribe burn the five ETWA and thus trammel wilderness via manipulation, confinement, prevention, and impediment; restrain activities, progress, and freedom; and prevent, impede, or hamper the free play of untrammeled wilderness which forms the core of the Wilderness Act of 1964.
November 6, 1984, the Southern Region (Region 8), FS, Regional Forester, signed the “Wilderness Fire Action Plan National Forests in Texas, November 1984”, which the National Forests in Texas (NFT), Forest Supervisor, William Lannan had signed on October 30, 1984.
This was the same day that the “Texas Wilderness Act of 1984” was signed into law by President Ronald Reagan. This signing of the “fire action plan” on the same day as the signing of the “Texas Wilderness Act of 1984” showed that the FS had prepared the “fire action plan” (with no public input) before the “Texas Wilderness bill” was passed by the U.S. Congress and signed into law. This “fire action plan” stated:
“This Wilderness Fire Action Plan supersedes the RARE (Roadless Area and Review Evaluation) II Fire Action Plan, approved March 17, 1981”.
“Flashy fine fuels, mostly needle and leaf litter, will accumulate rapidly on upland sites where periodic prescribed burning to reduce this fuel accumulation has been terminated … The National Forests in Texas utilizes Central Dispatching and suppression resources are used as needed. Therefore, it is meaningful that one action plan be utilized for all wilderness areas.”
“The small or medium tractor units equipped with a fire plow and front-mounted blade are normally used for fire suppression … The larger person-caused fires can have a more damaging effect on the wilderness character than would be the damaging effect of a plowed fire line on a smaller fire (considering plowed lines would be restored to as near natural as possible after the fire) … any or all of the above form a strong justification for utilizing tractor-low units for fire suppression.”
This was the very concern that the LSC had about trammeling in the five ETWA, but which was allowed, to some degree, by the Wilderness Act of 1964, as “control of fire”, or as was stated by the FS, “fire suppression”.
Recent research documents that suppression of “lightning-caused wildfires runs counter to the goal of protecting natural and untrammeled qualities in wilderness.” Fire suppression causes several ecological impacts which include:
1. High fuel accumulations occur where they normally wouldn’t, which allows for hotter fires.
2. Smoke and air pollution are increased.
3. Fire growth expands because wildfires aren’t allowed to burn to retard future wildfire burns.
4. Fires burn in some locations because previous fire suppression allows more vegetation to burn.
Later, an individual wilderness fire management action plan was prepared by the FS for each of the five ETWA. These action plans didn’t include prescribed fire but did focus on fire suppression after a fire started. The FS stated in these plans:
“Planned ignitions (prescribed fire) for fuel reduction or resource management will not be utilized as part of this plan. The use of prescribed fire to reduce fuel loadings should be addressed in a separate plan.”
“Fire Management Action Plan for Turkey Hill Wilderness”, was approved on April 14, 1994, and was included in the “Wilderness Fire Action Plan National Forests in Texas, November 1984”, as Appendix 4.
“Fire Management Action Plan for Big Slough Wilderness”, was approved on January 18, 1994.
“Fire Management Action Plan for Upland Island Wilderness”, was approved on April 14, 1994.
The copy of the “Fire Management Action Plan for Little Lake Creek Wilderness”, that I have has no approval date but has a recommended date by the District Ranger of December 2, 1992.
I don’t have the fire management action plan and the date it was approved for IMWA.
Over the years, the LSC pressed the FS about its position on fire control in the five ETWA and sought the latest research and other information it could get from the FS about fire and wilderness areas.
February 15, 1999, the LSC submitted a Freedom of Information Act (FOIA) request to the Ronnie Raum, FS, Forest Supervisor, NFGT, in reference to a previous January 6, 1999 LSC FOIA request that contained questions, requested information, and made comments about the FS document, “Wilderness Wildfire Hazard as Related to Tree Kill by Southern Pine Beetles on the National Forests in Texas”, of January 31, 1994.
The FS provided a response letter to the LSC on February 10, 1999, which said that LSC comments were noted, that the wilderness document was an internal working paper, and that decisions about fire are made through the 1996 Revised Land and Resource Management Plan (RLRMP), Limits of Acceptable Change (LAC) process, and individual wilderness fire management action plans.
The February 15, 1999 LSC letter, stated that the FS document was “apparently being used in developing decision documents about fire in wilderness” and “Since our information request was not responded to and our questions were not answered we are making the following requests”, which included an information request and a request to answer previous LSC questions that were made to the FS.
The HSC also educated its members and the public about forest fires. A September 2000 article, “Fires in the Forest: are They Bad or Good?”, was written for general distribution. The article stated:
“Loblolly Pines, the most common pine found on Sam Houston National Forest, grew with many hardwoods in a dense forest where few fires occurred. The very dense, less burnable hardwood vegetation, wet soils, scattered wet areas, streams, and flatwoods, our rainy climate, and quick decay of dead vegetation, made it difficult for fires to burn in forests with Loblolly Pine.”
“Humans, since the early 1900’s have been suppressing all fires, whether naturally caused or started by humans. Fire suppression causes a build-up of dead wood, which in the dry forests of the West accumulates to levels that would not normally occur. What is needed in Western fire dependent forests is careful prescribed fires (fires set during certain meteorological conditions) which will burn some of this accumulated wood. What is also needed is a policy which allows fire to burn naturally and not be suppressed.”
“Fires are a natural part of the forest and on the whole benefit forest survival. If humans allow the fire and forest to interconnect as they always have we will have healthier forests and fewer so-called fire catastrophes.”
The LSC spoke with researchers to understand their viewpoint about fire and wilderness areas. The LSC sent a March 4, 2003 letter to Dr. Craig Rudolph, FS, Southern Research Station, about prescribed burning in wilderness areas and whether it should be allowed.
The LSC stated, “… Wilderness needs less research, but more restraint; less altering, but more evolving; less human touch but more Nature’s touch.”
March 10, 2003, Dr. Rudolph replied to the March 4, 2003 LSC letter. Dr. Rudolph ended his letter by saying, “It is also the case the fire-maintained ecosystems are typically among the most endangered ecosystems that exist. This trend is exacerbated when conservation measures are enacted that do not take fire regimes into account … Ultimately this results in loss of biodiversity and catastrophic wildfires.”
The Sierra Club responded to Dr. Rudolph’s letter on April 1, 2003 by saying:
“I do not necessarily agree that managers must suppress fires if they are apt to spread off site. This is particularly true when Wilderness is surrounded by National Forests, like is the case for much of the boundaries of our East Texas Wildernesses in the NFGT.”
“There are many options to assist those who insist on living in forested areas where fire plays an important role as a natural ecosystem process. This includes fire proofing private in-holdings so fire risk is significantly reduced. This also includes buyouts of key in-holdings so natural fire is allowed to play its evolutionary role in Wilderness.”
“However, the basic problem is fire suppression. If the U.S. Forest Service (FS) is still putting out natural fires in East Texas Wilderness Areas that is a problem of management and manipulation of forest ecosystems.”
“But that is just the point. We cannot predict what Nature will do. Nature has a plan that we cannot see and will never know. Changes will occur, but on Nature’s terms and on Nature’s schedule. Not one moment sooner or later. Nature will provide the non-anthropogenic perturbation of fire if we let it. Just give Nature time. That may mean that neither you nor I will live to see the full fruition of Nature’s plan. That is disappointing. But it is reality. Unhindered natural processes do not play by our rules.”
The FS pressed forward with a hazardous fuels reduction plan for ETWA. The first wilderness area to receive attention was UIWA.
In a document entitled, “Management Problems in East Texas National Forest Wilderness Areas”, September 2, 2005, the LSC listed 20 management problems which included:
“6) The FS is planning to introduce prescribed fire into UIWA and Turkey Hill Wilderness Area (THWA, and maybe the rest of the ETWA – East Texas Wilderness Areas) not just for ecological purposes but to reduce fuels to reduce fire risk. In some of the ETWA or some parts of the of the ETWA ecosystems, fire rarely occurred. An unnatural fire regime will be the result of this action in these areas. The FS has not conducted the research to determine by historical, local, and site specific information what the natural fire frequency is estimated to be.”
March 6, 2007, the LSC listed a series of ways to deal with fire in wilderness areas and to minimize trammeling by the FS during prescribed burning in UIWA. These measures included:
“1) No fire lines in wilderness.
2) Start the prescribed fire outside wilderness and let it burn where it will.
3) Fire-proof adjacent properties to reduce risk.
4) Written minimum requirement analysis.
5) Determine what the minimum tool is.
6) Look at FS regulations on wilderness.
7) Burn during the season when burning would have occurred.
8) No fire farming (preventive fire lines inside wilderness).
9) Let wilderness evolve.
10) Wilderness Act does not guarantee ecosystem existence.
11) What happens if the burn program does not result in Longleaf Pine and pitcher plant continued existence?
12) Lighting caused fires should be allowed to burn.
13) Lighting caused fire outside UIWA should be allowed to burn.
May 29, 2007, the LSC submitted scoping comments to William E. Taylor, FS, District Ranger, Angelina/Sabine National Forests, NFGT, about a proposal to prescribe burn 13,300 acres of the UIWA to reduce hazardous fuels.
Among the comments made, the LSC referred specifically to quotes in the Wilderness Act of 1964 about what wilderness is and specific provisions in the President’s Council on Environmental Quality (CEQ) and the FS Handbook which deal with the National Environmental Policy Act (NEPA) and how it should be applied. An environmental impact statement (EIS) should be prepared.
June 3, 2007, the LSC prepared an article about trammeling entitled, “When is Trammeling With Fire in Wilderness Justified?”, about the proposed UIWA prescribed burn. In this article the LSC stated:
“The Sierra Club supports the following for the proposed UIWA prescribed burning proposal:”
“1) The FS must mimic the natural fire regime by replicating the natural fire frequency, seasonality, rate, duration, start locations, and patchiness of burn that occurred before humans altered the natural ecological process of fire.”
“2) Fire lanes must be established outside of wilderness boundaries on either national forest or private lands. No internal fire lanes should be allowed.”
“3) Only hand starting fires is allowed. No use of helicopters (to start fires), which destroy wilderness character, solitude, quiet, and enjoyment of natural sounds must be allowed.”
“4) Naturally ignited wildfires (lightning) must not be suppressed and must be allowed to burn in UIWA.”
“5) The prescribed burning program must not allow the manipulation of fire to favor any type of plant or animal species or community. Nature, wilderness, and fire will decide what plant communities exist on the landscape.”
July 26, 2007, the LSC sent a letter to William E. Taylor, FS, District Ranger, Angelina/Sabine National Forests, NFGT, about this issue and stated:
“The Sierra Club understands that the U.S. Forest Service is proposing to reduce hazardous fuels in UIWA. However, we believe that since the FS is also considering additional human manipulation regarding restoration of Longleaf Pine and other ecosystems in UIWA in the foreseeable future and because it is anticipated that reducing hazardous fuels may require significant human manipulation in Wilderness and could take a significantly long time (5-10 years) that the cumulative impacts of these proposals should be covered in the environmental analysis, evaluation, and assessment that is required under the National Environmental Policy Act (NEPA). In our view this means that an environmental impact statement (EIS) is necessary.”
“Although the FS did not formally put forward any desired future conditions (DFC) in the public scoping notice it is evident from the FS’s own documentation that such DFC are contemplated and will result in significant human manipulation in Wilderness. This further suggests that an EIS is necessary to fully inform the public so it can review, comment on, and understand the full environmental implications of all past, present, and future foreseeable actions … that are associated with the proposal for management of UIWA. In addition, this is the first time in the NFGT where prescribed fire has been proposed for any wilderness area and only the second time, to our knowledge, in the national forests in the entire southeastern United States. The intensity, magnitude, and controversy of such actions indicate that an EIS is needed to provide full analysis of these actions and to ensure full protection and compliance with the Wilderness Act.”
The LSC made a FOIA request to the FS for information about the “Tick Seed Fire” in UIWA of August 2008 and stated, “The Sierra Club … was not aware that this fire occurred and that the U.S. Forest Service entered UIWA and used mechanical or motorized equipment to fight this 40 acre fire. It was disturbing to see young Longleaf Pine seedlings and saplings had been cut and the vegetation either disturbed or destroyed on areas that had been recovering from human use for 25 years.”
“The additional mitigation measures the Sierra Club wants incorporated in the UIWA prescribed burning proposal include:”
“1) Use After action reviews (AAR) for each UIWA prescribed burning.”
“2) Require that a wilderness resource advisor (WRA) is assigned to all UIWA prescribed burns.”
“3) Implement the Fire Management Action Plan for UIWA, April 14, 1994, page 10, so that the plan objective of “Natural (lightning caused) fires will be permitted, as nearly as possible to play their natural ecological role” will occur.”
“4) Require that a wilderness “information needs assessment (INA)” be prepared for prescribed burning in UIWA.”
“5) Review and incorporate features and mitigation measures from other wilderness fire plans and state in the EA (environmental assessment) which plans were reviewed and used.”
“6) Consider the impacts of the proposed UIWA prescribed burning on both present and future visitors of the proposal and how trammeling can be reduced.”
“7) Wash helicopters, pumps, and other equipment so non-native invasive plant species seeds or parts are not brought into UIWA.”
“8) Complete the “Minimum Requirements Decision Guide” for all use of motorized/mechanized equipment with public review and comment.”
“9) Use minimum width, depth and canopy clearance to check fire spread and state what this will be in the EA.”
“10) Remove all signs of human activity and rehabilitate all areas disturbed by management activities to as natural an appearance as possible.”
“11) Obliterate and block constructed lines by pulling material back onto them and scattering vegetative debris over them so that trammeling does not occur continuously after the prescribed burn until the next prescribed burn. This will also reduce illegal motorized use in UIWA.”
“12) Prepare and present a draft monitoring plan now for public review and comment.”
September 3, 2009, the LSC submitted comments to the NFGT about an August 20, 2009 public notice for an environmental assessment (EA) for the “Upland Island Wilderness Fire Management Initiative (UIWFMI)”.
In detail, the LSC critiqued the UIWFMI and associated documents, like the “Botany Report”. The LSC requested that it “be kept updated by the FS regarding the progress of this proposal.”
September 25, 2009, the LSC sent a letter to the NFGT and the Angelina/Sabine National Forests after a September 22, 2009 meeting and visit with the FS in UIWA about additional mitigation measures for the draft EA that the FS had prepared for the UIWFMI and stated:
“The adequacy and level of the environmental analysis, comprehensive and complete response to comments, additional mitigation measures required, and reduction in trammeling are keys to finding whether an acceptable alternative will be found to conduct hazardous fuel burns in UIWA.”
March 29, 2010, the LSC sent a letter to Linda Brett, FS, Forest Supervisor, NFGT, about the FOIA information received on the “Tick Seed Fire” in UIWA and stated:
“Our concern is that the FS appears to equate this lightning fire and the burning it did in UIWA with the loss of “wilderness resource values. However, since wilderness is supposed to be a place where natural functioning ecological processes are not manipulated by humans, the killing of trees or other “resource values” is not bad, per se. Nature is supposed to call the shots in wilderness and humans are supposed to be humble visitors. It appears to us in the documentation we received about the Tick Seed Fire that the FS focused too narrowly on what were “wilderness resource values” and did not mention the negative impacts (as well as the positive effects that FS actions have on wilderness.”
“The Sierra Club walked with you in the fall to the location of the Tick Seed Fire and saw that mature Longleaf Pines had been killed by this fire. However, we do not equate the presence of Longleaf Pine as the purpose of UIWA and do not equate their deaths as being a bad thing.”
“… earlier the total burnout was listed as … 13,300 acres, in other words the entire UIWA. This is a highly unlikely scenario since the FS in making this assumption incudes the entire Neches River Floodplain, including sloughs, cypress swamps, and other very wet areas which even in August are not likely to burn. Such overestimates using assumptions that are not realistic add to the attitude the FS expresses … that much human interference for fire-fighting purposes must be allowed.”
“It appears to the Sierra Club that the FS does not equate the use of leaf blowers as being harmful to wilderness resources and values. The FS appears to think using leaf blowers protected wilderness resources and values. If by protection of wilderness resources and values the FS means fighting a natural lightning fire to keep this natural functioning ecological process from working then there is a definite problem in the FS with how it understands what wilderness is about. Leaf blower use may allow the FS to fight the fire better but using leaf blowers negatively impacts wilderness resources and value like solitude, quiet, and the enjoyment of natural sounds, and negatively impacts and stops a natural functioning ecological process of lightning fire from working in wilderness.”
Unfortunately, this warning from the LSC didn’t have the intended effect of more careful analysis in the final EA for the UIWFMI. The decision on this proposal was signed by the FS on April 28, 2010 and brought the conflict about fire management in UIWA into the open, to a new level, and to a head.
The UIWFMI that the FS approved on April 28, 2010 allowed massive trammeling which included:
1) Prescribed burns on 11,900 acres in UIWA to reduce hazardous fuels.
2) Prescribed burns on 990 acres of adjacent private property, state lands, and national forest lands.
3) Created a 1,260 acre “No burn Area” near Graham and Cypress Creeks in UIWA.
4) 16.4 miles of fire control lines on the exterior of UIWA.
5) 14.4 miles of interior fire control lines within UIWA.
6) Use of helicopters to burn.
7) Use of leaf blowers to create fire control lines.
June 11, 2010, the LSC appealed the FS decision to prescribe burn UIWA to the Chief’s Office in Washington, D.C. The appeal made many requests for changes to the UIWA prescribed burning decision and stated:
“1. Modify Alternative 2, the chosen alternative, so that hand tools only (no leaf blowers) are used to prepare interior fire lines inside Upland Island Wilderness Area (UIWA). This ensures that wilderness character is better and more fully protected and trammeling is minimized. No leaf blowers would be used to prepare interior fire lines inside UIWA.”
“2. Modify Alternative 2, the chosen alternative, so after the completion in one day of every prescribed burn in UIWA the “mop up” patrols will be conducted on foot with no use of helicopters. This will better protect wilderness character and minimize trammeling. No helicopters would be used to patrol the burn after it is complete in one day unless a fire flare-up requires such use. Patrols for “mop up” of the burn after it has been complete will be done by foot. This ensures that wilderness character is better and more fully protected, better monitoring is conducted of the burn on-the-ground and site specifically by FS personnel on foot, will not result in any additional significant safety concerns for “mop up” crews, and will minimize trammeling in UIWA.”
“3. Modify Alternative 2, the chosen alternative, so that an “After Action Review (AAR)” is required for each prescribed burn in UIWA. This ensures that wilderness character is better and more fully protected and trammeling is minimized in UIWA.”
“4. Modify Alternative 2, the chosen alternative, so that a wilderness resource advisor (WRA) is assigned to all UIWA prescribed burns. The focus of the WRA will be to ensure that impacts on wilderness character and that trammeling are minimized. This ensures that wilderness character is better and more fully protected and trammeling is minimized in UIWA.”
“5. Modify Alternative 2, the chosen alternative, to require that a wilderness “information needs assessment (INA)” be prepared for each prescribed burn in UIWA. An INA ensures that wilderness character is better and more fully protected and trammeling is minimized in UIWA.”
“6. Modify Alternative 2, the chosen alternative, to require washing of helicopters, pumps, and other equipment so non-native invasive plant species seeds or parts are not brought into UIWA. This ensures that wilderness character is better and more fully protected and trammeling is minimized in UIWA.”
“7. Modify Alternative 2, the chosen alternative, to require completion of “Minimum Requirements Decision Guide” for all use of motorized/mechanized equipment with public review and comment. This ensures that wilderness character is better and more fully protected and trammeling is minimized in UIWA, and the public can comment on, review, and understand the proposal.”
“8. Modify Alternative 2, the chosen alternative, to obliterate and block constructed interior fire lines by pulling material back onto them and scattering vegetative debris over them so that trammeling does not occur continuously after the prescribed burn until the next prescribed burn. This also reduces the chance that illegal motorized use of UIWA will occur. This ensures that wilderness character is better and more fully protected and trammeling is minimized in UIWA.”
“9. Modify Alternative 2, the chosen alternative, to prepare a draft monitoring plan for the UIWFM and present it via a public comment period; finalize the monitoring program for the UIWFM using the public comments received; and implement the monitoring program for the UIWFM at the same time it is implemented. This ensures that wilderness character is better and more fully protected and trammeling is minimized in UIWA and the public can comment on, review, and understand the UIWFM before it is implemented.”
“10. Modify Alternative 2, the chosen alternative, to implement the Fire Management Action Plan for UIWA, April 14, 1994, page 20, so that the plan objective of “Natural (lightning caused) fires will be permitted, as nearly as possible, to play their natural ecological role” will occur. This ensures that wilderness character is better and more fully protected and trammeling is minimized in UIWA.”
“11. The Sierra Club requests that the EA be modified to make clear that some ping-pong balls will enter riparian areas directly (not purposefully) and analyze, assess, and evaluated the environmental impacts of this action so the public can review, comment on, and understand fully the environmental impacts of this proposal.”
“12. Modify the EA to include a map and discussion which documents where sensitive receptors (including people whose health is vulnerable to nuisance smoke) are located and how they may be affected by prescribed burning in UIWA. The FS does not state what the likelihood is of affecting these receptors. The FS does not state what would happen to these receptors if they are affected. For some people, who have existing respiratory diseases, a life threatening exposure to smoke could be the result. But the FS does not analyze, assess, and evaluate the impacts of breathing or being exposed to smoke and provide that to the public.”
“14. Modify the EA to cover fully and adequately all the scoping issues listed under E. 2. of this appeal.”
“15. Modify the EA to cover fully and adequately all the DEA issues listed under E. 2. of this appeal.”
“16. Modify the EA, DN (Decision Notice), and FONSI (to address “natural quality” as part of wilderness character for all ecosystems, plant communities, and species inside UIWA when discussing prescribed burning UIWA and establish “baseline or reference conditions” for all of those ecosystems, plant communities, and species and do so not only for those that are fire tolerant but also those that are not fire tolerant. Otherwise the FS cannot say it understands the entire “natural quality” part of wilderness character and the effects that the proposed UIWA prescribed burning will have on “natural quality” and wilderness character.”
“17. Modify the EA to make clear that some ping-pong balls will enter riparian areas directly and analyze, assess, and evaluate those environmental impacts of this action so the public can review, comment on, and understand fully the environmental impacts of this proposal. This occurs because the FS is unable to control the application well enough of the helicopter ping-pong ball applicator; is unable to determine and delineate riparian areas because the vegetation often hides streams and is difficult to see from the air; and is not able to maneuver the helicopter well enough to prevent ping-pong balls and this fire from burning in riparian areas where fire would not burn normally.”
“18. After modifications of the EA that have been recommended in this appeal have been made, release the EA as a supplemental document with a public comment period so the public can review, comment on, and understand fully the environmental impacts of UIWFM.”
June 24, 2010, the LSC met with Linda Brett, FS, Forest Supervisor, NFGT, to discuss the appeal of the UIWFMI. After this discussion, the FS and LSC agreed to seven terms/conditions which would provide more protection to UIWA during proposed prescribe burns. Those seven terms/conditions included:
1. No leaf blowers would be used to prepare fire lines.
2. Helicopter patrols after the burn would be limited to one flight/day.
3. A committee of FS personnel and the public would develop a monitoring plan.
4. Fire lines at entry points into UIWA would be blocked to prevent illegal ORV (off-road vehicle) use and the Sierra Club would have the opportunity to look at sites where fire lines have been created to make recommendations about blocking entry points.
5. FS personnel would clean hand tools before entering UIWA to prevent the introduction of non-native invasive plant species.
6. In the Graham Creek “No Ignition Area” fuel bridges would not be removed unless it is necessary to protect private property.
7. The FS will conduct an “After Action Review” and “Wilderness Information Needs Assessment” and have a Wilderness Resource Advisor present during all burning operations.
June 25, 2010, the FS resolution letter stated:
“We acknowledge that the UIWFMS EA … could be clear on some points … In future EAs we will clarify the issues you brought forward during this appeal.”
The LSC offered to work with the FS to ensure that all future EAs reflect better descriptions of environmental impacts, positive and negative, and will continue to monitor and work with the FS to ensure that UIWA is protected to the maximum extent possible from trammeling.
June 27, 2010, the LSC sent a letter to Linda Brett, FS, Forest Supervisor, NFGT, which thanked her and the FS for meeting on June 24, 2010 about the appeal of the UIWFMI. The LSC agreed with the June 25, 2010 resolution letter which stated that the seven terms/conditions would be adhered to for the UIWFMI and this led to the LSC’s withdrawal of its appeal. The LSC stated:
“In the June 25, 2010 resolution letter, the FS states “We acknowledge that the UIWFMI EA could be clearer on some points … A few (not all) of those issues include:”
”1) Better assess, evaluated, and analyze the effects that smoke from the prescribed burning proposal has on people as sensitive receptors and locate where those sensitive receptors are on a map.”
“2) Ensure that the positive and negative effects of a prescribed burning proposal on all ecosystems, not just fire tolerant ecosystems but also fire intolerant ecosystems, are adequately assessed, evaluated, and analyzed.”
“3) Ensure that words used to denote actions that will occur convey that actuality (for instance, monitoring program with public input will be implemented and not “may be” implemented).
“4) Adequately show what the FS threshold is for “trammeling” in wilderness; the total number of all “traveling” actions that will occur; and what the goal is for reduction of “trammeling” over what time period.”
“5) Ensure that the number of conclusory qualitative words and phrases used for describing environmental impacts is minimized and the definition for these words and phrases are such that they, themselves are not conclusory and qualitative.”
“6) Ensure that a former activity in wilderness, like a road, is not given dominance over the area of land that has been wilderness for over 26 years.”
“7) Do not state that burning only during the “cool season” equates to the “range of natural variability” since “growing season fire” also occurred regularly and should be mimicked to restore the “range of natural variability” for fire.”
October 20, 2010, the LSC provided initial input to Linda Brett, FS, Forest Supervisor, NFGT, about the Wilderness Information Needs Assessment (WINA) for prescribed burning of UIWA. The LSC listed 17 questions it wanted the WINA to address including:
“1) How do we minimize trammeling due to the proposed prescribed burn at UIWA?”
“2) How do we monitor trammeling due to the proposed prescribed burn at UIWA?”
“10) What are the effects of trammeling on fire tolerant and intolerant ecosystems due to the proposed prescribed burn at UIWA?”
“13) How will trammeling of areas in UIWA that were significantly disturbed before wilderness designation (like areas that used to be roads) but have had 26 years to recover be measured or monitored due to the proposed prescribed burn at UIWA?”
“15) How do we reduce noise (and thus the distance that trammeling occurs) which is created by the proposed prescribed burn at UIWA?”
October 26, 2010, the LSC sent a letter to the FS about the need for specific standards for “trammeling” for the UIWA prescribed burning project. This letter referred to a meeting on October 20, 2010, that the LSC had with the FS about this issue and stated:
“We were disappointed that the meeting resulted in few or no proposals which addressed “trammeling” in connection with Appendix A – Wilderness Threats Matrix; Appendix B – Wilderness Information Needs Assessment Worksheet; and Appendix C – Wilderness Information Needs Assessment Work Plan.”
“… The Sierra Club stated that it would submit input about a description of “trammeling” that the UIWA proposed prescribe project burn will have. The UIWA prescribe burn project must track levels of “trammeling” actions to determine whether a reduction of “trammeling” occurs over time.”
“… 1) A description of “trammel” should first have a definition of “trammel” so that everyone that is involved with the UIWA prescribe burn project clearly understands what “trammel” means. In the Random House Dictionary of the English Language, College Edition, 1968, the definition of “trammel” states, “hindrances or impediments to free action; restraints” and synonyms for “trammel” include “hobble, curb, inhibition, hinder, impede, obstruct, encumber.”
The Wilderness Act of 1964, Section 2(c), Definition of Wilderness, states:
“A wilderness, in contrast with those areas where man and his own works dominate the landscape, is hereby recognized as an area where the earth and its community of life are untrammeled by man”.
“Trammel” in the UIWA prescribed burn project, deals with human actions that interfere with wilderness and the free action of wilderness. This means that allowing natural processes to operate in wilderness is a part of avoiding the act of “trammeling”.
The prevention and reduction of “trammeling” in the UIWA prescribed burning project assists in the protection of “Wilderness Character” which is the responsibility of the FS in Section 2(a) of the Wilderness Act of 1964, and states:
“shall be administered for the use and enjoyment as wilderness … the preservation of their wilderness character.”
“… 2) The Sierra Club also believes that monitoring of “trammeling” should also, in some way, be able to answer the following questions:”
“a. What are the effects of “trammeling” on fire tolerant and intolerant ecosystems due to the proposed prescribed burn at UIWA?”
“b. What are the baseline reference conditions for all fire tolerant and intolerant ecosystems due to the proposed prescribed burn at UIWA?”
“c. How will the ecotones between slope plant communities and upland plant communities and riparian plant communities and upland plant communities be monitored and thus the “trammeling” level be documented due to the UIWA prescribe burn project?”
“d. How will “trammeling” of areas in UIWA that were significantly disturbed before wilderness designation (areas that at one time were roads) but have had 26 years to recover be measured or monitored due to the UIWA prescribe burn project?”
November 2, 2011, the FS finalized its “Upland Island Wilderness Fire Management Plan (UIFWMP) 2012”, that had been under preparation since 2006. The LSC wasn’t aware of the existence of this final document until 2021.
February 3, 2012, the FS sent the LSC an email inviting it to observe the first prescribed burn in UIWA. The LSC representative indicated a desire to observe this burn. Ultimately, the LSC representative couldn’t attend the burn which occurred on March 1, 2012.
April 18, 2012, the LSC sent a letter to Ike McWhorter, FS, Fire Ecologist, NFGT, and provided observations about a visit to UIWA to look at the results of the March 1, 2012 prescribed burn that the FS conducted and stated:
“As I recall one of the mitigation measures that was discussed in the EA was that the FS was going to block fire lines at their intersection with roads so that all terrain vehicles would not have easy access into UIWA. The fire line we walked was not blocked at County Road 4-4. The Sierra Club requests that the FS block the intersection of this fire line at County Road 4-4 and any other fire line intersections with roads in UIWA.”
“I observed that fire burned down to the bank on the east side of Mill Creek. This is of concern since the riparian trees along Mill Creek are not fire tolerant. Some of these trees include American Beech, American Holly, and southern Magnolia, have thin bark, and are easily wounded or killed by fire. The Sierra Club requests that the FS not drop the napalm-like ping-pong fire balls when it crosses over Mill Creek via helicopter.”
“I observed that fire burned down to the bank on the east side of Oil Well Creek … The Sierra Club requests that the FS not drop the napalm-like ping-pong fire balls when it crosses over Oil Well Creek via helicopter.”
“… I believe that the deer feeder was brought into UIWA by ATV … The Sierra Club urges the FS to increase its law enforcement surveillance in UIWA so that those who engage in illegal activities are caught and prosecuted.”
November 2013, the FS prepared a “Prescribed Fire Plan for UIWA”. The LSC was not aware of this plan until 2021.
January 4, 2015, the LSC sent a letter and inquired about its previous information request to Mark Van Every, FS, Forest Supervisor, NFGT, which dealt with the “Wilderness Areas Managed to Minimum Stewardship Level”. The January 4, 2015 letter had this to say about fire in wilderness:
“1) Element 1, Wilderness Fire Management”
“The Sierra Club has reviewed pages 22, 180, 181, and 183 in the 1996 Revised Land and Resource Management Plan (RLRMP) which are referred to in this element. Pages 180 and 181 say little or nothing about fire in wilderness. Page 21, which is not mentioned, refers to the use of prescribed fire and is entitled “Vegetation Manipulation” and then continues on page 22 and refers to burning for fire management, wildlife improvement, range improvement, and timber management.”
“This “Vegetation Manipulation” section mentions wilderness on page 22 as follows: “Prescribing fire in some wildernesses for fuels reduction and maintenance of fire-dependent ecosystems … use of fire in wildernesses is provided with the development of burning plans that would amplify the natural fire processes that have not been allowed to develop since establishment.”
“Responses that the Sierra Club wants from the FS about this element include:”
“Should wilderness be managed for “Vegetation Manipulation” when the Wilderness Act requires that wilderness be “untrammeled”?”
“Which specific wildernesses (the quote says “some wildernesses” so the assumption is that prescribed fire will not be used for all five wilderness areas) will prescribed fire be used for fuels reduction and or maintenance of fire-dependent ecosystems? The Sierra Club is aware of the prescribed fire plans for Upland Island Wilderness Area but not for the four other wilderness areas.”
“What specific parameters (prescription) will be used to allow wildfire (whether of lightning or human origin) to burn in the five wilderness areas?”
“What is the specific Fire Management Plan for each of the five wilderness areas?”
“What is the prescribed fire action plan for each of the five wilderness areas that identifies the specific areas where prescribed fire can be applied to reduce fuel loading so that outside resources many be protected and maintain a fuel level that would allow fire to play its natural role (page 183, MA-7-47)?”
“Has the FS implemented and evaluated the effectiveness of the Fire Management Plans for each of the five wilderness areas? If so, what are the results and if not when will this occur?”
“Once the Sierra Club has received the information that is requested at the end of this letter for this element it may have additional questions about “Wilderness Fire Management”.”
The FS did not respond to this LSC information request.
March 25, 2015, the FS conducted another prescribed burn in UIWA. The LSC didn’t observe this fire but did view where it burned in April/May of 2015.
March 30-June 1, 2015, the FS conducted post burn surveys and prepared the “Fire Effects Monitoring Report for the Upland Island Wilderness Prescribed Burn on March 25, 2015” report. The LSC was not aware of this report until 2021.
February 24, 2016, the LSC contacted the FS and reminded it about the information request (which included comment and information requested about fire in NFGT wilderness) made on January 4. 2015 that had never been fulfilled.
Over a period of months, the FS provided information about wilderness management including fire. For “Element 1, Wilderness Fire Management”, the FS provided the following information:
“Year Wilderness Stewardship Challenge (FY05-14), 1. Fire Management, Wilderness Stewardship Performance (FY15 on), 3. Natural Role of Fire, “scoring has changed for different levels of accomplishment. Wildernesses that have had wildfires or prescribed fires in the reporting year met fire management direction at the 6-point level. 2-point checkbox added: Post-season reviews for wilderness fire management practices are conducted. 2-point checkbox added: Wilderness resource Advisors are assigned to each wildfire and prescribed fire.”
The FS scored Element 1, Wilderness Fire Management, an 8 for all five NFGT wilderness areas and stated for each one that, “Wilderness is “Managed to Minimum Stewardship Level”: Yes”.
March 8, 2017, the FS prepared a “Revised Fire Effects Monitoring Plan and Sampling Design for NFGT March 8, 2017”, Draft March 19, 2017. The LSC wasn’t aware of this plan and sampling design until 2021.
April 2017, the FS conducted another prescribed burn.
March 19, 2021, the LSC found out that the FS hadn’t abided by its agreement of 2010 to tell the LSC when prescribed burns were going to occur in UIWA. A check of paper records and emails showed that the LSC had not been contacted by the FS since 2015 about any prescribed burns or any wildfires that occurred in UIWA.
March 25, 2021, the LSC discussed this issue via phone with Kimpton Cooper, FS, District Ranger, Angelina/Sabine National Forests, NFGT.
March 26, 2021, the LSC sent a letter to the FS and stated:
“On behalf of the Lone Star Chapter of the Sierra Club (Sierra Club) I want to provide some information that may have been forgotten over the years about a U.S. Forest Service (FS) agreement and responsibility in connection with prescribed burning in Upland Island Wilderness Area (UIWA).”
“On June 11, 2010, the Sierra Club appealed the Upland Island Wilderness Fire Management Initiative Environmental Assessment (UIWFMIEA). On June 24, 2010, the Forest Supervisor, Ms. Linda Brett, and I, on behalf of the Lone Star Chapter of the Sierra Club, had an informal resolution meeting about the UIWFMIEA.”
“After that meeting, the FS and Sierra Club came to an agreement which was documented in a June 25, 2010 letter from Forest Supervisor Brett to the Sierra Club. The agreement stated:”
“Mr. Mannchen agrees to drop his appeal of the UIWFMIEA based upon the following terms and conditions:”
“On June 27, 2010, the Sierra Club sent a letter to Forest Supervisor Brett and agreed with the seven terms/conditions contained in her FS June 25, 2010 resolution letter and contacted the email address provided in the FS letter to withdraw the Sierra Club appeal of the UIWFMIEA.”
“In the June 25, 2010 resolution letter, the FS stated, “We acknowledge that the UIWFMIEA could be clearer on some points … In future EAs, we will clarify the issues you brought forward during this appeal.”
“4) Adequately show what the FS threshold is for “trammeling” in wilderness; the total number of all “trammeling” actions that will occur; and what the goal is for reduction of “trammeling” over what time period.”
“The Sierra Club offers to work with the FS to ensure that all future environmental assessments, evaluations, and analyses reflect a better description of environmental impacts, positive or negative.”
“The Sierra Club appreciates working with the FS to resolve our appeal of the UIW. Thank you.”
“It appears that the above agreement has not been fully implemented and has in parts, been forgotten. The Sierra Club states:”
“1) The Sierra Club learned that the FS was going to conduct a prescribed burn in UIWA this Spring, if possible. The Sierra Club was not notified about this.”
“I went back to past emails and found that through 2015, the FS notified the Sierra Club, when a prescribed burn was going to be conducted so that, if possible, the Sierra Club could send a representative to observe the burn. If the Sierra Club could not be present during the burn, it made plans after the burn to visit the burn site to view the results.”
“It is the Sierra Club’s understanding that it is to be notified before each prescribed burn so that, if possible, it can attend. The Sierra Club requests that the FS reintroduce notification of the Sierra Club about proposed prescribed burns in UIWA.”
“2) The third term and condition mentioned above, “A committee of Forest Service personnel and the public would be formed to develop a Monitoring Plan for Upland Island Wilderness burning”, in our view, has not been completed.”
“In October 2010, a meeting was held to discuss the “Monitoring Plan”. One issue discussed was monitoring for trammeling of UIW.”
“The Sierra Club was not notified that a “Monitoring Plan” was completed for prescribed burning in UIWA.”
“If a “Monitoring Plan” is complete for UIWA prescribed burning, the Sierra Club requests a copy. If a “Monitoring Plan” is not complete, then the Sierra Club requests re-initiation of FS efforts, with the Sierra Club and others, to complete the “Monitoring Plan”.”
“3) The Sierra Club has not had the opportunity to, “look at sites where fire lines have been created to make recommendations about blocking entry points.”
“4) The Sierra Club is not aware that the FS has prepared an “After Action Review and a Wilderness Information Needs Assessment”. If the FS has conducted an assessment, the Sierra Club requests a copy. The Sierra Club is not aware whether a Wilderness Resource Advisor has been present during each prescribed burn in UIWA.”
“5) Several of the 7 terms/conditions mentioned above should be documented so the FS can show the Sierra Club/public that they have complied with the agreement. These terms/conditions include:”
“1) No leafblowers would be used to prepare fire lines. Only hand tools would be used; 2) The use of the helicopter for patrolling after the burn would be limited to one flight per day. In the case of fire suppression, there would be no limit to the use of the helicopter for patrol; 3) Fire lines at entry points into Upland Island Wilderness would be blocked to prevent illegal Off Road Vehicle (OHV) use; 4) Forest Service personnel would insure that hand tools (rakes, etc.) are cleaned before entering Upland Island Wilderness to prevent the introduction of non-native invasive species; 5) In the Graham Creek No Ignition Area, fuel bridges would not be removed unless it is necessary to protect private property; and 6) The Forest will conduct an After Action Review and a Wilderness Information Needs Assessment. A Wilderness Resource Advisor will be present during all burning operations.”
“The Sierra Club requests a copy of documentation that shows that the terms/conditions have been met for each prescribed burn that has been conducted in UIWA.”
“The Sierra Club has provided with this letter, documentation (letters/emails) which shows the history of this issue. The Sierra Club does not claim that this documentation is complete but it does show what has occurred through 2015.”
“Finally, the Sierra Club commends Kimpton for monitoring and allowing a wildfire to burn about 400 acres in UIWA earlier this year. It is important for fire to play its natural role in Wilderness Areas. The Sierra Club is glad that the FS did not immediately suppress this fire but allowed it to burn naturally. If there is information about this fire, how it started, area burned (map), and condition of the area burned after the fire, the Sierra Club would like a copy.”
“The Sierra Club appreciates this opportunity to communicate with the U.S. Forest Service about UIWA and prescribed burning. The Sierra Club looks forward to re-initiation of collaboration on this issue as spelled out in terms/conditions in the June 25, 2010 Forest Supervisor’s letter.”
Kimpton Cooper, FS, District Ranger, Angelina/Sabine National Forests, NFGT, and the LSC had phone discussions and emails about these issues. An email on March 29, 2021 from Mr. Cooper stated:
“Thank you for your letter. We’ll review and follow up with you. Also I appreciate the phone call last week to discuss the issues you’ve brought forward in the letter. Once again my apologies for the oversight in providing you specific notice of our UIW fire plans and acknowledge that we will correct this oversight as we move forward.”
An email on March 29, 2021 from William E. Taylor, FS, Forest Supervisor, NFGT stated:
“Kimpton has or will be reaching out to invite you to the prescribed burn of a portion of UW for 2021. It has been several years (at least 2) since it was burned. Last burn on the north end was 2018 and the south end 2017 … I was the Ranger when the agreement was signed. We have not used leaf blowers for cleaning of lines for prescribed burning based on my knowledge, only hand tools … I appreciate your interest in the project. I believe it has been a success for everyone and demonstrates how a fire adapted wilderness can be managed with a light hand to prevent losing it and protecting surrounding homes, private property, etc. … We look forward to discussing the progress. I believe this is a project the Sierra Club, TCA and the Forest Service can be proud we worked together to implement. Thanks.”
April 1, 2021, a wildfire (“Wilderness Tram Fire”) burned 552 acres in BSWA in Davy Crockett National Forest. The FS allowed this fire to burn more acres than normal and didn’t attempt to suppress it immediately.
April 5, 2021, the FS sent an email which responded to the LSC March 26, 2021 UIWA agreement reminder letter. The FS stated for leafblowers:
“Please see “UIW Burn BurnPlan excerpt” document which provides direction to implementation personnel on requirements from collaborative agreement such as no mechanical tools for preparation and cleaning of tools before use in UIW, etc.”
“Specifically, I’ve highlighted some items on pages A-19 for this topic.”
For helicopter patrols:
“See Burn Plan excerpt described in item 1. Specifically, I’ve highlighted items on pages A-20 for this item.”
For the committee to create a monitoring plan:
“The committee meeting (Forest Service and interested public) occurred in October 2010. Following that meeting the attached monitoring plan has been used to guide fire effects monitoring efforts.”
For fire lane entry points:
“Please see attached UIW Rx Fire Maps (Northern Unit and Southern Unit). Also please see Burn Plan excerpt. Specific items are highlighted on page A-19.”
“We welcome any feedback or suggestions you might have once you’ve reviewed the fire lines at entry point locations. If you’d like to meet on site we can schedule some time to do so.”
For cleaning hand tool so non-native invasive plant species are not spread in UIWA:
“See Burn Plan excerpt described in item 1. Specifically see highlighted items on page A-11.”
For fuel bridges in the Graham Creek “No Ignition Area”:
“Please see Burn plan excerpt described in item 1. Check highlighted section on page A-11.”
“Also see UIW Rx Fire Maps which depict the no ignition zone.”
For After Action Reviews and Wilderness Needs Assessment:
“After Action Reviews (AARs) are conducted at the conclusion of each burn day and include fireline personnel and is focused on information sharing from the day’s activities as a learning exercise. In the past Larry Shelton has observed the AAR if he was able to stay to the very end of operations. I’m extending the same invitation to you if you’re able to make it to the burn. It is my understanding that the Wilderness Needs Assessment conversation occurred during the same Fall of 2010 meeting in which the collaborative group discussed the development of the monitoring plan and so this item was completed.”
“We have had a wilderness resource advisor engaged on all Rx Fire operations for UIW. Ike McWhorter has served this role for us.”
For notification of fire activities within Upland Island Wilderness:
“Again, I apologize for failing to provide specific notification to you and the Lone Star Chapter of Sierra Club when fire activities occur within Upland Island Wilderness (UIW). As previously discussed, we will notify you of the day before and morning of any potential prescribed fire operations within UIW as well as share information about any fire suppression operations within UIW once the emergency response phase of the operations allow. We are currently looking at some possibilities for latter part of this week. We’ll be in touch if it looks like any of these opportunities start to materialize as described above.”
For the Rockwall Church Fire:
“February wildland fire in UIW: As discussed on our 3/25 call, there was a wildland fire within UIW in February 2021 which occurred just shortly before the winter storms. I’ve attached a map of the burn area and shared some additional information below:”
“Fire Name: Rockwall Church Fire
Total Acres: ~410 acres
Duration of suppression activities: February 3, 2021 – February 22, 2021
Tactics and Strategies: Utilized natural features (stream channels) and installed handline (using MIST tactics) to contain the fire by indirect means. Also conducted burnout operations.”
“Weather patterns and wind directions allow for a more indirect approach. The fire was moving into the interior at a modest rate of speed. If fire had been moving toward exterior of wilderness and adjacent private ownerships or if the rate of spread were faster different tactics may have been warranted.”
“Ike McWhorter was our wilderness advisor for the fire response. Additionally, our NFGT Recreation Program Manager was also onsite in a Wilderness advisor trainee role.”
April 9, 2021, the LSC sent an email to Kimpton Cooper, FS, District Ranger, Angelina/Sabine National Forests, NFGT, about UIWAFMI implementation. The LSC stated:
“On behalf of the Lone Star Chapter of the Sierra Club (Sierra Club), I want to thank you for stating that in the future the U.S. Forest Service (FS) will notify the Sierra Club when there is a prescribed burn in Upland Island Wilderness Area (UIWA) as agreed to in the 2010 Upland Island Wilderness Fire Management Initiative (UIWFMI) appeal resolution. The Sierra Club also appreciates your commitment to notify it when a wildfire occurs in UIWA.”
“This letter has requests which refer to the materials that the FS sent the Sierra Club on April 5, 2021, due to our March 26, 2021 letter which reminded the FS about UIWFMI resolution commitments. The Sierra Club appreciates the information that you sent to us. Thank you.”
“The Sierra Club wants to continue this dialogue so that we all learn and benefit from our joint interest in protection of our Wilderness resource in the National Forests and Grasslands in Texas (NFGT).”
“1) As mentioned above the Sierra Club appreciates the FS’s renewed commitment to the UIWFMI agreement.”
“The last FS notification the Sierra Club has about prescribed burns in UIWA is from 2015. The Appendix A: Prescribed Fire Plan, November 2013, B. Vegetation/Fuels Description, Pages A-6 through A-9, Catahoula Ecological Management Unit, indicates that Burn Blocks A, B, C, and D had prescribed burns in FY 2017 and for Manning Ecological Management Unit, that Burn Block E had prescribed burns in FY 2012 and FY 2016. The FS does not show any prescribed burns for the Alluvial Ecological Management Unit – Fire Exclusions/No Ignitions Zones.”
“Information Request: The Sierra Club requests a map and description of the prescribed burns conducted in the UIWA Catahoula Ecological Management Unit, Burn Blocks A, B, C, and D, in FY 2017 and Manning Ecological Management Unit, Burn Block E, in FY 2016.”
“Request: The FS does not have a working mechanism (institutional memory) to track compliance with appeal/objection resolutions over time. The Sierra Club appreciates that District Ranger Kimpton Cooper was not the District Ranger at the time of the UIWFMI appeal resolution in 2010.”
“Someone in the FS should have told Kimpton about the UIWFMI resolution and the requirements that applied to the FS. This did not occur. Therefore, the Sierra Club was not informed about the prescribed burns that occurred in FY 2016 and FY 2017 in UIWA.”
“The Sierra Club requests that the FS prepare and implement a mechanism that tracks appeal/objection resolution implementation over time. This mechanism can also be used for other FS projects where the public has provided input and the FS has agreed to incorporate public suggestions in projects without an appeal/objection.”
“2) The Sierra Club is concerned that the is FS moving away from the objectives of the UIWFMI. Pages A-12 through A-13, Appendix A: Prescribed Fire Plan, November 2013, B. Vegetation/Fuels Description, list four resource objectives for the UIWFMI. These four objectives are: 1) “To provide, as a first priority, safety for human lives and property”, 2) To reduce hazardous fuels that pose unacceptable risks to lives and property”, 3) “To preserve, to the fullest extent possible, wilderness character and associated values”, and 4) “To restore fire to its natural, ecological role in the ecosystem.”
“The April 28, 2010 Decision Notice (DN) and Finding of No Significant Impact (FONSI), indicates that there are different objectives for the UIWFMI. In that document it says, “My decision to implement Alternative 2 is based on its effectiveness to reduce hazardous fuels in UIW, to protect human life and adjacent private property, to increase the safety of wildland firefighters who would have to respond to wildfires within UIW, and to protect the ecosystems in UIW from possible wildlife conflagrations or high severity fires. This project will reduce the hazardous fuels that have developed in UIW as a result of fire suppression during the last 25 years since it was designated as wilderness. It will also result in a wider range of options for responding to unplanned ignitions in the wilderness.”
“The November 2009 Environmental Assessment (EA) for the UIWFMI also has different objections than Appendix A: Prescribed Fire Plan, November 2013, B. Vegetation/Fuels Description.”
“The EA objectives are described on Page 1, EA, 1.1 Introduction, “The National Forests and Grasslands in Texas (NFGT) is proposing to use prescribed fire in order to reduce hazardous fuels in Upland Island Wilderness (UIW) on the Angelina/Sabine Range District.”
“The objectives that the FS lists in Appendix A: Prescribed Fire Plan, November 2013, B. Vegetation/Fuels Description, are not the same as those found in the DN/FONSI/EA. The DN/FONSI/EA objectives require that the UIWFMI, “to protect human life and adjacent private property, to increase the safety of wildland firefighters who would have to respond to wildfires within UIW, and to protect the ecosystems in UIW from possible wildlife conflagrations or high severity fires”. The DN/FONSI/EA do not require, “To restore fire to its natural, ecological role in the ecosystem”.
“This is what is called “mission creep”, when an agency, over time (in this case 11 years), diverges from the direction it is supposed to go. The FS has engaged in “mission creep” and diverged from what it is supposed to do according to the UIWFMI and appeal resolution.”
“The FS further emphasizes this “mission creep” in the “Appendix A: Prescribed Fire Plan, November 2013”, when it states, “Restoring the ecological role of fire is a long-range goal for the wilderness … Only once fuel reduction objectives are achieved, can a proposal for restoring the ecological role of fire be considered … and prescribed burning to achieve wilderness fire management objectives”. This is described as part of, “To restore fire to its natural, ecological role in the ecosystem.”
“This is not what the UIWFMI requires. These statements document that there is movement by the FS to expand trammeling in UIWA now and in the future under the UIWFMI and allow the creation of more human manipulation and control for restoration of a certain ecological role and fire management objectives in UIWA. This action is not appropriate for the UIWFMI and does not fit in, is against, and is not an objective of the UIWFMI.”
“These statements indicate that in the future the FS intends to further push the intensity of trammeling and prepare and implement a “proposal” for systematic manipulation and control of UIWA to favor certain ecosystems or vegetative communities via “wilderness fire management objectives”. These actions subvert the intent of the UIWFMI objectives and their implementation.”
“The Sierra Club’s concern has been long-standing. See the enclosed July 26, 2007 letter to Eddie Taylor, District Ranger, second paragraph, where the Sierra Club states, “The Sierra Club understands that the U.S. Forest Service (FS) is proposing to reduce hazardous fuels in UIWA. However, we believe that since the FS is also considering additional human manipulation regarding restoration of Longleaf Pine and other ecosystems in UIWA in the foreseeable future and because it is anticipated that reducing hazardous fuels may require significant human manipulation in Wilderness and could take a significantly long time (5-10 years) that the cumulative impacts of these proposals should be covered in the environmental analysis, evaluation, and assessment that is required under the National Environmental Policy Act (NEPA). In our view this means that an environmental impact statement (EIS) is necessary.” An EIS was never prepared by the FS.”
“This apparent bias is reflected on Page A-10, Appendix A: Prescribed Fire Plan, November 2013, when the FS states, “With the increased sunlight desired grasses and forbs are visible and present.” The FS is not supposed to choose what is desired or not in Wilderness. Let the natural processes work and whatever results is desirable.”
“The ecological role of fire in ecosystems in UIWA may occur or be approached due to prescribed burning to reduce hazardous fuels, but this is an ancillary effect and should not be one of the objectives of the UIWFMI.”
“The Sierra Club, over the years, has had discussions with FS employees involved with UIWFMI. Our understanding from them has been that they and the FS know that prescribed burning of UIWA, using an objective to implement restoration of “fire to its natural, ecological role in the ecosystem” is not allowed. Hazardous fuel reduction is allowed.”
“It may be more likely that the FS can allow lightning started fires to burn and not be suppressed in UIWA due to prescribed burning to reduce fuels, but this is not an objective of the UIWFMI.”
“Request: The Sierra Club requests that the FS to remove from Appendix A: Prescribed Fire Plan, November 2013, and any other prescribed fire plan that will be used for UIWA in the future, any objectives that are not the objectives of the UIWFMI DN/FONSI/EA.”
“This means that the only objectives that will be implemented in an UIWA prescribed fire plan are, “to protect human life and adjacent private property, to increase the safety of wildland firefighters who would have to respond to wildfires within UIW, and to protect the ecosystems in UIW from possible wildlife conflagrations or high severity fires”.”
“3) April 5, 2021 FS email, 4., the FS states that, “We welcome any feedback or suggestions you might have once you’ve reviewed the fire lines at entry point locations.”
“In Appendix A: Prescribed Fire Plan, November 2013, Page A-19, Interior Control Lines: handlines within wilderness, the FS makes a similar statement, “Project cooperators will have the opportunity to look at sites where fire lines have been created to make recommendations about blocking entry points.”
“The Sierra Club provided feedback in the past about fire line entry points but did not receive any communications from the FS about its input. The Sierra Club sent a letter on April 18, 2012 (copy enclosed) to the FS. In that letter, the Sierra Club stated, “At Mill Creek we walked in on a bulldozed fire line at the UIWA and private land boundary. As I recall one of the mitigation measures that was discussed in the environmental Assessment (EA) was that the FS was going to block fire lines at their intersection with roads so that all-terrain vehicles would not have easy access into UIWA. The fire line we walked was not blocked at County Road 4-4. The Sierra Club requests that the FS block the intersection of this fire line at County Road 4-4 and any other fire line intersections with roads in UIWA.”
“Request: When the Sierra Club submits suggestions for blocking fire lines at roads and other places, the FS will respond to the Sierra Club about the suggestions.”
“4) April 5, 2021 FS email, 7., the FS states, “It is my understanding that the Wilderness Needs Assessment conversation occurred during the same fall of 2010 meeting in which the collaborative group discussed the development of the monitoring plan and so this item was completed.”
“The Wilderness Needs Assessment for UIWA was never completed. Attached are copies of the Sierra Club’s October 20, and 26, 2010 letters to the FS about WNA and need for specific standards to address trammeling. The Sierra Club never received from the FS any response to these letters or any final document that showed what the FS planned to do to complete the WNA.”
“Attached are the notes taken at the October 20, 2010 planning meeting for the WNA. The Sierra Club never received any additional information about the WNA after this time. From the Sierra Club perspective, the WNA was never completed. Also attached is one version of what and how a Wilderness Information Needs Assessment is and can be prepared.”
“7) Appendix A: Prescribed Fire Plan, November 2013, B. Prescribed Fire Objectives, Page A-13, the FS states that “The development of these objectives and standards generally follows the LAC process”.
“The Sierra Club believes that this statement is not correct. The Limits of Acceptable Change (LAC) process requires public input and collaboration. Any public input and collaboration was cut short in the WNA process and was not set-up like the LAC process. One meeting of just a few of the members of the public does not make a LAC process.”
“There was a draft LAC process conducted on Turkey Hill and Upland Island Wilderness Areas in 1993 but the Sierra Club understands that this was never completed, accepted, and implemented by the FS.”
“8) There is an issue of trammeling when the FS implements the UIWFMI that was not fully revealed in the DN/FONSI/EA. The Sierra Club was not aware that the FS would establish fire plots and remove vegetation and disturb soil for sampling, data acquisition, and monitoring purposes.”
“The March 8, 2017, “Revised Fire Effects Monitoring Plan and Sampling Design for NFGT” document sets out a protocol for monitoring/sampling. The impacts of the monitoring/sampling were not defined in the DN/FONSI/EA.”
“The EA says under 2.5.3 Monitoring that, “The effects of these prescribed burns would be monitored to assess the process of reducing hazardous fuels in UIW … If the monitoring results indicate the progress in reducing hazardous fuels in sufficient, a fire management program that seeks to mimic the frequency and intensity of the natural fire regime may be proposed in the future – with full public involvement and collaboration.”
“This indicates the FS plans to trammel additionally in the future to create a fire regime that it considers is “natural”. This is of concern.”
“It would appear that the FS did not reveal in the DN/FONSI/EA cumulative effects analysis, a description and the effects that monitoring/sampling have, and the cumulative effects that a future “fire management program” may have in UIWA. The FS also failed to describe the trammeling effects of monitoring/sampling and a future “fire management program”.”
May 10, 2021, the LSC requested from the NSC approval to participate in a FS in-the-field meeting on May 25, 2021, using Covid-19 safety protocols, to observe where a wildfire had burned in BSWA. Approval from NSC didn’t come so LSC members attended as interested citizens.
May 13, 2021, the LSC visited UIWA to view where the FS had conducted a prescribed burn on February 5, 2021. Observations included:
“We first stopped on Forest Road (FR) 314, at a small parking area, and walked north to the “High Point” in the Longleaf Pine Uplands. There used to be a small, human-made primitive trail at this point that led up to the “High Point”. Debris from the three prescribed fires since 2012, and particularly the most recent fire, obliterated the primitive trail.”
“There was much debris on the ground and standing, both from pine trees and understory trees that burned and died. A lot of this debris was Yaupon Holly and included dead and standing 1 to 2-inch-diameter understory trees. There was a lot of Longleaf Pine, and other pine (Loblolly and Shortleaf Pine) needles that fell since April 12th. Rain occurred the previous day and the ground in places was wet and soggy and sometimes you sank into the ground as you walked.”
“There were patches of grass growing on the long slopes to the “High Point”. There were areas where Bracken Ferns had grown-out since the fire along with Bull Thistle and greenbriar. I saw a Ground Skink in the burnt leaf litter and a Green Anole which climbed up a woody stalk. The American Beautyberry shrubs, which burned, were resprouting at the roots.”
“We walked along a seepage creek, about 8 to 12 inches wide. The riparian zone and most of the small hardwood trees had burned. We saw burned Red Maple resprout from roots and there were small Farkleberry, Sweetgum, Fringe Tree, Bluejack Oak, and American Holly along the creek, which flowed clear.”
“You could easily see the Catahoula Formation boulders and rocks on the slopes of the “High Point”. Feral pigs had wallowed and rooted on various parts of the “High Point”. On the west side of the “High Point” slopes, we found a small stream that had Longleaf Pine, along with Loblolly Pine, growing in the stream riparian area. Several Red Mulberry also grew here.”
“We left this area and continued to drive east on FR 314. We stopped to take photos of a blooming pitcher plant bog which grows on the side of the road. We drove north on FR 303 and then drove on County Road 4-4 west. We did not get to the northwest part of UIWA which burned because the road progressively got more washed out and we began to see downed trees on the road.”
“We doubled back and drove south on FR 303 on the east side of UIWA and stopped where a wildfire had burned on February 5, 2021, about 409 acres. We walked through this forest for several hundred yards. We saw how the fire effects were much less severe. This must have been a creeping light intensity groundfire. We crossed one small creek and stopped at a second. There were a lot of Loblolly Pine needles on the ground from the fire and some burn marks on trees and woody debris on the ground. We found a Three-toed Box Turtle, Partridge Berry, Jack-in-the Pulpit, and maybe a Spider Lilly in the wildfire burned forest.”
May 20, 2021, Brandt Mannchen, Forest Management Issue Chair, LSC, sent an email to Larry Shelton, TCA, and stated:
“Just want to be straight with you about fire in wilderness. I am not sure I can support more purposeful fire (prescribed fire in wilderness areas). The UIWA fire agreement was based upon fuel reduction to make the surrounding private and national forest land safer, from more severe fires. I am not sure I made the correct decision in 2010 when I agreed to the UIWA burning but that is water under the bridge now.”
“Burning on purpose in wilderness areas for ecological reasons is another matter when the Wilderness Act talks about being untrammeled. Letting wildfires burn in wilderness makes sense and I support that. But prescribed fires in wilderness, which trammel because humans light them and are specifically manipulated to burn a certain way adds further traveling.”
“Just wanted to let you know.”
May 25, 2021, several members of the LSC, as interested citizens, met with the FS and TCA to view where a wildfire had burned in BSWA. The following information was collected on this visit:
“The fire started on April 1, 2021 and burned about 552 acres. The fire was mostly contained on April 2, 2021. The FS does not know if the fire was started by humans or lightning. The investigation of the fire is ongoing. The fire burned 200 plus acres on the first day. The Incident Commander was Paul Hicks. The fire was discovered about 10:30 am. On the first day, winds were from the north (pushing south) and burned 5-7 chains/hour (a chain is 66 feet) with a flame length of 4-7 feet.”
“A backing fire was used to protect private land in the south. The flame length for this fire was 1-2 feet. The wind shifted to the south and southwest the second day (April 2, 2021). The FS used a dozer to blade roads on private land to contain the wildfire.”
“There were 8 people available to fight the fire on the first day. The FS felt it was short of people in DCNF to fight the fire because in Sam Houston National Forest and Angelina National Forest there were prescribed burns being conducted that day. A handline was put in BSWA on the east side to protect private land. The FS was able to use private property to observe the fire from a hill. The concern in the area is for the private land with houses and industrial pine plantations.”
“When the fire burned north on the second day, it hit the floodplain (natural fire control line) and by 8-9 pm the FS left because the fire was contained by the hand lines and the floodplain. The third day movement stopped and movement of the fire on the second day was slower than movement on the first day.”
“The falling of large snags during the fire is a safety issue. The FS erred on the side of caution on allowing the fire to burn to the point where it was contained. The fire stopped on the west side at Houston County Road 1175. This is where we discussed the fire and entered BSWA.”
“The FS talks to landowners about defensible space around their homes and being fire-wise about what their homes are made of. However, unless there has been a droughty year with a lot of fire (bad fire season) people get complacent and forget to focus on their homes each year to reduce vegetation and not have flammable material next to their houses.”
“The 8-15-year-old industrial pine plantations are a big problem and burn very intensely. Companies thin these plantations by 12-15 years and are not willing to invest the $30-40/acre needed to reduce fire hazard via prescribed burning.”
“Jamie (Sowell) said that Upland Island Wilderness Area (UIWA) has a lot of fuel and the FS would like to put fire in every wilderness. However, the FS does not have the energy or capacity to do planning for each individual wilderness. Each wilderness is different and fuel hazards will have to be addressed via individual wilderness area.”
“Larry (Shelton) said that BSWA had a 30-year build-up of fuels but burned well. It helped that there was Spring green-up when the fire started because this moderated fire intensity.”
“We walked into BSWA about 100 yards and talked about the fire. I noted wherever there were pine trees (bark) or pine tree debris, downed woody debris, branches, needles, limbs, etc., that this was where the fire burned most intensely.”
“Larry stated that the terrace soils at this site consist of 5-6 inches of loamy soil over hard clay. This keeps the soil moist because the water does not percolate well due to the tight clay soils. There were extensive signs of water flow (debris piles) throughout the part of BSWA where we walked. There were many swales and depressions.”
“I saw the following plants as we walked through or over the swales, mounds, flats, and other topography of BSWA: White Oak (some very large trees), Eastern Hophornbeam, American Hornbeam, Loblolly Pine, Shortleaf Pine, Shagbark Hickory, Sweetgum, grapevine species, Virginia Creeper, Poison Ivy, American Beautyberry, White Ash, Canadian Black Snakeroot, greenbriar species, Carolina Jessamine, Crossvine, American Holly, Southern Red Oak, other red oak species (perhaps Shumard, Swamp Red, or Cherrybark Oak), Green Dragon, Sassafras, Ebony Spleenwort, Bracken Fern, Partridge Berry, legume plants (pea plants), and White-flowered Milkweed (Asclepias variegata).”
“In some places, there were large numbers of an unidentified pea plant (legume) and Bracken Fern (fire fern). Some of the understory that was killed or severely wounded by the fire included American Holly, American Hornbeam, American Beautyberry, Eastern Hophornbeam, and Yaupon Holly.”
“We found an illegal deer blind as we walked through BSWA after FS personnel left. We walked past the old Forest Road 519 and past and on the 4 C’s Trail. The up and down of BSWA here was impressive with many mounds and depressions or small stream channels or ravines.”
May 26, 2021, Kimpton Cooper, FS, District Ranger, Angelina/Sabine National Forests, NFGT, sent a letter to the LSC in response to the April 9, 2021 letter about the UIWA Prescribed Burn Project. The FS provided an UIWA vicinity map which showed the burn blocks in the Catahoula and Manning Ecological Management Units. The FS stated it was working on ways to ensure that objection resolutions are tracked over time.
The FS didn’t remove the language that the LSC was concerned about which said that prescribed burning in UIWA was “To restore fire to its natural, ecological role in the ecosystem” but said that this was a “Fire/Fuels Program level objective and not the purpose of the Upland Island Wilderness Prescribed Fire Project which is to reduce hazardous fuels.”
The FS also didn’t remove the management objectives listed for longleaf pine ecosystems because these were for all the NFGT and not just wilderness. The FS did say that it would “share the draft burn plan before the next UIW burn entry” with the LSC.
The FS stated it would “do better at closing the loop on comments submitted related to the blocking of UIWA Fire lines.”
June 1, 2021, the LSC sent an email to Jamie Sowell, FS, Forest Fire Management Officer, NFGT, which said:
“It was good to meet and talk with you last week at Big Slough Wilderness Area.”
“Due to trammeling in wilderness the Sierra Club is very concerned about the use of prescribed fire. The Sierra Club supports doing what you, Robert, and others did: allow wildfire to burn as much as possible in Big Slough Wilderness Area to provide fire ecosystem effects.”
“The Sierra Club prefers this minimal wildfire policy (reduced suppression) and only in limited instances allow planned ignitions. Natural revegetation in wilderness makes sense and for dangerous fuel accumulations a comprehensive fire management plan should be required. Since each wilderness area is different this would require a plan for each wilderness individually.”
“If you get down to Sam Houston National Forest I would love to go to Little Lake Creek Wilderness with you and take a look. We can access this wilderness at three locations from the Lone Star Hiking Trail.”
June 2, 2021, Jamie Sowell responded to the LSC June 1, 2021 email and stated:
“Thank you Brandt, I enjoyed the visit also. It’s always great and really benefits me in my duties to hear different perspectives and insight into things. I appreciate your support and look forward to working with you in the future.”
June 6, 2021, the LSC sent the FS a response to its May 26, 2021 letter about UIWAFMI and stated:
“With this letter, there are several continuing issues/concerns that the Sierra Club brings to your attention that stem from the May 26, 2021 letter.”
“2) Page 1 of the May 26, 2021 letter, the Sierra Club appreciates that the FS is working on ways to prepare and implement a mechanism that tracks appeal/objection resolution implementation over time (institutional memory). When further progress is made the Sierra Club would like to be informed of the results.”
“3) Page 2 of the May 26, 2021 letter, it’s not clear how the objective of the UIWA Fire Management Initiative (UIWAFMI), reduce hazardous fuels, is interrelated and affected by the objectives of the Fire/Fuels Program level via the Revised Fire Effects Monitoring Plan.”
“The objectives are contradictory between these two documents particularly when it comes to the Wilderness Act requirement of not trammeling due to its negative effects on wilderness character.”
“It’s troubling that the FS is unwilling to separate out, in the Revised Fire Effect Monitoring Plan, wilderness so that it is not treated the same as the National Forests and Grasslands in Texas (NFGT) with a goal of establishing a certain type of forest ecosystem.”
“The FS should explain in both documents and show how employees are not going to confuse the two documents’ objectives.”
“Otherwise, the FS will trammel UIWA by managing for the Longleaf Pine Ecosystem or the restoration of fire to its natural ecological role in this ecosystem which means more human manipulation and trammeling which the Wilderness Act doesn’t allow.”
“The Sierra Club is not satisfied or happy that the FS refuses to remove from Appendix A: Prescribed Fire Plan, November 2013, and any other prescribed fire plan that will be used for UIWA in the future, any objectives that are not the objectives of the UIWFMI DN/FONSI/EA.”
“The Sierra Club is disappointed that the FS refuses to remove “restore fire to its natural, ecological role in the ecosystem” from the UIWA prescribed fire plan because it is not the “hazardous fuels reduction” objective of the UIWFMI. The FS appears to set-up and support trammeling of wilderness when the Wilderness Act does not allow this. This is of great concern to the Sierra Club.”
“6) Pages 2 and 3 of the May 26, 2021 letter, the Sierra Club is concerned that the FS that a Wilderness Needs Assessment (WNA) was conducted but does not speak to its completion with full public participation.”
“The FS states that notes of the meeting in October 2010 were sent to people who attended the meeting. Priority items were not all addressed and placed in the wilderness character and fire effects monitoring document. Trammeling was one such issue that was discussed but was not resolved.”
“The October 20, 2010 notes for the “Upland Island Wilderness Information Needs Assessment Meeting” state, “B. Wildlife: Question: How do we minimize effects to wildlife?”; “2. Recreation: Question: Does use increase after burning? Is use affecting the resources? How are we going to monitor?”, etc.; “3. Invasives: Question: Would invasives increase as a result of burning? How are we going to monitor? Periodic surveys by the Forest Botanist … Costs?”.”
“The meeting notes also state, “We will follow up with completed worksheets and proposed work plans.” This never occurred. The worksheets and proposed work plans were never distributed to participants and no solicitation of comments for these occurred.”
“The Sierra Club objects to this cursory and less than collaborative manner of working with the public. We do not appreciate being left out of the loop after being invited in by the FS. The Sierra Club again requests that the FS finish the worksheets and work plans with public input and address how to reduce trammeling in all of its actions in UIWAFMI.”
“8) Pages 3 and 4 of the May 26, 2021 letter, the Sierra Club disagrees with the FS that “The development of these objectives and standards generally follows the LAC process”. Since the LAC process is a public process and since this document was not provided for public review and comment the FS cannot claim that the Limits of Acceptable Change (LAC) process was generally followed.”
“The Sierra Club again states that if the FS is going to use the LAC process for the UIWFMI, the entire public must be invited to participate.”
“8) Page 4 of the May 26, 2021 letter, the FS does not answer the Sierra Club concern that establishment/use of vegetation plots were not list as a trammeling issue in 2010 and their effects were discussed not in the UIWAFMI EA.”
July 26, 2021, the LSC sent an email and letter to Eddie Taylor, FS, Forest Supervisor, NFGT, about the UIWFMP 2012 and stated:
“Attached is a letter that comments on concerns about the Upland Island Wilderness Fire Management Plan, 2012 (UIWFMP).”
“As stated in the Sierra Club letter, until recently the Sierra Club had never seen the UIWFMP. This is why, 9 years later, we are only now providing comments about that document.”
“In addition, there is a copy of a Sierra Club letter on trammeling in Upland Island Wilderness Area that we sent the NFGT Forest Supervisor on October 26, 2010 which the Sierra Club quotes from in our UIWFMP comment letter.”
“The Sierra Club would like to have a discussion with you about the UIWFMP and our concerns. Please let me know when we can talk.”
“Thanks for your help.”
The July 26, 2021 letter to the FS about the UIWFMP 2012 stated:
“Recently the Lone Star Chapter of the Sierra Club (Sierra Club) became aware of and asked for a copy of the U.S. Forest Service (FS) “Upland Island Wilderness Fire Management Plan” (UIWFMP) in the National Forests and Grasslands in Texas (NFGT). This document is a subordinate document to the Upland Island Wilderness Fire Management Initiative (UIWFMI).”
“The Sierra Club has never seen this document before and did not know of its existence until recently. The Sierra Club has never had a chance to review and comment on this document.”
“A. Information Request”
“In the UIWFMP, several documents that relate to prescribed burning in NFGT wilderness are mentioned. These documents include: 1) NFGT Fire Management Plan, 2) 10-Year Wilderness Stewardship Challenge, 3) Upland Island Wilderness Wildfire Response Plan, 4) Wilderness Advisory Group recommendation for the development of individual wilderness fire management plans, 5) Community Wildfire Protection Plan(s), and 6) Federal Wildland Fire Management Policy.”
“The Sierra Club appreciates the help the FS has given it in obtaining information that is used to make decisions in the NFGT. Because these documents relate to prescribed burning in Upland Island Wilderness Area (UIWA) and due to the Sierra Club’s continuing interest in this issue and concern, the Sierra Club requests a copy of each of these documents.”
“This request is in keeping with your request to the Sierra Club in January 2017, when you said that if the Sierra Club wants information, instead of going through the Freedom of Information Act process, “ask for it”.”
“B. Partial History of Sierra Club Involvement With the Upland Island Wilderness Fire Management Initiative (UIWFMI)”
“After participating in the UIWFMI National Environmental Policy Act (NEPA) process, providing scoping comments, and comments on the draft environmental assessment (EA), on June 25, 2010, the Sierra Club and FS met and informally resolved the June 11, 2010 appeal by the Sierra Club of the UIWFMI. On June 27, 2010, the Sierra Club withdrew its appeal of this proposal after the FS agreed to additional constraints for prescribed burning in UIWA.”
“On October 20, 2010, the Sierra Club participated in a Wilderness Information Needs Assessment meeting to “decide how to collect, store and analyze data needed for the Upland Island Wilderness burn”. This one meeting, did not result in final collaboration and agreement on all issues discussed.”
“On October 26, 2010, the Sierra Club sent the Forest Supervisor a letter, which said, in part, the following:”
“Enclosed is input from the Houston Regional Group and Lone Star Chapter of the Sierra Club (Sierra Club) regarding the U.S. Forest Service (FS) Wilderness Information Needs Assessment (WINA) and the need for specific standards that address “trammeling” for the proposed Upland Island Wilderness Area (UIWA) prescribe burn project.”
“The Sierra Club appreciates the October 20, 2010 meeting which resulted in the start of the gathering of public input for a WINA. The Sierra Club appreciates Mr. Ike McWhorter’s efforts during this meeting. We were disappointed that the meeting resulted in few or no proposals which addressed “trammeling” in connection with Appendix A – Wilderness Threats Matrix; Appendix B – Wilderness Information Needs Assessment Worksheet; and Appendix C – Wilderness Information Needs Assessment Work Plan.”
“At the end of the October 20th meeting the Sierra Club expressed its concern to Mr. McWhorter. The Sierra Club stated that it would submit input about a description of “trammeling” that the UIWA proposed prescribe project burn will have. The UIWA prescribe burn project must track levels of “trammeling” actions to determine whether a reduction of “trammeling” occurs over time. Below, the Sierra Club provides a definition and description of “trammeling” that the UIWA prescribe burn project will have. The Sierra Club does this as a way to begin determination of how “trammeling” will be tracked and monitored during the UIWA prescribe burn project.”
“A description of trammeling caused by the UIWA prescribe burn project is made difficult because the Sierra Club is not aware of all of the elements, equipment, and procedures that will be needed. This should be kept in mind when reviewing our input since we will undoubtedly miss some actions that contribute to “trammeling” in UIWA.”
“After sending this letter, the Sierra Club never heard from the FS about these trammeling and other issues and was never invited to review and comment on the Upland Island Wilderness Fire Management Plan, 2012. When the UIWFMP was complete, the Sierra Club was not sent a copy and we never knew of its existence until recently.”
“The Sierra Club was left out of the process that it had been invited to participate in. This is not appropriate and certainly does not exhibit the “collaborative” spirt and nature that the FS has stated that it wants to cultivate with the public.”
“Page 2, UIWFMP states, “Partnerships and public involvement will be essential … It will be imperative to involve a wide spectrum of public interest”.”
“The Sierra Club believes in transparency, public involvement, and collaboration. The FS says it believes in the same things. If the FS does believe in these same things, it should act accordingly to ensure that transparency, public involvement, and collaboration occur.”
“This did not occur with the preparation of the UIWFMP where the Sierra Club was not allowed to participate. Only Stephen F. Austin State University was a partner and collaborated with preparation of the UIWFMP.”
“C. FS Implements Subordinate UIWFMP Which Changes the Nature of the Dominant UIWFMI”
“The reason that the Sierra Club sends this letter and is so concerned about the current public participation in the UIWFMP is that Wilderness requires, even demands, restraint. The UIWFMP has not been prepared sufficiently with that idea as a priority.”
“It’s a concern that by defining conditions in Wilderness in the manner that they have been defined in the UIWFMP, there is a guarantee that more manipulation (trammeling) will occur. Wilderness is not a condition class, but a national natural resource which the U.S. Congress called, “an enduring resource of wilderness” (Section 2(a)). Wilderness is what Nature makes of the landscape via natural disturbance and ecological processes and without human interference or manipulation.”
“The Sierra Club is concerned that the FS’s failure to appropriately plan and manage for hazardous fuel reduction in Wilderness will be used as a justification for ever more trammeling and the reduction of the wilderness resource. Fire suppression is still overwhelmingly practiced in UIWA unless a fire fits within the narrow windows of acceptable prescribed burn conditions.”
“The Sierra Club appreciates in 2021 that the FS allowed a wildfire to burn in part of UIWA and Big Slough Wilderness Area. This is currently the exception rather than the rule and FS trammeling due to fire suppression and prescribed burning dominates Wilderness existence.”
“Perhaps the biggest concern that the Sierra Club has about the UIWFMP is that the UIWFMP undermines and changes what the UIWFMI intends, requires, and was agreed to in the appeal that the Sierra Club filed.”
“D. Limits of Acceptable Change (LAC) Does Not Protect Wilderness From Trammeling”
“The FS relies in the UIWFMP on the LAC analysis that was done in 1993 and 1994. I participated in that process, not on behalf of the Sierra Club, but as an individual. I raised concerns about the lack of discussion and resolution of trammeling and other issues. I was not happy with the process. I let both Dr. Mike Legg and his assistant, Ms. Rebori, know this at the time.”
“The FS reliance in the UIWFMP on the LAC is not appropriate since that process was not complete and full agreement on what the LAC should consist of for all issues was not reached. To use the incomplete LAC to set triggers for wilderness issues is not good science. The Sierra Club is concerned about the LAC’s use in the UIWFMP since it introduces bias into the process and assumes a certain level of trammeling is allowed and necessary.”
“E. Climate Change and the UIWFMI and FMP”
“Page 22, C. Desired Future Conditions and Natural Variability, the FS states, “When wilderness conditions approach an extreme departure from their central tendency or when eminent threats emerge, it will be imperative to determine if the changes (threats) are the result of natural causes or human influences and to determine what actions, if any, should be taken to address the threats and restore the desired conditions”.”
“This means, in an era of human induced climate change, that may last for centuries or millennia, the FS will try to chase some historical model based upon the best estimates informed by incomplete documentation of forest conditions during pre-settlement times. This is not allowed by the Wilderness Act and is a massive case of trammeling that the FS has determined via science that cannot be factually documented or replicated.”
“The FS should prepare a UIWFMI and Plan that takes climate change into account.”
“F. Trammeling Due to Prescribed Fire”
“The FS, in the UIWFMP, participates in actions that are not allowed by the Wilderness Act. There are no trade-offs allowed in the Wilderness Act. The FS has decided that there are “Four distinct qualities, based on the definition of wilderness from the Wilderness Act, have been related to wilderness character”.”
“From this the FS decides that it will arbitrarily determine how much and where those four qualities (FS derived as undeveloped, untrammeled, natural, and outstanding opportunities for solitude and unconfined type of recreation) will be expressed in wilderness. In essence, the FS will manipulate wilderness and trammel it even though the Wilderness Act does not allow this. This is not appropriate.”
“G. Summary”
“It appears that the FS has turned a hazardous fuels reduction project into an ecosystem restoration project without the appropriate Wilderness Act and NEPA analysis, assessment, evaluation, and public transparency, involvement, and collaboration for the UIWFMP. This is not appropriate. The Sierra Club requests that the UIWFMP be revised to be a hazardous fuels reduction project only.”
“If an ecosystem restoration project is desired for UIWA then the FS must, with full Wilderness Act and NEPA analysis, and public transparency, involvement, and collaboration, revise the UIWFMI and after its approval, revise the UIWFMP.”
“The Sierra Club would appreciate a discussion with you about this important issue on prescribed fire, wilderness management, and trammeling of Upland Island Wilderness Area. Thank you.”
July 29, 2021, William E. Taylor, FS, Forest Supervisor, NFGT, responded to the LSC and stated:
“Brandt when I said you could just ask for documents outside of FOIA, I assumed you would be reasonable in your requests. I should have set boundaries for requests. I feel over the last months you have crossed the line into making unrealistic requests which has led to increasing our workload and costs tremendously. I am at a point where I almost need a full time position to manage the Sierra Club’s requests. We cannot continue to provide the amount of documents you are requesting without going through FOIA (Freedom of Information Act). I always want to have a good relationship with you and the Sierra Club, but all relationships need boundaries. We have many plans that are based on NEPA decisions or help support those decisions. If you want this about of information you will have to FOIA it. I look forward to working together in the future. Thanks.”
July 29, 2021, the LSC responded back to Forest Supervisor William E. Taylor via email and stated:
“I would like to have a conversation with you about the information requests I have made. If they can be fulfilled via pointing me to a web address that would be appropriate and I will download the material.”
“This is the first time anyone has suggested that there is a problem. I do not believe the information requests have been excessive particularly since many were not difficult to fulfill.”
“When can we talk on the phone?”
July 30, 2021, the LSC and the FS discussed information requests and a summary stated:
“This issue was raised due to a July 28th Sierra Club information request about the Upland Island Wilderness Area (UIWA). The Upland Island Wilderness Fire Management Initiative (UIWFMI) was approved in 2010 after the Sierra Club filed an administrative appeal of the project.”
“Eddie apologized for sending an email on July 29th to others about Sierra Club information requests because it was meant for Brandt only. However, Eddie sent his email by mistake to people he did not intend to see the email. Eddie said he was going too fast that day and made a mistake. Brandt said he wanted to get past this so the Sierra Club and FS can discuss and work on proposed projects.”
“Eddie said that due to budget cuts, etc., that the FS does not have the capacity to answer every question the Sierra Club asks. Eddie said that a District Ranger has a right to decide what information he/she will use to make a decision. Eddie said that Sierra Club comments are valuable a lot of times but some in the NFGT think the Sierra Club is trying to get the FS to work for the Sierra Club.”
“Brandt said that a lot of times when he goes to the internet, he cannot find the information that he is searching for and therefore asks the FS for it. Eddie stated that the NFGT needed to update its website and put more information on it.”
“Brandt mentioned that it appeared that the UIWFMP, was an example of mission creep, because the UIWFMI, which the UIWFMP implements, is a fuels reduction project and not an ecosystem restoration project.”
“Eddie said that … the bottom line is that it’s only a fuels reduction project. Brandt said that in the past he had talked … about the UIWFMI and thought that both agreed that it was for fuel reduction only and not ecosystem restoration. If fire adapted communities benefited from the fuel reduction project that was appropriate as it would be if they did not.”
“Eddie talked about using wildfire more for burning in UIWA. Brandt said the Sierra Club supported this and appreciated that this year (2021) in UIWA and Big Slough Wilderness Area, the FS had allowed wildfires to burn as much as possible instead of immediately putting them out (suppression). Brandt said in the future the Sierra Club would like to see more “prescription wildfires” burn in UIWA.”
“Brandt said that this UIWFMP issue would have been resolved in 2012 but the Sierra Club never received a copy of the UIWFMP until recently. Brandt said that after an information needs assessment meeting in 2010, there was no follow-up and the Sierra Club did not hear about the 2012 UIWFMP until now.”
“Eddie said that there is a new person in the NFGT … who will work with the website and see that additional information is placed on it. In the past, the website was not updated as it should have been.”
“Brandt brought up several instances where many weeks or months pass, and no response occurs when an information request is made. Brandt said a lot of times a scoping public comment time period is ticking, and the Sierra Club asks for Stand Maps and Data, soils information, and similar information so that these can be used to analyze and make comments on the proposal.”
“If the information is not provided, the analysis cannot be made, and the unavailability of information is placed in the scoping comments as an issue or concern. A lot of the information is relatively easy to send electronically because the FS has the information and it’s not like in previous years where paper copies had to be made.”
“To resolve the information request concern, the following was agreed upon by Eddie and Brandt:”
“1. Eddie would consider having contact specialists provide information instead of the District Ranger.”
“2. More information would be put on the NFGT website.”
“3. FS personnel may provide the Sierra Club with web links that it can go to and the get the information desired.”
“4. Brandt will review the July 28th Sierra Club information request, relook on the internet and see if he can find any of the information, and if he cannot, he will send an email … see if he can find the information and send it to the Sierra Club.”
August 7, 2021, the LSC sent an email of appreciation to the FS for the phone call about information requests and stated:
“I appreciated our talk the other week about a lot of issues.”
“My main point about the Upland Island Wilderness Fire Management Plan is, that unless the emphasis on ecosystem restoration is corrected in that document so that it aligns with the fuel reduction purpose and need of the Upland Island Wilderness Fire Management Initiative, as personnel move on the leave, whoever takes over is going to believe that ecosystem restoration is the purpose and need of the Initiative. The "mission creep" I mentioned to you.”
“I believe that would be a mistake and not positive for the future of Upland Island Wilderness Area.”
This ended the discussion about LSC information requests. The monitoring by the LSC of FS wilderness fire management continues and is a never-ending task.
August 17, 2022, the FS contacted the LSC and TCA about a lightning fire that occurred on August 9, 2022 in UIWA. The fire burned 38 acres. The LSC asked the FS if it was safe to view the fire. The FS let the LSC know it was safe to view the fire.
September 14, 2022, from 10 am to 12:30 pm, the LSC visited the location of the “Hopson Fire” in UIWA and walked this site. The LSC prepared notes about this visit on September 15, 2023 and sent these via email to the FS and stated:
“The Sierra Club walked north from Forest Road (FR) 314 into UIWA and slowly veered northwest toward several streams and a promontory. The Sierra Club found the “Hopson Fire” site and walked through a significant portion of it from south to north, to the east where there was a ravine/stream, and to the west where there was rolling and flat topography.”
“The Sierra Club observed that woody plants like American Beautyberry, Sweetgum, and Southern Wax Myrtle had burned (seedlings or small saplings) and were resprouting about 36 days after the fire was observed. Some small areas had not burned. Most of the overstory pine trees we saw were Longleaf Pine with a few Loblolly and or Shortleaf Pines.”
“There were midstory Black Gum and Sweetgum that had been burned or showed the effects of the fire via brown leaves and drooping stems. Bracken Fern was growing vigorously.”
“Some of the flowers that were blooming included Crow Poison, Pencil Flower, Wild Petunia, Dayflower, Yellow Star Grass, and Flowering Spurge (Euphorbia corrollata). We saw several seedling Longleaf Pines that were killed by the fire or burned and survived the fire. Ground Skinks were seen in the leaf litter in areas where fire didn’t burn.”
“On a promontory that burned, there were many Butterfly Weeds blooming with Zebra Butterflies and other butterflies feeding on them. There also were some grasshoppers that flushed as we walked the burned area. This promontory had several understory or midstory Blackjack and Bluejack Oaks that were in small clusters or individual trees.”
“Along streams we noted many Sweetbay Magnolia and some Royal Fern, indicative of seepage along the lower slopes of the promontories. There was a lot of feral hog activity on the lower slopes and along streams and some on the uplands. We saw White-Tailed Deer tracks and Yellow-bellied Sapsucker holes in Sweetgums.”
“There are two items that may be of concern.”
“The first item that may be of concern is that a large living Longleaf Pine tree was cut via chainsaw in UIWA. This pine tree may have had a rotten base (it was hard to determine) but the FS “Hopson Fire” report indicated that snags, which are dead standing trees, were cut via chainsaws and not living trees.”
“The Longleaf Pine tree that was cut by a chainsaw wasn’t a standing dead tree but was a living tree with luxuriant needle growth on the branches. It appeared that this tree should have been left alone since there was a lot of room to work around it where the fire burned, and it was living and not a snag. If living trees are cut in UIWA, then the “Hopson Fire” report should state this and not give the impression that only snags were cut.”
“The second item that may be of concern is that on some slopes where fire occurred (either prescribed or wildfire), there were small, stair-step, overland flow erosion pathways. These erosion pathways appear to bring sandy soil down slope toward and into streams. This could result in sedimentation of streams.”
The FS prepared a “Fire Effects Monitoring Report for the Upland Island Wilderness Fire Management Initiative”, on November 14, 2022 and a “Wilderness Character Monitoring Report for the Upland Island Wilderness Fire Management initiative” on January 18, 2023. These reports were a summary of FS efforts to re-introduce prescribed fire into UIWA and how that affected wilderness character.
The LSC responded with comments about these two reports on January 30. 2023 and stated:
“Page 1, some of the major problems with this report are that it significantly underestimates trammeling (human manipulation of wilderness); is not based upon actionable collaboration between the FS and the public; and includes the linkage of additional trammeling due to other FS actions (wildfire suppression) but does not present their environmental impacts and trammeling which appropriate since this FS action is linked to prescribed burning.”
“The Wilderness Character Monitoring Report for the Upland Island Wilderness Fire Management Initiative significantly underestimates trammeling and is biased.”
“On June 27, 2010, after the Sierra Club had reached an informal resolution for its appeal of the FS proposal to prescribe burn Upland Island Wilderness Area (UIWA), the Sierra Club sent a letter (attached) to Ms. Linda Brett, Forest Supervisor, National Forests and Grasslands in Texas (NFGT). In that letter and a later letter of March 26, 2021 (attached), the Sierra Club stated:”
“In the June 25, 2010 resolution letter, the FS states “We acknowledge that the UIWFMI EA could be clearer on some points … In future EAs, we will clarify the issues you brought forward during this appeal.” A few (not all) of those issues include:”
“4) Adequately show what the FS threshold is for “trammeling” in wilderness; the total number of all “trammeling” actions that will occur; and what the goal is for reduction of “trammeling” over what time period.”
“5) Ensure that the number of conclusory qualitative words and phrases used for describing environmental impacts is minimized and the definitions for these words and phrases are such that they, themselves are not conclusory and qualitative.”
“6) Ensure that a former activity in wilderness, like a road, is not given dominance over the area of land that has been wilderness for over 26 years.”
“The FS has not clarified, collaborated, and resolved these issues with the Sierra Club in the past 13 years.”
“The FS underestimates trammeling significantly. This is done by not counting all actions/activities that the FS uses to trammel UIWA during prescribed burning. The FS only counts the number of prescribed burns as a trammeling action instead of counting each trammeling action/activity that is part of and allows the prescribed burn to be conducted. The FS underestimates the effects of trammeling as “minor, short-term negative effect” or “very minor, short-term effects”.
“There was no response from the FS then or since then about the Sierra Club’s October 26, 2010 letter and any collaboration about trammeling in UIWA due to prescribed burning and how this would be recorded and monitored.”
“Because of this FS lack of response and collaboration about trammeling and its significance and underestimation, the Sierra Club is required to bring this subject up again 13 years later. This is not good public involvement, participation, and collaboration.”
“The Sierra Club is still waiting for the FS to collaborate on trammeling and how this is reported in a wilderness character monitoring report for UIWA for prescribed burning.”
“The Sierra Club requests that the FS conduct the appropriate level of public involvement, participation, and collaboration for trammeling due to prescribed burning in UIWA.”
“Page 2, the FS statement, “The fact that the proposed burns were management ignited and not natural events would be unapparent to most wilderness visitors once operations are complete”, is not consistent with the Wilderness Act of 1964 which does not provide any excuse to allow trammeling which might be “unapparent to most wilderness visitors”.
“The FS is supposed to reduce and eliminate trammeling as much as possible regardless of whether any member of the public knows about the trammeling. This is one of the problems with both of these reports that are the subject of this letter.”
“These two monitoring reports reflect an attitude that, as long as things are done from the FS perspective of what is okay, trammeling is acceptable. This is not true, and the Wilderness Act does not support such an attitude.”
“Page 2, the FS states, “beneficial effect by restoring fuel conditions over the entire wilderness that would provide managers more options for managing lightning-caused wildfires” and “Prescribed burning has also enhanced the ability of fire staff to respond to wildfire. This was evident from the successful containment of three wildfires in wilderness during the project with very little impact on Wilderness character”.
“These statements document the link between prescribed burning and wildfire suppression trammeling and that the FS cannot see that its own actions lead to more, not less, trammeling in UIWA. Freedom from manipulation in Wilderness is what untrammeled is about.”
“The FS has linked prescribed burning to suppression of wildfires in UIWA. The FS has not provided monitoring about the impacts that wildfire suppression has on wilderness character and particularly on trammeling in this monitoring report when both are linked together.”
“The Sierra Club requests that since the FS has linked prescribed burning and wildfire suppression actions together, that it include trammeling and other wilderness character impacts due to wildfire suppression in UIWA in the wilderness character monitoring report for prescribed burning.”
“The FS reveals the depth of its trammeling when it says, “The restoration of natural fuel loadings will also increase the number of options for managing lightning-cause wildfire to achieve wilderness fire management objectives. This will improve natural qualities of wilderness character.”
“Management for lightning wildfire in wilderness for fire management objectives is trammeling and it does not improve wilderness character but decreases it via additional trammeling.”
“This statement refers to an activity, the use of leaf-blowers in wilderness, not allowed in UIWA. The FS makes an assumption, with no documentation to back it up, that the use of helicopters and motorized equipment has, “minor, short-term effects with no overbearing results on wilderness character.”
“The noise and visual intrusiveness of a helicopter in UIWA and the use of motorized pumps, along with all other prescribed burning and wildfire suppression actions/activities, trammels UIWA and thus has “overbearing results on wilderness character”.
“The FS work did affect solitude and primitive and unconfined type of recreation which is the criteria that should be used and emphasized. The Sierra Club does not consider 6.3 miles of fire-line constructed and maintained in wilderness as being “very localized” impacts and trammeling.”
“Page 1, Fuels Management Goals and Objectives, the FS refers to “prescribed conditions”; a specific range of tons of surface fuels/acre (2-4); reduction of fuel loadings for litter and dead and downed woody fuels to less than 3 tons/acre and less than 1 ton/acre of live woody understory fuel on 80% of upland pine sties; maintain mean overstory density within 10% of pre-burn conditions; and reduce mean duff accumulations by 50%.”
“These are examples of planning and implementation of trammeling by the FS. What is of great concern is management of wilderness to perpetuate Longleaf Pine and upland pine ecosystems, which is not legal in wilderness.”
“Nature is the manager in wilderness, not humans and what they hope will be perpetuated, particularly in a time of climate change, which obscures what will and will not occur in UIWA as it evolves.”
These comments and those of the TCA led to a meeting with the FS on February 6, 2023. The meeting lasted the entire day and resulted in vigorous discussions about the two reports. There was some agreement and additional disagreement about fire management in wilderness and how to maintain wilderness character with the minimum of trammeling (keeping its wild character).
The LSC followed up and submitted to the FS a letter, via email, on February 17, 2023 which provided recommendations about how the FS can improve its fire effects and wilderness character monitoring for UIWA and stated:
“The Lone Star Chapter of the Sierra Club (Sierra Club) provides these recommendations about how the U.S. Forest Service (FS) can improve its fire effects and wilderness character monitoring for Upland Island Wilderness Area (UIWA) as part of the prescribed burning project (PBP). The Sierra Club looks forward to collaboration with the FS now and in the future about UIWA trammeling, management, and monitoring.”
“The Sierra Club promised to provide this information to the FS during the February 6, 2023 meeting that it and the Texas Conservation Alliance (TCA) had with the FS. Some of the recommendations are based upon the October 26, 2010 letter to the FS about trammeling and wilderness character.”
“Fire Effects Monitoring and Report Recommendations”
“1) Monitoring for fire effects “trammeling” should answer:”
“a. What are the effects of “trammeling” on fire tolerant/intolerant ecosystems due to the PBP?”
“b. What baseline reference conditions for trammeling and natural ecosystems does the PBP use? Where do these baseline reference conditions come from for trammeling and fire tolerant/intolerant ecosystems?”
“c. How will “trammeling” of areas that were significantly disturbed before wilderness designation (former roads), but have had 39 years to recover, be monitored due to the PBP?”
“2) The FS should use language other than roads, old road, etc., to refer to areas that are trammeled and may be trammeled in the future for internal fire lines in UIWA.”
“The mind-set encouraged by using these terms is that these are trammeled areas, not wilderness, and therefore are the best places for fire lines. This will cause repeated trammeling of the same areas and prevent vegetative regeneration, soil recovery, and hinder wilderness character restoration.”
“3) The FS should on a continuous basis determine whether private properties that are on the boundaries of UIWA can be bought or conservation easements acquired so that the PBP can more easily be implemented and more a natural burn can be achieved over a larger area.”
“4) The FS should use drones as the method of fire introduction for the PBP. This will result in less visual and noise trammeling in UIWA during prescribed burns and may result in more accurate application of fire in difficult to burn areas.”
“5) If the Limits of Acceptable Change (LAC) for UIWA is to be used as a basis for the PBP, it should be posted on the NFGT website along with additional information that was generated from that process so the public can have access.”
“6) Revised locations of or additional monitoring plots should be researched, determined, and implemented. The present monitoring plots don’t monitor all areas that should be monitored.”
“7) The landowner agreement for the Denman area should be renewed. If this cannot be renewed, the FS should determine how this area should be affected by the PBP.”
“8) The present fuel loadings serve as targets for vegetative debris in wilderness. This is trammeling and if these fuel loadings, 2-4 tons/acres, are to be used, then this is what should be adhered to and not additional elements that shape what UIWA will look like and be.”
“The targets in the sampling protocols (reduce mean duff accumulations by 50%, maintain mean overstory density within 10% of pre-burn conditions, and reduce … woody fuels to less than 3 tons/acre and mean live woody understory fuel loadings to less than 1 ton/acre on at least 80% of upland pine sites) should be abandoned because they direct what UIWA will look like and don’t simply result in a reduction of fuel to 2-4 tons/acre. This trammels and directs UIWA toward a certain vegetative state or condition.”
“9) Burning specific patches of vegetation, like thickets, is trammeling and shouldn’t be allowed in UIWA. Natural vegetative heterogeneity should be allowed to reassert itself.”
“10) The appropriate duff/litter method shouldn’t be the standard method used but should be to collect, dry, and weight litter samples in separate plots on transects. This apparently is the more accurate method.”
“11) Climate change effects should be factored into the PBP.”
“Wilderness Character Monitoring and Report Recommendations”
“1) A definition of “trammel” from the Random House Dictionary of the English Language, College Edition, 1968, states, “hindrances or impediments to free action; restraints” and synonyms for “trammel” include “hobble, curb, inhibition, hinder, impede, obstruct, encumber.”
“The Wilderness Act of 1964, Section 2(c), states, “A wilderness, in contrast with those areas where man and his own works dominate the landscape, is hereby recognized as an area where the earth and its community of life are untrammeled by man”.
“Trammel” for the UIWA PBP encompasses human actions that interfere with wilderness/free action of wilderness. This means that allowing natural processes to operate in wilderness is part of avoiding the act of “trammeling”.
“2) Actions that the cause trammeling in the PBP, at a minimum, include:”
“a. Use of a helicopter causes visual; noise; fire pattern (burning in a manner and way that Nature does not burn); air pollution; vegetation; disruption of wildlife; and safety trammeling.”
“b. Placement of fire lines on the boundary/inside UIWA using hand tools/mechanical equipment causes litter, duff, and soil; coarse woody debris; vegetation; disruption of wildlife; noise; air pollution; fire pattern; and visual trammeling.”
“c. Use of water pumps/lines/equipment to wet fire lines inside/outside of UIWA causes noise; soil; visual; air pollution; disruption of wildlife; and fire pattern trammeling.”
“e. Mop-up after a burn causes fire pattern; disruption of wildlife; visual; vegetation; soil; coarse woody debris; and noise trammeling.”
“e. Use of people to conduct actions causes visual; disruption of wildlife; vegetation; soil; and noise trammeling.”
“f. Other trammeling actions should be added by the FS, if known.”
“3) The use of hours for trammeling actions better reflects reductions in trammeling that the FS accomplishes over time. For instance, you could reduce the time it takes to prepare for a prescribed burn but take the same number of days. The time reduction wouldn’t be reflected by using days versus hours.”
“4) The use of qualitative terms like “minor magnitude” and “minor extent and magnitude” in Table 1., “Untrammeled” and “Undeveloped” don’t provide the public with an idea of effects on wilderness character and how much the natural, undeveloped, untrammeled, and opportunities for solitude or primitive and unconfined recreation aspects are reduced/increased.”
“5) Remove leaf-blowers from Table 1., “Undeveloped”, for internal fire lines, because they aren’t allowed in UIWA for the PBP.”
“6) Some trammeling actions include: length of fire lines; width of fire lines; area of vegetation cleared; number of hours that each internal combustion engine is used; number of people used for each action/total number of people used for all actions; number of helicopter trips/hours; area of hand removal of debris conducted. See 2) above.”
“7) The creation of ash is an effect of trammeling UIWA. This effect is found due to prescribed burning or wildfire and cannot be eliminated.”
“8) Soil impacts, erosion and compaction, are forms of trammeling and should be monitored.”
“9) Trammeling reduction monitoring for wildfire suppressions actions is needed.”
“10) Monitoring plots are a form of trammeling. They may be the only way to determine whether the fuel reductions required by the PBP have occurred.”
“11) The number of fires over time (frequency) are a form of trammeling.”
“12) Solitude reflects a quality or state of being alone, in seclusion, being apart, isolation, and detachment from others.”
“The Sierra Club looks forward to working and collaborating with the FS on implementation of fire effects and wilderness character monitoring in UIWA, now and in the future.”
The FS responded and stated:
“Thank you for your recommendations regarding the UIWA Wilderness Character and Fire Effects Monitoring. I look forward to our continued collaboration on this project.”
VI. Sierra Club, East Texas Wilderness Areas, and Southern Pine Beetles
There has been a continuous battle between the LSC and the FS over control of Southern Pine Beetles (SPBs) in ETWA. As mentioned above under fire, Section 4. (d)(1) of the 1964 Wilderness Act states, “… such measures may be taken as may be necessary in the control of fire, insects, and diseases, subject to such conditions as the Secretary deems desirable.”
This management loophole has caused untold controversy and difficulty with leaving wilderness to evolve on its own when SPBs increase in ETWA. Before we get to that battle, we need to talk about SPBs so you can understand their nature and role in pine and pine-hardwood forest ecosystems.
SPBs are predators of pine trees (Longleaf, Loblolly, and Shortleaf) in East Texas. In the NFGT and on private lands, landowners often control SPBs after they have attacked pine trees. Areas where these attacks occur are called “spots”.
The last significant SPB predation in the NFGT occurred in 1991-1994. Since that time (29 years) SPBs have been at low population levels. In the future, there’s concern that population levels will rise, and economic loss of pine trees will grow.
SPBs are a natural solution to dense pine tree growth caused by humans or Nature. SPBs act as natural thinning agents when they kill pine trees by boring into pine trees, making galleries to lay their eggs, and the larvae hatch out and feed on pine tree cambium until they are ready to leave the tree.
Pine tree death creates new habitats and biological legacies like standing dead trees (snags), downed trees (coarse woody debris), thickets, root wads, etc. These habitats and biological legacies are important for the ecological health of forest ecosystems because they provide shelter, food, and nutrients. Oftentimes humans overstock pine plantations, farms, and forests which creates conditions that SPBs like. Methods to reduce SPB attacks usually include:
1. Spray trees with pesticides.
2. Cut and leave pine trees with SPBs and a buffer of green pine trees around the “spot”.
3. Cut and remove (salvage logging) pine trees attacked by SPBs and a buffer of green pine trees around the “spot”.
4. Monitor “spots” of pine trees with SPBs to determine their rate and direction of growth.
The LSC is concerned that many SPB reduction methods result in soil erosion, damage vegetation, stream siltation, loss of nontarget hardwood trees, pesticide pollution, and loss of wildlife habitat. This occurs both in the general forest area of the NFGT and ETWA.
The LSC favors an alternative SPB control strategy (CS) implemented over the long-term which causes less environmental damage. The LSC CS is a combination of methods that are available and will reduce, not eliminate, SPB predation.
The LSC CS is a type of Integrated Pest Management (IPM). IPM is a combination of cultural, biological, and other treatments which reduce pest numbers to levels where economic damage for humans is acceptable.
Each tree species has a range of conditions (maximum and minimum) under which it can grow successfully. Trees often survive in a weakened condition in many areas. The set of conditions that each tree species must have for good growth includes sunlight, water, soil (minerals, nutrients, and organic matter), topography, and space (tree density).
Research has shown that SPBs attack weakened pine trees. This is how “spots” begin. This often means that pine trees that are attacked grow under less than good conditions. Less than good conditions for pine trees include dry soils, wounded trees, wet soils, nutrient deficient soils, and areas with overly dense pine trees. Growing pine trees in these areas is an invitation for SPBs. Too often pine trees are grown under less than good conditions to maximize economic returns.
Conversion from hardwood forests and mixed hardwood-pine forests to pine forests or pine-hardwood forests is often based upon economic and not biological reasons. After such conversions, pine forests grow in densities and areas where they normally wouldn’t naturally survive or thrive. Competition from hardwood trees normally reduces or eliminates pine trees from these unsuitable areas.
In East Texas, Southern Red, Bluejack, Blackjack, and Post Oaks and Black Hickory are found on dry ridges. In wetter areas, oaks like Willow, Water, Delta Post Oak, Shumard, Cherrybark, and other bottomland hardwood tree species grow naturally. Many of these dry or wet areas have been planted in dense stands of Loblolly Pine with little consideration for good growing conditions.
In wet areas, root rot is prevalent which can weaken pine trees and make them more susceptible to SPBs. Traditional hardwood or other unsuitable areas (like riparian or mesic soil areas) and increased hardwood tree density create natural barriers or screens where hardwood trees surround pine trees and make SPB attacks more difficult.
An increase in hardwood trees in these areas has beneficial wildlife impacts due to increased soft and hard mast, den or cavity trees, and additional snags and downed trees. White-tailed Deer, Eastern Wild Turkey, Gray and Fox Squirrels, rodents, herptiles, and other animals will benefit from more hardwood trees and the food and shelter they provide.
Planting more Longleaf Pine trees, in the right locations, can reduce the susceptibility of a forest to SPBs. Longleaf Pine trees have greater resistance to SPBs due to thick bark and more resin which pitches out or drowns SPBs. Longleaf Pine trees used to be the dominant upland pine tree in some areas in East Texas. Unfortunately, many of these uplands have been planted by the FS and others to Loblolly Pine trees which are not as resistant to SPBs.
Increased populations of hardwood and Longleaf Pine trees increase habitat for woodpeckers. Some woodpeckers, like the endangered Red-cockaded Woodpecker (RCW), like old Longleaf Pine trees in more open upland areas. Woodpeckers are prime predators of SPBs. Increased woodpecker habitat means more woodpeckers to feed on SPBs.
Longleaf Pine trees generate additional snags, cavities, and large downed wood on the forest floor. This provides more nesting and perching sites for hawks, owls, and other birds and shelter and food for raccoons, opossums, reptiles, amphibians, insects, and other animals.
Improved pine tree genetics can play a role in the reduction of SPBs. Greater insect resistance can be bred into pine trees (increased resin production and thicker bark) so that trees can resist and survive SPB attacks better.
Natural factors like droughts, floods, hurricanes, windstorms, lightning strikes, wildfires, etc. can wound and weaken pine trees. These weakened pine trees can be girdled and left in the forest to serve as snags and downed trees for the benefit of wildlife.
Spacing of pine trees in the NFGT, 20-25 feet between trees, is done to reduce SPB attacks. The growth of variable densities of pine trees scattered over the landscape better represents the original growth of pine trees and should act to interrupt or reduce SPB movements.
Pine trees with scraped bark produce odors that attract SPBs. Improved logging practices that reduce the number of wounded trees due to logging equipment help reduce the number of SPB target trees. Hardwood trees, like Sweetgum, release odors that mask pine tree odors and lower the possibility of SPB attacks. Therefore additional hardwood inclusions or clumps in the forest can help disrupt SPB attacks.
The use of pheromones to disrupt and disturb SPB attacks (due to scent clues) should be quickly implemented on a wide scale when a SPB attack is discovered. Areas of pine trees should be thinned (logged) to reduce their density so they are not desirable targets for SPB attacks. Prescribed burning prepares pine forests for better growth and thus improves the defenses of a pine dominated forest against SPB attacks.
The increased “edge effect” that SPBs cause is beneficial to some wildlife. These smaller forest openings allow for different successional stages in random forest growth. These smaller openings are more beneficial for wildlife than large areas that are clear-cut. These SPB openings simulate natural openings due to storms. SPB “spots” allow forests to grow in a mosaic of tree species and ages by naturally thinning overstocked pine trees. When this occurs, remaining pine trees grow better due to reduced competition.
Taken together, these methods, applied systemically over East Texas, reduce economic damage due to SPB attacks. We must accept that SPBs are a valuable part of dynamic pine-hardwood forest ecosystems in East Texas. When we accept that we must live with SPBs and when we give up thoughts of their eradication, we will learn to appreciate and take advantage of the healthy forest ecosystems that SPBs create.
Unfortunately, the FS has attempted to grow too many pine trees too close together which has caused problems in the general forest and has left a residual high pine tree density in East Texas Wilderness Areas and makes this ripe habitat for SPBs. Now let’s talk about the battle!
A. Early Battles Against SPB’s in Designated East Texas Wilderness Areas
Please see, “History of the Sierra Club and East Texas Wilderness Designation”, for a view of how SPB management affected proposed ETWA that the LSC supported for designation as wilderness by the U.S. Congress. Here is a quote from that document:
“October 30, 1984 was a day of celebration for Texas conservationists when President Ronald Reagan signed the Texas Wilderness Act, Public Law No: 98-574.”
“Besides designating Turkey Hill, Upland Island, Indian Mounds, Big Slough, and Little Lake Creek Wilderness Areas, the bill also allowed acquisition of Temple-Eastex intermingled lands by exchange which then would become Wilderness.”
“The bill also allowed any timber sale purchaser with a contract within the boundaries of Indian Mounds, Upland Island, or Little Lake Creek Wilderness Areas, within 90-day of when the bill became law, to enter into an agreement with the Secretary of Agriculture to cancel the timber contract without payment of damages by the purchaser.”
“Finally, the bill closed the RARE II program and set out the parameters of how and when National Forests in Texas would again be considered for Wilderness Area designation.”
“The passage and signing of HR 3788 ended an over 14-year fight to obtain Wilderness for the “People of Texas”, East Texans specifically, and United States citizens everywhere, by the Sierra Club and others. But the Sierra Club had to prepare for many years of additional sorrows and fights that lay ahead and would cloud Wilderness protection in East Texas.”
The battle against further cutting and logging in the recently designated ETWA continued. Because the FS salvage logging responsibilities resulted in the sale of hundreds of thousands of board feet of trees in LLCWA, timber contractors were road building and logging trees in a cut and remove timber sale. No environmental impact statement was prepared for these specific timber sales.
The LSC, in a Houston Post article on November 8, 1984, stated that the FS logging plan in ETWA was, “A horrible pogrom against wilderness” and that the FS was using the SPB as “an excuse to open the now protected wilderness areas to commercial timbering”.
The FS Region 8 office (Southern Region) had approved a SPB plan for ETWA that, “infestations of 10 trees or less will not be treated unless they are on a wilderness area boundary or adjacent to colonies (now called clusters) of endangered red-cockaded woodpeckers.”
The LSC pressed its concerns that many hardwood trees were being destroyed; removal of SPB trees via truck and helicopter had spread the beetles to other areas, that tests using pheromones for beetles should be conducted in wilderness areas, buffer zones should be cut around the perimeter of wilderness areas and not inside them, timber sales had been rushed through in wilderness areas without notification of the U.S. Congress and the public, and that a quarter-mile long fern bed had been destroyed in LLCWA.
The FS disagreed with these concerns, but the LSC insisted that the FS was using the Wilderness Act’s control of insects paragraph, as a way to commercialize wilderness areas and destroy their wilderness value.
The LSC sent a letter to the FS on November 8, 1984, with comments for the October 22, 1984 FS proposal to amend the EA for SPB infestations in wilderness areas. Concerns that the LSC expressed included:
1. A lack of time given to respond and no information provided to comment on. The LSC provided its September 15, 1983 comments on the SPB EA which “are just as valid as they were last year.”
2. Before additional cutting in wilderness areas the FS should prepare an EIS. Questions the LSC presented to the FS last year were never answered.
3. There is concern about the effects cutting will have on federal and state listed threatened and endangered species and game and nongame wildlife. No documentation has been provided by the FS that these species will not be more adversely affected by logging than if left alone, particularly when SPB are found deep in wilderness or Further Planning Areas.
4. The LSC is against cut and remove (sell) SPB which gives loggers an economic argument to log wilderness areas. No documentation is provided to show cutting will stop SPBs and is endangering outside timber sources. Buffer cutting, if needed, should be done outside wilderness areas on federal lands. If private lands are endangered then only as a last resort cut and leave should be done. Use of pheromones is not being seriously considered or utilized.
5. Although the Wilderness Act allows for control of insects, the present SPB practices if continued will never allow wilderness to evolve to its ultimate climatic and natural condition. Unique ecosystems, like fern bogs, plants, like orchids, and unique animals, like salamanders and endangered species control areas are affected by SPB logging. Wilderness areas should act as natural control areas which show us how a natural forest responds to SPB infestations. Let Nature take its course in wilderness areas.
5. There will always be SPBs and the FS should acknowledge that their management must be different in wilderness than that used on the rest of the national forest.
6. The LSC requests an EIS and a weekend conference or workshop where all interested parties can gather and discuss, and come up with recommendations on management of SPB in wilderness areas.
7. The LSC requests any documents that the FS produces for control of SPB in wilderness and Further Planning Areas or management strategies in these areas.
8. The LSC requests a written response to its September 15, 1983 letter.
On November 9, 1984, the FS sent a letter to the LSC which stated:
“We have completed Amendment 2 EA for “Southern Pine Beetle Control in RARE II Further Planning and Recommended Wilderness Areas, National Forests in Texas”, October 1984 … Enclosed for your information is a copy of Amendment 2 and the Regional Forester’s decision notice.”
This amendment didn’t take the LSC’s November 8, 1984 concerns into account because the LSC letter couldn’t have been received, read, analyzed, and considered in less than one day.
On November 12, 1984, the LSC sent a letter to the FS with a copy of a resolution passed by the LSC Executive Committee about “Wilderness Management Policy (Interim)”. This policy states:
“Be it resolved that the Lone Star Chapter of the Sierra Club is opposed to artificial manipulation or management of the ecosystems in the five Texas National Forests Wilderness areas by prescribed burning and entry for the control of southern pine beetle until such time as a wilderness management plan is developed with the involvement of the public.”
“It is understood that a “leave it alone” management policy in no way prevents or prohibits oil and gas drilling.”
“In the event that the U.S. Forest Service insists on buffer cutting for southern pine beetle control, then such cutting should take place outside the wilderness boundaries.”
This policy was adopted by a unanimous vote of the LSC Executive Committee on November 11, 1984, at its regularly scheduled meeting in Austin, Texas.”
On November 30, 1984, the FS sent George Russell, the LSC’s Wilderness and Forest Practices Chair, a letter with questions/answers about the “National Forests in Texas Wilderness Areas Interim Direction”. The FS letter stated:
“Five wilderness areas were designated within the National Forests in Texas by PL. 98-574 on October 30, 1984.”
“These areas will be managed in accordance with provisions on P.L. 98-574 and the Wilderness Act of 1964 utilizing specific wilderness management direction which will be prepared for each area.”
“Enclosed is a copy of the interim direction which we will use in administering these areas until specific wilderness management direction is completed.”
“If you have other questions about the use or management of these areas, please contact us.”
This interim management direction stated:
“Will the Forest Service take control action against the Southern Pine Beetle within these areas?”
“Yes – objectives of SPB control in these areas are:”
“(1) containment of infestations to protect other National Forest and private lands outside of the boundary, and”
“(2) protection of RCW colonies within the wilderness areas.”
“Specific control actions to be taken may be found in Amendment 2 of the EA for “Southern Pine Beetle Control in RARE II Further Planning and Recommended Wilderness Areas, National Forests in Texas”, approved by the Regional Forester on November 5, 1984.”
“Can threatened and endangered species and their habitats be managed in a wilderness?
“At present time the only known threatened and endangered species in the National Forests in Texas wilderness areas is the RCW. Certain management activities may be allowed within the wilderness to protect a federally listed threatened or endangered species. The need and use of these activities will be addressed when specific management direction is determined for each of the wilderness areas.”
A December 21, 1984 issue of the Earth First! journal, reported the logging of LLCWA in this manner:
“In one of the most blatantly arrogant actions ever committed by any federal agency, the U.S. FS has conducted commercial timber sales in a Congressionally designated Wilderness Area … never before has the Forest Service twisted the Wilderness Act to conduct a commercial timber sale in a Wilderness Area. The timber sale was discovered by a field party… on October 4, the date of final passage of the Texas Wilderness Act … Several hundred thousand board feet of timber had been sold. Most of it was uninfested by the pine beetle … The purchasers had built roads into the wilderness, felled thousands of pines, and obliterated the Red Loop of the Lone Star Hiking Trail, and were still removing logs. Using heavy equipment, loggers under the supervision of the former Forest Service Ranger for the district had demolished a large fern bed, mashed the soil, and damaged the remaining hardwoods up to the bank of the creek.”
U.S. Representative John Bryant, who introduced the wilderness bill that passed Congress and was signed into law by President Reagan, criticized the FS in a January 19, 1985 article in The Huntsville Item. Congressman Bryant said:
“Although we stand at the edge of an undisturbed wilderness area, we stand, too, within walking distance of a travesty … the result of the commercial cutting and sale of timber conducted by the U.S. Forest Service.”
A Houston Chronicle article of the same event stated:
“A dedication ceremony for five new wilderness areas turned into a finger-pointing debate Friday as U.S. Rep. John Bryant blasted the U.S. Forest Service’s malicious tree-cutting”
“A lavish stand of pines and hardwoods there had become a graveyard of stumps because of the assault on the pine beetle.”
“Bryant said he plans to introduce a bill to stop the Forest Service from clear-cutting”.
“The remedy to this is to get people in the Forest Service who are committed to conservation rather than cutting trees down … The problem is, you’ve got the fox guarding the hen house in East Texas. How do you stop the fox from eating the chicken?”
“The Lone Star Sierra Club’s George Russell … said it is unproven that cutting stops the beetle”.
“Fifteen spots are under surveillance; trees were cut and left behind at 14; and they were cut and removed from three.”
Later in September 1985, the Sierra Club, Gulf Coast Regional Conservation Committee (GCRCC, Louisiana, Mississippi, Alabama, Georgia, and Florida with Texas as an associated Sierra Club Chapter), submitted a letter to John Alcock, Regional Forester, FS, Atlanta, Georgia, as input for NEPA scoping for an EIS on SPB suppression in all forests of the Southeastern U.S. Some of the comments submitted by the GCRCC were:
1. The scoping deadline is too short and should be extended one month.
2. The science of control, whether it works, and studies that have been carried out to demonstrate success should be covered in the EIS.
3. Biological controls like pheromones should be discussed along with the state of research and effectiveness and what their future use will be.
4. Even-aged management and its contribution to SPBs should be covered.
5. Wilderness values and control should be discussed.
6. Does the FS have enough resources to control small spots or will a reactive mode be used.
7. The differences between how even-aged and mixed stands are treated.
8. The conflict between managing for Wilderness and Endangered Species.
9. How genetically superior trees affect or are affected by SPBs.
10. The effect that control burning has on SPBs.
11. How natural barriers affect SPBs.
12. Should wilderness and all other public and private lands be managed differently for SPBs.
13. How should wilderness study areas be managed for SPBs.
14. The advantages and disadvantages of all SPB control methods and their efficacies.
15. Discuss preventive versus reactive management for SPB.
16. How integrated pest management (IPM) will be implemented.
17. Use of buffer zones for wilderness, wilderness study, and scenic areas.
The battle continued via the press. In a September 1985 article, the Houston Post was told by the FS that, “The infestation is part of a regional problem that has reached epidemic proportions in Louisiana, Mississippi and Texas”.
“George Russell, of the Sierra Club’s Lone Star Chapter, claimed national foresters made the forests even more attractive to pine beetles by emphasizing pine cultivation over other types of trees. Russell says the forest service, for commercial reasons, is turning what used to be natural forests into forest farms composed primarily of pines.”
“By destroying the natural diversity of the forest, they are creating a natural environment for the beetles to thrive … We don’t have an epidemic of pine beetles; we have an epidemic of pine trees.”
“Now we’re destroying a forest to save it from the pine beetle.”
“Russell said while neither form of control has been proven effective, his organization has no objection to their use in most of the national forest. He does argue bitterly, however, that neither should be used in the wilderness areas of the forests.”
Two lawsuits were filed by the Sierra Club Legal Defense Fund (SCLDF). A lawsuit filed in Texas in April provided a limited injunction/restrictions for SPB control in wilderness. The judge ordered the FS to stop cutting hardwood trees and to cut pine trees only to save RCWs or to impede the spread of the SPB. The judge further ordered that the FS make use of “natural barriers”, streams, roads, railroad rights of way, and cleared lands” during its SPB control efforts.
The second lawsuit that the SCLDF filed was in Washington, D.C. dealt with cutting in wilderness areas in Louisiana (like the Kisatchie Hills Wilderness Area), Mississippi, and Arkansas.
Linked with these attacks on ETWA were areas that used to be Wilderness Proposals, Further Planning Areas, or Wilderness Study Areas, like the Four Notch Further Planning Area, that were cut, logged, crushed, burned, and artificially planted.
SPBs began spreading in “Four Notch” and the FS cut buffer after buffer until 2,600 acres of pine and hardwood forest had been cut (helicopter logging) and looked like a giant clearcut. In addition, the nexus of fire and logging then came into clear view when the FS used a 52 ton “tree crusher” to knock down all living trees (usually hardwood trees) in the 2,600 acres and allowed helicopters (helitorch) to use a “napalm-like substance” to burn the entire area.
An area that had once been a proposed wilderness area then was artificially planted with pine trees. “The protector of the forests is burning them says George Russell of the Sierra Club’s Lone Star Chapter. Smokey the bear has become schizophrenic.”
The 1987 lawsuit, Sierra Club v. Lyng, (which included The Wilderness Society) was brought against the Secretary of Agriculture, U.S. Forest Service, about SPB control in wilderness areas in Louisiana, Arkansas, and Mississippi. “Among the court’s holding were that under the Wilderness Act, the Secretary had an affirmative burden of justifying his actions by demonstrating they are necessary to effectively control the threatened harm that prompts the action being taken.”
The LSC interpreted necessary, “to mean that the Secretary needed scientific proof that the cutting was necessary before the program could be implemented” but “The court found that the plaintiffs had interpreted necessary too narrowly which “should be read as the means needed to achieve a certain result or effect”.
The trial court said, “The pertinent section of the statute is therefore most reasonably construed as allowing the Secretary to use measures that fall short of full effectiveness so long as they are reasonably designed to restrain or limit the threatened spread of beetle infestations from wilderness land into the neighboring property, to its detriment.”
“The trial court also found that wilderness areas would not be sacrificed for private land interests but that the Secretary had properly explained that private landowners would exert the same amount of effort as the Forest Service to control beetle infestation.”
The LSC, in this lawsuit, argued that the FS had not prepared an EIS. The trial court found and agreed with the LSC and granted a preliminary injunction but didn’t determine if the SPB control program was permissible pending publication of the EIS. The FS wrote an EIS on short-term beetle control and a Record of Decision (ROD) which laid out why the FS felt SPB control was needed.
From these two lawsuits, sprung mitigation measures from the April 6, 1987 Final EIS and ROD for the “Suppression of the Southern Pine Beetle”. Changes from the existing SPB control program included:
“1. The policy will be to not control SPB in wilderness unless an essential RCW colony (cluster) and foraging area is threatened: or unacceptable damage is predicted to occur on adjacent State and private lands; or Federal lands having high-value forest resources other than commercial timber.
“2. Less control will be undertaken in wilderness because control will be allowed only within ¼ mile of the wilderness boundary and to protect essential RCW colonies.”
“3. No control will be undertaken to protect commercial timber resources on adjacent Federal lands.”
“4. Use of the spot growth model will improve the accuracy of predicting which spots are expected to spread from the wilderness onto adjacent State and private lands, or Federal lands having high-value forest resources other than commercial timber.”
“5. No action will be undertaken within wildernesses unless a reasonable expectation exists that the treatment will be successful.”
“6. Greater forest improvement emphasis will be focused on the lands adjacent to the wildernesses to make them less susceptible to SPB attack.”
“7. The public will be informed when SPB control is undertaken to protect essential RCW colonies and involved in the decision to control to prevent the spread of an SPB infestation from the wilderness onto adjacent State and private lands, or Federal lands having high-value forest resources other than commercial timber.”
“Wilderness (General)”
“1. No SPB control action will be taken in wilderness unless an infestation threatens an essential RCW colony or occurs within ¼ mile of susceptible host on State and private land or high value forest resources on Federal land and is predicted to spread onto that land causing unacceptable damage on that land. Infestations will be allowed to run their natural course unless the aforementioned resources are threatened.”
“2. No SPB control action will be taken in wilderness until a site-specific analysis of the infestation and surrounding site conditions is completed and documented. The site-specific analysis must indicate that successful control can be expected, given: (a) the intensity on the infestation; (b) the constraints applied to the control methods for use in wilderness and (c) the resources available to control the spot.”
“3. IPM control methods for SPB are modified for use in wilderness as follows:
“a. Cut and Remove – use helicopter, draft animals or cable skidding from public roads, or access, to remove infested logs. In visually sensitive zones such as along hiking trails, remove entire tree if feasible or otherwise remove slash from visual zone. Helicopter flight lines will avoid trails where possible.”
“b. Cut and Leave – no modification for use in wilderness except to cut slash to lay close to the ground or remove slash if feasible tin visual zones to mitigate visual impact.”
“c. Cut and Hand Spray – same modifications as cut and leave method.”
“d. Pile and Burn – this method will not be used in wilderness.”
“4. Monitoring, ground checking and tree felling crews will travel to infestations by non-motorized methods. Only under conditions in Item 5., following, will vehicles be allowed.”
“5. In extenuating circumstances, such as an intense outbreak, or lack of adequate resources to implement the preceding control methods, use of motorized ground vehicles may become necessary to protect essential colony sites or adjacent lands as described under alternative 4. However, use of such to do control work in wildernesses would require complete documentation of the extenuating circumstance and approval in advance by the Regional Forester. This deviation would be used only as a last resort when destruction of an essential RCW colony or unacceptable damage on adjacent lands is imminent.”
“When the use of motorized ground vehicles is permitted in wilderness by the Regional Forester, the following management requirements apply:”
“a. Use only the existing roads or access ways. Limit road improvements to a standard no higher than required for safe passage of equipment and workers, and to protect the soil.”
“b. Return existing roads to as near their pre-use condition as soon as they have served their purpose.”
“c. Close all roads and access ways needed for SPB control to motorized public use. Only use associated with the control of the SPB and administrative use will be allowed.”
“d. Use fords (no structure) where possible, but only under conditions that will not visibly change physical stream characteristics. These conditions are:”
“(1) Bedrock stream bottom and lower banks.”
“(2) Rock or gravel stream bottom and lower banks.”
“e. Install temporary stream crossing structures using the largest fill materials available. Crossing will be removed completely after control operations are completed. Stream banks and bottoms will be reclaimed to approximately the original conditions.”
“f. To the greatest extent possible, schedule control activities when visitor use will be lowest.”
“6. All practical efforts to protect hardwoods will be made when SPB control actions are implemented. No hardwoods will be cut unless to insure the safety of crews or wilderness user.”
“7. The affected and interested public will be informed or involved as appropriate in the decision to control in wilderness. (See exhibit 2)”
“Wilderness Protection of Essential RCW Colonies”
“1. Only essential RCW colony sites and foraging areas (approximately 125 acres per site) will be protected from SPB in wilderness. Essential colonies are defined by the U.S. Fish and Wildlife Service (FWS) as:”
“a. Colonies not located on the periphery of the species range and,”
“b. Colonies located where viable population levels have not been met in the general forest area surrounding the wildernesses, according to the RCW Recovery Plan.”
“2. An essential RCW colony in wilderness must be occupied or have been occupied during the previous breeding season. Colonies having been vacated longer would not be protected in wilderness.”
“3. Spots located within ½ mile of essential colonies will be ground checked so predictions of spot growth with a SPB spot growth model can be made. Control action will only be taken on spots predicted to adversely affect the colony site and foraging areas (totaling 125 acres) within the next 30 days and threatens the continued existence of the colony. If the spot is not predicted to impact the colony in 30 days, monitoring will continue until the spot warrants control under the 30-day criteria or is no longer considered a threat.”
“4. The management requirements under Wilderness (General) and General Forest Area and Wilderness (RCW Colony Site Protection), also apply.”
“Wilderness (Protection of Adjacent Lands)”
“1. Infestation must occur within ¼ mile of susceptible host type on State and private land or high value Federal forest resources (other than commercial timber)., and be predicted to spread onto and cause unacceptable damage on these lands before control action is considered.”
“2. Aerial detection will be used to identify and locate for ground checking all infestations in wilderness within ¼ mile of susceptible host on State, private or high value Federal Forest resources.”
“3. Infestation located within ¼ mile of these lands will be ground checked as soon as possible (generally two days) following detection to collect data for input in a SPB spot growth model and determine the direction of spread.”
“4. Spot growth model predictions will be completed as soon as possible (generally three days) from ground check. Forest Pest management personnel will provide the extent of tree kill predicted by the model. This information will be used to estimate the location and extent of damage on adjacent lands from the uncontrolled infestation.”
“5. A site-specific analysis will be completed and documented on each infestation predicted to impact adjacent lands prior to implementing control action. It will assess the predicted impacts to adjacent land considering landowners’ management objectives, age and condition of trees and the current threat of SPB impacts from other non-wilderness sources. Direct, indirect and cumulative impacts to the wilderness attributes and other resources will be assessed and considered equally in the control decision process.”
“6. The management requirements for control under Wilderness (general) and under General Forest Area and Wilderness (General) also apply.”
“General Forest Area and Wilderness (RCW Colony Site Protection)”
“1. Trees vacated by the SPB will not be cut or chemically treated unless necessary to insure public safety.”
“2. Inactive and relict cavity trees, if infested, or within a designated treatment buffer zone, may be cut to secure RCW colonies. (Requires evaluation by a Forest Service wildlife biologist.)”
“3. Uninfected trees within a 200-foot buffer around RCW cavity trees would not be cut or chemically treated unless such control efforts would be likely to prevent SPB infestation of cavity trees.”
“4. Disturbance in the colony sites will be kept to a minimum especially during the breeding season. No salvage operations will be conducted in active colony sites from March 1 through the time RCW young have fledged (approximately July-August). Control activities would be limited to the felling of trees or chemical treatment, or both, if necessary to secure the colony site during the breeding season.”
“5. Control activities within ½ mile of RCW colonies will conform to the guidelines set forth in the FS Wildlife Habitat Management Handbook (FSH 2609.238). Where cut and leave and cut and remove techniques are not feasible, and cut and hand spray is used, no standing trees will be sprayed. Pile and burn will not be used near active RCW colonies.”
“General Forest Area and Wilderness (General)”
“1. Site-specific analysis must be completed for any proposed SPB control action. This analysis will determine if a biological evaluation is necessary to determine if any threatened and endangered species or species being proposed for this status may be affected by the treatment. If the proposed treatment may affect one of these species or its habitat, consultation with the FWS is required under the Endangered Species Act. If sensitive species may be affected, coordination with the appropriate Federal or State agencies will occur. If adverse impacts could occur, the site-specific biological evaluation will identify possible mitigation measures.”
“2. Use control methods that will minimize soil disturbance.”
“3. Use of erosion control measures as soon as possible after the ground disturbing, SPB suppression activities are completed, to prevent or minimize erosion, sedimentation and long-term site deterioration.”
“4. Cultural resource surveys and coordination before soil disturbing activities are implemented. Site evaluation and protection will minimize disturbance of significant sites.”
“5. The cut and hand spray technique must only be used according to general direction set forth in FSM Chapter 2150, Pesticide Use Management. Label instructions for insecticides registered for beetle control must be followed.”
“6. Standing trees will not be sprayed with insecticides.”
“7. Insecticides will not be used in a manner that would adversely affect threatened or endangered species.”
“8. The potential risk to humans and the environment will be minimized by applying insecticides only according to label instructions, Forest Service policies and other Federal regulations. Application will be supervised by a certified pesticide applicator. Areas treated with insecticide will be signed and closed to firewood collection (See Appendix C.)”
“9. Workers who apply insecticides will be trained to ensure minimum impacts and maximum effectiveness. Only those methods that assure proper application of insecticides on the infested tree bole would be used.”
“10. Riparian ecosystems that encompass floodplains and wetlands will receive appropriate protection. As a minimum, riparian areas will extend 100 feet from the edge of all perennial streams and other perennial water bodies, including lakes. Site investigations to identify riparian areas and floodplains will consider the soil and plant characteristics of the site, and will be guided by appropriate Forest Service direction and State requirements. Roads that cross riparian areas will be stabilized with rip rap, vegetative establishment, or other appropriate methods.”
“11. Logging Equipment will be kept out of perennial and intermittent stream channels except on approved, designated crossings. Crossings will be at right angles to the stream or riparian area.”
These were now the rules and mitigation measures that the FS would have to use to deal with SPB control in wilderness areas, including the NFGT.
In May 1990, the LSC and others complained that the FS SPB program in wilderness was negatively impacting LLCWA in SHNF. The FS used the rationale that the trees cut were near essential colonies (now called clusters) of the endangered RCW and its foraging areas.
The LSC kept pushing for other SPB control measures, like the use of pheromones, specifically verbenone. George Russell, volunteer LSC leader and spokesperson, requested that the Texas Forest Service use verbenone on his forested property where there was a SPB infestation.
The results of the successful use of verbenone on Russell’s property were submitted to the Executive Director of Texas Parks and Wildlife Department (TPWD) on May 25, 1992, with the request that TPWD request that U.S. Fish and Wildlife Service (FWS) and U.S. Forest Service “reinitiate consultation on the use of this treatment in RCW habitat, wilderness areas (like LLCWA) and scenic areas (like Big Creek and Winters Bayou Scenic Areas) to minimize environmental impacts to these sensitive areas.” Similar letters were sent to the FWS and the National Forests in Texas.
The LSC pressed the FS for additional information about research on SPB control. The LSC made a FOIA request for a copy of, “Report of New Information Relevant to the FEIS for the Suppression of the Southern Pine Beetle – Southern Region”, and any associated documents.
The LSC stated that it hadn’t been notified about this reassessment and hadn’t been asked for comments. The LSC stated that it had made its concerns known to the Region 8 Office over the past two years about the inadequacy of the SPB FEIS with respect to wilderness and scenic areas. The LSC stated:
“In particular we have notified the Region 8 Office about the devastation that is occurring in both Little Lake Creek Wilderness Area and Big Creek Scenic Area. In addition we feel strongly that impacts on forest interior species, riparian and wetland and bottomland hardwood areas, sensitive plant species (like trillium), and other issues are being ignored by the National Forests in Texas while these important and sensitive resources are being destroyed. We object.”
The fight continued as SPBs continued to live their lives in the forest. U.S. Congressman Charlie Wilson, in October 1993, revealed that he was sponsoring a bill to allow the FS to cut trees throughout wilderness areas, “to protect trees on nearby private lands from the southern pine beetle.”
Wilson’s bill would remove the ¼ mile buffer on the boundary of wilderness areas where cutting of trees is allowed. Tom Maddux, LSC representative, stated, “If this goes through, we might as well not have a wilderness area”.
Wilson said that there is “a tremendous amount of timber that is lost each year in wilderness areas because of the southern pine beetle.” The bill, “will untie the hands of the Forest Service and allow them to attack the beetle with a great deal more vigor.”
The bill would allow “salvage-harvesting of timber already damaged by beetles and also the cutting and harvesting of uninfested trees in new buffer zones.”
Maddux stated that wilderness areas have “an unnatural density of pines from past (Forest Service) management, and the beetles are just restoring the natural balance between pines and hardwoods that existed historically.”
Maddux said, “Dead pines (killed by beetles) are no more a natural calamity than fire at Yellowstone (National Park), … They’re just part of a natural process.” Maddux further stated that “Wilson’s bill … is part of a nationwide push to use forest health as an excuse to cut more trees in national forests. It’s happening in every region of the country”.
Maddux further expanded on the problem in an eloquent op-ed that was published in the Houston Chronicle in November 1993. In that op-ed, Maddux laid it all out when he stated:
“U.S. Rep. Charles Wilson … has introduced HR 3233 … which would abrogate the federal Wilderness Act and allow logging deep inside our Texas wilderness. Wilson’s bill is in response to pressure from the loggers, from so-called “wise use” groups, from the Texas Forest Service and from the U.S. Forest Service.”
“These … have worked in concert … to create a panic among private timberland owners in order to build public support for their agenda of wilderness destruction.”
“Wilson’s bill is bad public policy. It has no firm scientific basis in its proposed control of the beetles. The arguments for this bill do not stand up to cool-headed, rational analysis.”
“… this beetle epidemic, far from being a disaster, is simply a natural occurrence that will restore the ecological balance between pines and hardwoods that existed before commercial foresters created vast monocultures of pine.”
“… to claim that beetle-killed trees are wasted is sheer ecological ignorance. Nature doesn’t waste anything. Those dead trees provide foraging and nesting sites for many woodpeckers and other wildlife. Then they fall, decay and return their nutrients to the soil to nourish another generation of trees.”
“… the so-called control methods proposed to be used in the wilderness areas will fail just as miserably there as they have elsewhere. There is no scientific evidence that the buffer-cutting technique used by the Forest Service works any better than simply letting nature take its course.”
“Over a longer term of, say, 10 years, buffer cutting manifestly does not work. In that amount of time, we see that whole areas have been cut down to “control” the beetle. Some control!”
“The Forest Service simply wants to use beetle infestations as an excuse to cut more timber. Why else would it refuse to use verbenone, a behavioral chemical emitted by the beetles themselves. Verbenone tells other beetles, “Stay ways, no more room in this tree.” Synthetic verbenone treatments have provided to be effective in halting infestations.”
“There simply is no firm scientific evidence for invading our wilderness areas with chain saws and logging trucks. Only one-third of 1% of East Texas forest land is wilderness. Can’t we at least leave that much alone?”
Meanwhile, the FS linked SPBs to other possible problems in wilderness so that more logging of trees in wilderness areas could occur. The FS put together, on January 31, 1994, with no public input or notification, a document entitled, “Wilderness Wildfire Hazard as Related to Tree Kill by Southern Pine Beetles on the National Forests in Texas”.
This document was a strategy to raise fear in the public of pine-beetle killed areas in ETWA. It was generic in description but very specific in how to address the problem. For instance, the “Summary” of this document stated:
“Southern pine beetles have recently killed most of the pine trees on large areas of the five Wilderness /areas on the National Forests in Texas. A total of 17,333 acres of pine trees have been killed or are currently infested.”
“The fuel conditions which develop following beetle-kill significantly increase the potential for dangerous wildfires under very high-to-extreme fire danger conditions, which occur on an average of 18 days per year. These fuel conditions significantly increase the risk of wildfire damage to adjacent private property.”
“The standing dead trees in beetle-kill areas pose an extremely high hazard to fire fighters. The threat of falling trees and limbs make it difficult to contain wildfires at small acreages while still minimizing disturbance to Wilderness values.”
“The current wildfire suppression capability of the Forest (and its cooperators) was not designed to meet this threat. The Forest’s suppression capability should be increased by:”
“1. Obtaining two additional tractor/plow units (with transports) which are called for at the Most Efficient Level of the current NFMAS analysis.”
“2. “Upgrading water-delivery capability by replacing four existing small slip-on engine units with larger capacity engines (with foam capability) on the Districts with Wilderness.”
“3. Providing availability of a 20-person Emergency Firefighter crew when fire danger is Class D or Higher (18 days per year).”
“4. Providing availability of two medium helicopters with buckets on the 18 highest fire danger days.”
“5. Considering set-up of a portable airtanker base at Lufkin, TX when the Keetch-Byram drought index is above 500 and at least 2 weeks of high fire danger are forecast.”
“The Forest should also further analyze the feasibility of using prescribed fire for fuels reduction, with appropriate public involvement and environmental analysis.”
No coverage of ecological damage, that this plan, if implemented, would cause in wilderness areas, was mentioned.
Environmentalists continued to address the SPB problem via other avenues. A report prepared for the HSC by Dr. Steven P. Lewis was released February 1994. This report was entitled, “Control of the Southern Pine Bark Beetle and Its Relationship to the Survival of the Red-Cockaded Woodpecker”.
This report was prepared to collate all significant information about SPBs and RCWs. The report stated:
“… but there are three factors that complicate southern pine beetle control efforts. First, there are short and long-term impacts on the forest community. Short-term impacts occur because the southern pine beetle control areas are treated mostly like clearcuts, with site preparation and planting of nursery-grown clone seedlings. The long-term suppression of hardwoods creates an almost pure stand of pine, creating another high risk forest.”
“Second, pine trees are not entirely an agricultural commodity. Since trees are long lived and constitute part of our natural environment, they possess esthetic, wildlife, and recreational values. Because of this, undue impact on forests to control the southern pine beetle can lower these values.”
“Third, a considerable amount of southern forests are under the control of the United States Forest Service (USFS). Although the USGS is legally bound to manage our forest resources for multiple use (recreation, esthetics, biodiversity, and timber production), the overriding use has been timber production. Management practices meant to control the southern pine beetle, such as the cutting of buffer zones around southern pine beetle spots tend to reduce the esthetic and biological value of the forests … As a result of these practices, environmentalists feel that the USFS is not following its mandate to preserve our forest resources for multiple use. It should be pointed out that while the same southern pine beetle control are used on private land, there does not exist a mandate or law for private landowners and southern pine beetle control has not been a cause for controversy on private lands.”
“It should be remembered that southern pine beetles and pine trees have coexisted for millions of years and neither are in immediate danger of becoming extinct. However, many of the present pine forests are not the same as pine forests of the past. Instead of being widely spaced, uneven-age trees of many species with great genetic variability, modern managed forests, such as those planted by the USFS, are composed of closely spaced, even-age trees of a single genetically identical species.”
“The southern pine beetle was important in the evolution of forests. Its role in the dynamics of the pine ecosystem was to kill senescent trees and allow a mosaic of age classes to exist. Modern silvicultural practices, with its goal of maximizing timber production and its preference for even-aged monocultures of pine, have created conditions favoring epidemics of southern pine beetle infestation.”
“Since woodpeckers have been shown to effectively control southern pine beetle under endemic conditions … silvicultural changes may increase the number of woodpeckers in the forest, thereby increasing the effectiveness of woodpeckers as control agents of southern pine beetles. Their suggestions include:
“1. Maintaining mixed pine-hardwood stands around the pine stands. It is particularly important to have mature forests present.”
“2. If clearcutting is used … it is important to limit the size of clearcuts to under 40 acres. Large clearcuts make a tract of land unsuitable for woodpeckers for 20-30 years.”
“3. Further reduction in habitat suitability for woodpeckers is caused by site preparation after a clearcut … Reduce site preparation allows foraging sites for some woodpeckers (hairy and downy) to exist for several years.”
“4. It is also important to maintain deciduous vegetation because many insects that woodpeckers feed on are associated with this type of vegetation. This is contrary to the Timber Stand Improvement guidelines.”
“5. Dead trees (snags) should be left standing since they are foraging areas and potential nest trees for woodpeckers. Regulation of the number of snags can significantly impact woodpecker numbers. Even beetle abandoned southern pine beetle killed trees should be left for this purpose.”
“6. Longer rotation times also favor woodpecker populations. Seventy years is the minimum rotation for hairy and downy woodpeckers while orations of 80-120 years are needed for optimal pileated woodpecker habitat.”
Some recommendations and management implications that this report suggested included:
“1. Reduction of basal area in overstocked stands … would be less detrimental to the stand than having to resort to cut-and-leave, cut-and-remove, or cut-and-burn.”
“Since southern pine beetles prefer stands with a higher percentage of pines, a logical management alternative to pure stands of pines is mixed pine/hardwood stands.”
“2. Man-made chemicals should be avoided.”
“Nonchemical methods should also be used for hardwood control … prescribed fire should be considered.”
“3. Behavioral chemicals such as verbenone show promise … The use of such chemicals is especially needed in sensitive areas (red-cockaded woodpecker colony areas, Wilderness, scenic and riparian areas)”.
“4. Red-cockaded woodpecker colonies and surrounding areas need to be managed to reduce the risk of southern pine beetle infestation.”
“5. Disturbances in and around the colonies should be held to a minimum … If logging is to be carried out around the colony and buffer zones, this activity should be excluded during the nesting season.”
“6. They suggest that to mimic this phenomenon a modified shelterwood cut (instead od clearcutting) or a thinning cut should be the management policy in forests surrounding existing red-cockaded woodpecker cavity trees.”
“7. Clearcuts should be outside of the foraging habitat of the birds … Selection cutting does not present the same problem as clearcuts but the increase in understory height that results from this treatment would have to be controlled by mechanical thinning or prescribed fire to keep the habitat optimum for red-cockaded woodpeckers.”
“8. Although some people claim that timber production and red-cockaded woodpeckers are mutually exclusive, the proper management of a forest can do both … timber production and red-cockaded woodpecker can coexist if rotations are increased to 80 or more years and if suitable mature habitat is maintained.”
“9. The construction of artificial cavities may help the recovery of the red-cockaded woodpecker.”
“10. If the hardwoods in a red-cockaded woodpecker nesting area encroach into the midstory and fire or chemical control is not desirable … allowing firewood cutting around the cavity trees … Certain restrictions (e.g., trees to be removed clearly marked, Forest Service personnel present during cutting)”.
“11. Reinstate the “corridors concept” that was deleted from the first recovery plan. This strategy called for the management of interstate highway rights of way as corridors of suitable habitat for red-cockaded woodpecker that would aid in the dispersal among populations.”
The LSC used this and other documents in its efforts to reduce FS SPB control impacts.
The LSC continued its efforts against Rep. Wilson’s H.R. 3233, which would allow the cutting and logging of pine trees deep within the five ETWA. Tom Maddux provided comments on June 1, 1994, to the Subcommittee on Specialty Crops and Natural Resources, Committee on Agriculture, in Washington, D.C., at the U.S. Congress for the LSC and The Wilderness Society. The LSC’s comments stated:
“The Sierra Club and The Wilderness Society are both strongly opposed to H.R. 3233, Congressman Wilson’s bill to allow timber cutting deep within our five wilderness areas in East Texas.”
“This bill would override both the Wilderness Act of 1964, the law which established our nation’s wilderness system, and the Texas Wilderness Act of 1984, which created our five wilderness areas in East Texas. Indeed, this bill – if enacted – would cut at the heart of what is understood by the term “wilderness.”
“Wilderness is an American idea and an American ideal. The idea of preserving some parts of nature from human tinkering was and still is a revolutionary concept. And like all revolutionary concepts … wilderness is controversial. Wilderness has its opponents; but we believe and hope that like other great American ideas, wilderness will endure.”
“It required decades of hard struggle and in the end great compromises to convince Congress of the desirability, and I would say the necessity of creating a wilderness system to preserve for all time some large representative samples of the native American landscape.”
“Congress intended and specifically stated, with certain exceptions, that wilderness areas were to be managed by Mother Nature and not by the meddlesome hands of over-eager humans.”
“If we destroy that principle – the principle that wilderness should evolve under natural processes – then we destroy the very essence of wilderness. H.R. 3233 would destroy that principle and if enacted would permit the Forest Service to rip the heart out of our precious East Texas wildernesses.”
“Some people are understandably distraught at the sight of the massive Southern Pine Beetle infestations in Indian Mounds Wilderness and other wilderness areas. “This infestation may not be the prettiest of sights, but it sure beats the wreckage that would be done by logging the area.”
“It must be remembered that the beetles are a natural force in the forest ecosystem, just like fire.”
“Likewise, if the current outbreak of beetles in wilderness areas is of extraordinary proportions, that is simply because for decades the Forest Service has been converting mixed native forests into monocultural plantations of pine. It was inevitable that this unnatural imbalance would eventually be corrected.”
“I believe that a few years hence, when the passions of the moment are cooled, we will all see the current Southern Pine Beetle outbreak in our wilderness areas just as enlightened people now see the recent wildfires in Yellowstone – not as a disaster, but as a natural occurrence that has worked to restore the natural balance of pines and hardwoods that existed in the virgin forests of East Texas.”
“Expert opinions are divided, but it seems that the preponderance of scientific opinion outside the U.S. Forest Service, the Texas Forest Service, and the timber industry, is very skeptical of the efficacy of these methods (cut-and-leave and cut-and-remove). Moreover, independent scientists are overwhelmingly opposed to using these methods in wilderness areas.”
“What Dr. Lewis suggests instead, and what the Sierra Club and The Wilderness Society will support, is the experimental use of verbenone, a beetle pheromone that essentially tells other beetles (no vacancy here, go away.” Verbenone can be produced synthetically and has been used successfully to stop small SPB outbreaks without any cutting of trees, either infested or uninfested.”
“We consider the use of verbenone in wilderness to be a non-invasive procedure and we will support its experimental use, there, which is already permissible under current law.”
“Whatever the reasons, we believe that once nature has reestablished the former balance between pines and hardwoods we will then see that SPB densities will be dramatically lower in wilderness than in commercial pine plantations.”
The LSC fought against H.R. 3233 and ultimately this bill wasn’t approved by the U.S. Congress. Surprisingly the FS testified against H.R. 3223 in Congress. The LSC sent a letter on June 7, 1994 to Alan Newman, Forest Supervisor, NFGT, thanking him for testifying against H.R. 3223. The letter stated:
“Although the Forest Service and the Sierra Club do not agree regarding cutting in Wilderness Areas (as you know the Sierra Club is opposed to southern pine beetle cutting in East Texas Wildernesses) it was good to see the Forest Service testify that there are real Wilderness values that will be destroyed in H.R. 3223 is passed in Congress.”
“We particularly appreciate your recognition of wilderness character and natural ecosystem processes. The SPB, as you state, is a natural phenomenon that has a purpose in wilderness. We also appreciate your acknowledgement that timber removal for salvage is inconsistent with wilderness management purposes.”
“We urge you again to consider relooking at the cutting in Wilderness and scenic area issue by contacting the Regional Office and letting them know this is an issue that needs further assessment in an amended SPB EIS. We need to let natural processes function as they are supposed to with as little interference from us as possible. Cutting in Wilderness or scenic areas I not appropriate.”
“Again, thank you for recognizing wilderness values and the need to protect them from SPB control.”
During these difficult times the NSC amended its 1977 “Wilderness Management” policy on July 8, 1995. Some quotes from that policy are appropriate for this history:
“The Wilderness Act of 1964 is the basic charger for wilderness management direction.”
“Within the context of the Wilderness Act, the primary wilderness management objective should be to protect “an enduring resource for wilderness” from significant degradation by human influence and use.”
“Each wilderness possesses individual characteristics. The application of wilderness management techniques should reflect the individuality of each wilderness within the context of requirements to preserve the wilderness resource. Wilderness management plans should provide for flexibility in meeting conditions that very with location and time.”
“Wilderness serves as a benchmark, permitting comparison of relatively unmodified environments with other environments. The protection of this benchmark function may, in some cases, require limitations on use.”
“In wilderness management, natural ecological processes should be allowed to operate freely to the maximum extent feasible to promote, perpetuate, and, where necessary, restore the wilderness character of the land. Minimal manipulation may be allowed in order to restore human-disturbed environments or offset human-induced restrictions on natural processes.”
“The managing agencies should develop site-specific wilderness management plans for each wilderness. Development and adoption of such plans should require maximum public involvement at all stages, and the Sierra Club urges all concerned citizens to participate. In all instances the minimum tool for management should be used.”
“Monitoring, measuring and scientific study of the wilderness environment should be allowed as long as it is as unobtrusive as possible. Restraint should be applied to and by the managing agencies over the impacts of research, experimentation and environmental monitoring so as to protect the resource and experience.”
This is the current NSC policy that the LSC and its local groups use and implement when dealing with wilderness and FS proposals for SPB control.
SPB control and wilderness management next meet in 2012. The LSC submitted pre-scoping comments on April 26, 2012, for an EA for SPB in wilderness areas on the NFGT. The LSC stated:
“2) Although this is not a popular statement to make, SPBs are the agents of natural disturbance that help shape a forest’s structure and composition. SPBs ensure that the natural ecosystem process of disturbance functions well. Therefore treatment measures that reduce or remove SPBs from wilderness are interferences with natural processes and should not be allowed inside of wilderness. Since wilderness is supposed to be a place you visit, where you enter on Nature’s terms and not your own, human manipulation of wilderness (trammeling) should be minimized and eliminated as much as possible so wilderness can freely express itself, uncontrolled.”
“SPB killed trees in wilderness are an important part of the wilderness experience, wilderness character, and natural process of Nature. SPBs provide important ecological residuals like snags, coarse woody debris (downed trees), and vegetation diversity along with ecological structure, increased mast production, increased hardwood tree populations, increased biodiversity, reduced soil erosion, watershed protection, and other important functions. In addition, SPB areas create a matrix or patchiness that is a natural product of this natural disturbance.”
“A good example of this effect is discussed in an article in the Natural Areas Journal, Volume 20, No. 4, 2000, by Timothy B. Harrington, Mingguang Xu, and M. Boyd Edwards, entitled, “Structural Characteristics of Late-Successional Pine-Hardwood Forest Following Recent Infestation by Southern Pine Beetle in the Georgia Piedmont, USA”. This article states, “Results indicate that small patch mortality from southern pine beetle increased structural complexity of late-successional pine-hardwood stands by causing localized reductions in stem density of large pines (and therefore reduce susceptibility to future beetle attacks) and associated increase in tree species diversity. Development of several old-growth characteristics, particularly increased abundance of snags and dominance by late-successional hardwood species, has been accelerated by southern pine beetle infestation … Stand basal area of all trees within SPB-infested stands (18.1 m2 ha -1) averaged only 40% of that observed in non-infected stands (45.1 m2 ha-1) (Table 1), indicating that SPB greatly reduced the risk rating of these stands for future infestation … Because they are not a host species for SPB, hardwoods may act as a barrier for beetle dispersal to adjacent pines. In addition, foliage of specific hardwoods (e.g., sweetgum) emits volatile compounds that confuse the ability of SPB to locate other pine trees … These canopy gap dynamics should reduce overall susceptibility of the forest to SPB infestation because spacing among residual pines has been increased and the larger pines have been reduced in abundance.”
“Similar effects were shown in the two research papers that the FS provided the Sierra Club, “The suppression of Dendroctonus frontalis and subsequent wildfire have an impact on forest stand dynamics” and “Forest composition following overstory mortality from southern pine beetle and associated treatments”.”
“The thinning function of SPBs (Sierra Club’s term for landscape scale changes) is distinctly obvious from the quotations from the article mentioned above. This thinning of pine trees done by SPBs across the landscape allows for other ecological changes and functions to proceed as demonstrated in “The Ecology of Natural Disturbance and Patch Dynamics”, edited by S.T.A. Pickett and P.S. White, Academic Press, 1985, pages 243-249, which states:”
“1. A. Increased Plant Mortality … Populations of bark beetles and other wood-boring insects grow in trees severely stressed by prior injury, disease, or herbivory … Bark beetles of the family Scolytidae are particularly important mortality agents in forest ecosystems.”
“2. B. Patch Predisposition to Disturbance … Forest regeneration occurs in the wake of pine mortality … In the absence of subsequent disturbance, beetle-induced mortality of the dominating pines accelerates the transition to fire-intolerant hardwood forest, with the youngest hardwoods in the immediate wake of the mortality wave and progressively older hardwoods extending away from the wave … Fire, fueled by abundant woody litter, probably terminates the advance of the insect-induced mortality wave but provides new beetle refuges in fire-scarred pines. Fire also destroys fire-intolerant hardwoods and re-establishes the pine forests, which again becomes increasingly vulnerable to insect-induced waver mortality after 30 years.”
“3. IV. Insects as Regulators of Ecosystem Productivity … A. Community Organization … In some ecosystems, environmental conditions prevent establishment of competing vegetation, and insect regulation of resources demand occurs through changes in the age distribution of vegetation. For example, pines are tolerant of fire but intolerant of resource limitation relative to hardwoods and some other conifers. Frequent fire maintains pine forests by reducing interspecific competition for resources, but intraspecific competition for light and nutrients often leads to senescence of overstory pines and prevents pine seedling establishment. Because large pines are rarely killed by fire, insect-induced mortality of stressed overstory pines may be a major mechanism in promoting pine regeneration and productivity in such ecosystems.”
“The point that the Sierra Club makes is that continued human manipulation of wilderness does not mimic the natural disturbance regime and ensures that the imbalance in ecological evolution and processes continues. These unnatural actions (treatment measures) cause the forest to operate in a less natural, protective, and sustainable manner. This will cause the forest to become less healthy and not healthier.”
“For wilderness, unless absolutely necessary (due to the law defined by the SPB lawsuit of the 1980’s) even the use of pheromones in wilderness should not be allowed. This issue as well as the issue of the value of SPBs for forests due to their natural disturbance, patchiness creation, vegetation diversity, and forest structure and composition value and benefits should be discussed in the EA. Pheromone use outside of wilderness would be a welcome reasonable alternative discussed in the EA.”
“3) The Sierra Club is opposed to cut/remove (cut/log SPB infested trees and a green tree buffer that has no SPBs), cut/hand spray (cut SPB infested trees and spray with insecticides), or pile/burn (cut SPB infested trees and burn the logs). These treatment methods in wilderness are far too intrusive, manipulative, controlling, and ecologically harmful.”
“The Sierra Club’s first choice is not to implement treatment measures in wilderness. If the FS decides to implement treatment measures in wilderness then the Sierra Club favors the following measures in order of priority:”
“1. Treat SPB areas with pheromones (in concentrations that are equal to that used in the 1990s and experimentally if need be to utilize this concentration) and do not cut a buffer of living green trees. Use the pheromones verbenone and or frontalin.”
“2. If cutting is done, do only cut/leave with no green tree buffer cut. No logging, selling, or giving away of trees cut in wilderness. Trees on the ground will act as nurse trees where young seedlings can grow, provide nutrients for soil, provide shelter and food for animals, create moisture retention habitat, and act as erosion dams to stop sediments from entering water.”
“3. No SPB cutting in streamside zones, areas with sensitive plant or animal habitat, wetlands, seepage areas, sensitive soil areas that rut/erode easily, or bird or other monitoring sites.”
“4. Require that FS personnel mark important wildlife trees, large trees, snags, and den trees for protection during cutting. If any of these trees are damaged or destroyed the logger must pay a monetary penalty. A clause will be placed in the contract which requires a penalty for such actions.”
“5. Directionally fell SPB trees so that the minimum damage occurs to pine and hardwoods trees that are not felled.”
“4) The Sierra Club wants all reasonable alternatives analyzed in the EA. According to the Council on Environmental Quality's (CEQ) regulations that implement the National Environmental Policy Act (NEPA), all reasonable alternatives must be considered. The above stated treatment measures are reasonable alternatives or can be included as parts of reasonable alternatives.”
“5) The impact of reopening closed roads or building new roads on fragmentation of the forest, forest interior species, recreational activities (like hiking on the Lone Star Hiking Trail (LSHT) or the Four C’s Trail (4C’s)), proposed, endangered, threatened, and sensitive species (PETS), and other issues must be considered. The Sierra Club is against the creation of roads or the reopening of former roads due to SPB activities in wilderness.”
“6) The EA should discuss the need for additional and closer supervision and monitoring of each area cut to ensure mitigation is done correctly and has not been ignored.”
“7) There is a need to specifically protect the LSHT and 4 C’s (Lone Star Hiking Trail and 4 C’s Hiking Trail) from the impacts of logging or cutting trees and associated activities.”
“8) The FS must discuss in the EA the trade-offs between protection of wilderness and protection of trees on national forest land adjacent to wilderness.”
“9) Any entries into wilderness that result in cutting of trees must be obliterated so that people cannot drive all-terrain vehicles (ATVs) or other motorized or non-motorized vehicles into wilderness after SPB treatment has occurred.”
“10) The impact of SPB cutting/logging on fragmentation of the forest from biodiversity landscape, ecosystem, community, species, and genetic perspectives should be discussed in the EA. This includes the impacts of too many openings (both roads built for the cutting, roads that already exist, and all other openings) which create linear or other fragmentation, increase in predators of neotropical birds and nests near SPB cut areas, increase in parasites of neotropical bird nests (like the brown-headed cowbird), more poaching due to greater access, more wildlife disturbance due to greater access, loss of solitude, loss of quiet, loss of natural sounds, changed microclimate effects on the forest (2-3 trees lengths into the forest) from the SPB cuts including increased light, increased dryness, decreased humidity, decreased interior forest habitat and species (like Yellow-billed Cuckoo, Pileated Woodpecker, Louisiana Water Thrush, Slender Wakerobin, Nodding Nixie, and all other such species known by the FS to be interior forest species).”
“11) The effects on aesthetics and scenic beauty should be addressed in the EA. Which is uglier, a SPB cut area or an area with large standing dead pines but intact other canopy trees, midstory trees, understory trees, shrubs, vines, herbaceous layer, grass layer, leaf litter, snags, and coarse woody debris layer with moss, lichens, and other plants.”
“12) The effects on recreation from SPB cutting including: more briars and other growth which makes it difficult to travel, a hotter climate which makes it unpleasant to use the cut area, increased habitat for ticks, chiggers, fire ants, and other pests, loss of vegetation to look at, loss of wildlife to look at, effects on birding in a once mostly undisturbed appearing area, effects on camping in a once mostly undisturbed appearing area, effects on hiking in a once mostly undisturbed appearing area, effects on nature photography in a once mostly undisturbed appearing area, effects on backpacking in a once mostly undisturbed appearing area, effects on nature study in a once mostly undisturbed appearing area, effects on canoeing in a once mostly undisturbed appearing area, effects on fishing in a once mostly undisturbed appearing area, effects on hunting in a once mostly undisturbed appearing area, effects on wildlife observation in a once mostly undisturbed appearing area.”
“13) The impacts of losing other forest vegetation (due to logging, cutting, and other associated activities) that is not affected by SPB for a period of time that is equal to the age of the oldest trees in the area cut (for example the loss of 60-80 yrs. of ecological succession if a SPB spot is logged where the trees are 60-80 yrs. old) should be discussed in the EA.”
“14) On August 11, 1987, John E. Alcock, Regional Forester, incorporated a letter into the Southern Pine Beetle Environmental Impact Statement (EIS) and Record of Decision (ROD) concerning the Sierra Club v. Lyng, Civ. No. 85-2226, United States District Court for the District of Columbia final order and memorandum, about control of SPB in wilderness and the requirements for control that adjacent landowners must follow.”
“Regional Forester Alcock stated "At argument on the motions the court voiced its concern that the Forest Service may act in wilderness to protect adjacent landowner's timber even though the landowners have not made any efforts to protect themselves. The Forest Service assured the court that no control efforts will be initiated in a Wilderness Area unless the owner of adjacent land to be protected has taken reasonable steps on the adjacent land to combat spread of the beetle and will continue such efforts. The court therefore included in its memorandum the caution that a site-specific determination of necessity for controlling wilderness SPB infestations must include a finding that the adjacent landowner is also making an effort to protect his land. Specifically, the memorandum opinion states that, “Vigorous control efforts along the borders of wilderness land will be undertaken, therefore, only when met by equally vigorous efforts on adjacent land, ensuring that the burden of beetle control will not fall disproportionately on the Wilderness Areas. Those who seek protection of their lands must demonstrate to the Forest Service a willingness to share the burden of acting in a manner that will minimize any necessary intrusions upon wilderness values.' (Memorandum at pgs. 10-11.)".”
“This letter goes on to say, "The ROD states that adjacent landowners' forest management objectives and the threat to these lands from non-wilderness SPB sources are to be considered during the site-specific analysis. (ROD: pg. 1, third paragraph; pgs. 12 & 13, number 1; pgs. 20 & 21, number 5; pg. 32, number 5) Forest management objectives normally include control and protection activities to minimize SPB losses. However, in light of the court's ruling, I feel we need to be more specific regarding these forest management objectives. Therefore, I want to emphasize that during the site-specific analysis and decision making process, SPB suppression actions taken by adjacent landowners on their land will be evaluated and documented. If the landowner is not taking vigorous control efforts to reasonably protect himself from SPB infestations occurring on his land, no action would be taken to protect him from infestations in wilderness. This letter is hereby incorporated into the SPB EIS and ROD."
“This is not the message that the Sierra Club heard at the April 17, 2012 collaborative meeting in Zavalla. The FS will have to do better, according to its commitment to the court and public than asking a landowner to check-off a box, yes or no. Because of this mandate the Forest Service must include in the EA:”
“1. The site-specific analysis and the decision-making process that will be followed regarding SPB control on private lands proposed to be protected by cutting on wilderness and that document “equally vigorous efforts on adjacent land, ensuring that the burden of beetle control will not fall disproportionately on the Wilderness Areas.”
“2. The evaluation and documentation that will be made for the adjacent landowners' SPB suppression actions.”
“3. The description and documentation that shows that adjacent landowners are making "equally vigorous efforts" to control SPB on their lands.”
“It is evident that if the landowner has not conducted SPB control and or good forestry practices on his/her land then the FS must not cut in the wilderness areas.”
“15) The EA should address what information will be provided to the public regarding any treatment measure actions. For instance, information of interest includes where spots to be controlled are located, the size of the spots, the location of adjacent private property and national forest property, the direction the spots are going, the history of the spots, and a map showing this site specific information.”
“16) The minimum tool concept must be used in wilderness.”
B. Later Battles Against SPB’s in Designated East Texas Wilderness Areas
The FS then sent out a September 13, 2012 public scoping notice for an EA for SPB in wilderness areas on the NFGT. The Sierra Club referred to its pre-scoping comments of April 26, 2012 and stated, “The Sierra Club resubmits those comments as still relevant and applicable to this proposal.” The Sierra Club stated further, in its September 13, 2012 scoping comments, that:
“The Sierra Club continues to be concerned about the way the FS deals with landowners and SPB. The public notice states “Suppression actions would be implemented to protect pine tree resources on adjacent private property … in addition, the adjacent landowner(s) must concur with the Forest Service suppression treatments in wilderness and also confirm they will or have in the past taken action on their property to suppress or prevent southern pine beetle infestations.”
The LSC quoted from the April 26, 2012 pre-scoping comments and said that what the FS proposed was insufficient for what the Regional Forester required. Finally, the LSC stated:
“The Sierra Club’s SPB decision choices for wilderness are, in order of priority:”
“1. Not implement treatment measures in wilderness.”
“2. Treat SPB areas with pheromones (verbenone and or frontalin) and do not cut a buffer of living green trees.”
“3. If cutting is done, do only cut/leave with no green tree buffer cut.”
“4. No SPB cutting in streamside zones, areas with sensitive plant or animal habitat, wetlands, seepage areas, sensitive soil areas that rut/erode easily, or bird or other monitoring sites.”
“5. Specifically protect the Lone Star Hiking Trail and 4 C’s Trail from the impacts of logging or cutting trees and associated activities.”
“6. The minimum tool concept must be used in wilderness.”
The proposal moved forward and the LSC, Texas Conservation Alliance, and Wilderness Watch had a meeting with the FS on June 10, 2013 about the EA for the “Suppression of Southern Pine Beetle Infestations in Wildernesses in the National Forests in Texas”. The LSC made several comments about this meeting:
“It was good talking with you … about the U.S. Forest Service (FS) Environmental Assessment (EA) for the Suppression of Southern Pine Beetle (SPB) infestations in Wildernesses in the National Forests in Texas.”
“I want to list some of the things that I heard yesterday during our conversation:”
“2) Private landowners must do their part with regard to SPB treatments before or simultaneously on their land before any cutting would be done in wilderness.”
“4) It would be good if the August 11, 1987 amendment to the SPB Wilderness EIS record of decision were quoted in the EA so that it is very clear what the FS should do.”
“5) The FS goal for SPB and wilderness … is to “minimize the impacts on wilderness”.”
“6) There is less suitable pine habitat (about 2,000 acres) in all wilderness areas for SPB than there was in the past.”
“9) It would be good to clearly state what criteria will be used to make the site specific analysis.”
“10) The SPB Wilderness EA is a programmatic document and there will be no categorical exclusions or decision memos based upon this document for each SPB spot found in wilderness.”
“11) The need that there be “no disproportionate burden” for wilderness to deal with in regard to SPB must be addressed.”
’13) If there are SPB infestations on private property and the landowner does nothing then the FS will be under no obligation to cut infestations in wilderness areas.”
“14) There needs to be a mechanism whereby groups or interested persons can be informed about SPB infestations in wilderness and provided with the opportunity to give their input on what should occur.”
“15) The SPB EIS is out-of-date with regard, at the very least, to treatment options and should be updated.”
“16) A decision tree or list of criteria for how decisions will be made about SPB infestations in wilderness would make the decision more clear and would be helpful.”
“17) If cutting must be done, then cutting fewer trees is better than cutting more trees. Cutting down trees in wilderness is a last resort and not a first resort.”
“18) Use of pheromones (frontalin and or verbenone) outside or inside wilderness to steer SPB away from other properties would be better than cutting trees within wilderness.”
“19) It would be good to have NFGT trained crews for cross-cut saws or alternatively regional crews ready to cut if necessary. The noise of chainsaws in wilderness does impinge on wilderness character.”
“20) Upland Island Wilderness Area, of the five NFGT wilderness areas, is the only one that has substantial pine acreage that could be infested by SPB.”
When scoping was conducted again by the FS on August 12, 2013, the LSC provided additional comments for the EA for the “Suppression of Southern Pine Beetle (SPB) Infestations in Wildernesses in the National Forests in Texas”. The August 23, 2013 LSC comments stated:
“1) The Sierra Club visited Little Lake Creek Wilderness Area (LLCWA) on August 20, 2013 and noted the conditions … Most of the forest that the Sierra Club saw was upland hardwood-pine or pine-hardwood forests. In some place there were scattered large Loblolly Pine … and in other place there were greater numbers of pine trees … There were several headwater streams for Little Lake creek that were crossed.”
“2) SPBs are the agents of natural disturbance that help shape a forest’s structure and composition. SPBs ensure that the natural ecosystem process of disturbance functions well. Therefore treatment measures that reduce or remove SPBs from wilderness are interferences with natural processes and should not be allowed inside of wilderness … human manipulation of wilderness (trammeling) should be eliminated and minimized as much as possible so wilderness can freely express itself, uncontrolled from human actions.”
“SPB killed trees in wilderness are an important part of the wilderness experience, wilderness character, and a natural process of Nature.”
“3) The Sierra Club is opposed to cut/remove (cut/log SPB infested trees and a green tree buffer that has no SPBs), cut/hand spray, … or pile/burn … These treatment methods in wilderness are far too intrusive, manipulative, controlling, and ecologically harmful.”
“14) … The FS must do better, according to its commitment to the court and public than asking a landowner to check-off a box, yes or no. because of this mandate the Forest Service must include in the EA:”
“1. The site-specific analysis and the decision-making process that will be followed regarding SPB control on private lands proposed to be protected by cutting on wilderness and that document “equally vigorous efforts on adjacent land, ensuring that the burden of beetle control will not fall disproportionately on the Wilderness Areas.”
“2. The valuation and documentation that will be made for the adjacent landowners’ SPB suppression actions.”
“3. The description and documentation that shows that adjacent landowners are making “equally vigorous efforts” to control SPB on their lands.”
“If it is evident that a landowner has not conducted SPB control and or good forestry practices on his/her land then the FS must not cut in the wilderness areas.”
“17) The EA must be site specific. The EA must mention locations where SPB outbreaks are expected. The site specific locations, the environmental damage that will occur, and the trade-offs between the alternatives must be explored and revealed.”
The process continued and on December 8, 2013 the Sierra Club provided the FS with its public comments for the draft EA for the “Suppression of Southern Pine Beetle Infestations in Wildernesses in the National Forests in Texas”.
Many of the previous LSC comments submitted on April 26, 2012, September 20, 2012, June 11, 2013, and August 23, 2013 were repeated in these new comments. The LSC made additional comments:
“2) Page 3, EA, states “Maintaining low pine basal areas, creating mixed stands, and favoring less susceptible pine species can serve to prevent the development of infestations.” The FS does not address what it will do with public forest lands to ensure that these conditions occur outside the five wilderness areas. If the FS has already managed in this way it should clearly define what the new risk (which should be less than high basal area older pines) is and what is the likelihood of SPB attack on these areas outside and adjacent to the five wilderness areas that are federal forest lands and RCW habitat.”
“3) Page 4, EA, the FS does not compare how many acres of the total acres in each wilderness area are within the ¼ mile buffer where pine trees are allowed to be cut. In a small, narrow, wilderness like Little Lake Creek Wilderness Area, a substantial percent of the entire wilderness can be cut using the ¼ mile buffer cutting area. These comparisons should be provided to the public so that it can review, comment on, and understand all potential environmental impacts that will occur due to the proposal.”
“4) Pages 15 and 16, and pages 2, 10, and 11 of the Minimum Requirements Decision Guide, the FS does not seriously address landowners’ responsibilities for managing their lands to reduce SPB risk. The requirement that the FS holds the landowner too is virtually nothing, a form and a check-off … Wilderness is a totally different category of land use … and the FS should hold landowners to the same management responsibility that it has for federal forest lands and not wilderness lands.”
“This is not the analysis and documentation that Regional Forester Alcock required the FS to take with his August 11, 1987 letter.”
“5) Page 18, EA, 1.7 Issues from Scoping, the FS ignores most of the issues that the Sierra Club presented in our three scoping letters and does not discuss or even acknowledge them in the EA. The FS has not taken the Sierra Club seriously with regard to our public input.”
“7) Pages 20, 31, 33, 35, EA, and pages 2, 4, 6, 10, 11, and 12 of the Minimum Requirements Decision Guide, the FS uses phrases that it does not define. These phrases must be defined so that the public can review, comment on, and understand all the potential environmental impacts of the proposal.”
“1. unacceptable damage
2. level of damage predicted
3. catastrophic damage
4. slightly detectable
5. overbearing results
6. clearly detectable
7. appreciable effects
8. highly noticeable
9. substantial effects
10. temporary in duration
11. small part of a natural process
12. small percentage of the total wilderness acres
13. no significant signs of human development
14. un-natural dense vegetation growth
15. catastrophic to private lands
16. immediate threat
17. unnatural loss of the wilderness resource
18. threat cannot reasonably be abated
19. tremendous losses of timber”
“9) Page 21, EA, the Sierra Club appreciates that the FS limits the cutting of trees near the LSHT and the 4 C’s trail.”
“10) Pages 25, EA, Alternative 2 – Cut and Leave using Hand Tools only, page 34, Affected Environment, Wilderness Character, the FS states, “Saw crews would use existing roads within the wilderness areas to access the pots” and “The presence of these roads”. There are no roads within the five wilderness areas. There is only wilderness in wilderness. There were areas in these five wilderness areas that used to be roads before wilderness was declared. To state 29 years after the U.S. Congress decided that these five areas were wilderness that parts of these five wildernesses are not wilderness and are still roads is just plain wrong. This kind of thinking is self-serving and allows the FS to justify using these areas and damaging them when conducting cut/leave activities.”
“12) Page 25, EA, Alternative 3 – Cut and Leave using Hand Tools and/or Chainsaws, the FS states “The use of chainsaws should not add any additional effects to water resources.” This is not true. Chainsaws use gasoline and oil. There could be a spill of gasoline or oil in the five wilderness areas due to the use of a chainsaw to cut down trees. This same risk does not exist for manual cross-cut saws. In addition, carrying chainsaws in wilderness areas could result in additional soil erosion if equipment is not handled carefully.”
“16) Page 35, EA, Wilderness Character, Alternative 3 and page 47, Alternative 3, the FS fails to mention the noise that chainsaws make which will affect wilderness character by degrading or destroying quiet, solitude, and natural sounds. In addition, the noise disturbs animals. Noise also alters or interferes with the way that animals use natural sounds. The ability of animals to use natural sounds will thus be degraded or destroyed and wilderness character will be negatively affected.”
“17) Page 37, EA, 3.5 Vegetation, Alternative 1 – No Action, the FS states “More habitat could be lost leading to greater forest fragmentation.” This is a false statement. The loss of large pine trees due to SPB does not destroy the forest (all the shrubs, seedlings, saplings, fungi grass, herbaceous plants, and hardwood trees are left) but makes it more diverse. It also does not fragment the forest but creates a patchy matrix, due to the SPB ecological process (pine mortality agent). The assumption that a SPB infestation causes fragmentation is untrue. The dead trees are ecological legacies and still are part of the forest, a unique type of forest called an early successional forest that does not create an environment that other animals cannot travel through (no fragmentation).”
“18) Page 27, EA, 3.5 Vegetation, Alternative 2, cutting SPB spots with chainsaws so that the job can be finished quicker is not supposed to occur in wilderness or wilderness character will be violated to control insects. The FS should remove this statement.”
“21) Page 47, Alternative 3, the FS mentions removal of trees via helicopter … The Sierra Club is opposed to helicopter removal of trees in wilderness since this action degrades and destroys wilderness character, negatively impacts quiet, natural sounds, and solitude, and can result in damage to living and dead trees that are standing.”
“25) Page 71, Yellow-breasted Chat, Alternative 3, the Sierra Club opposes Alternative 3 because it includes “cut and remove” methods which will destroy wilderness character and natural ecological processes in wilderness by removal of snags and downed wood.”
“29) Pages 12, 14, 15, 16, 18, 19, 20, 22, 30 and 31 of the Minimum Requirements Decision Guide, the FS talks about the possibility that it will not have a crew(s) trained and available that is able to handle cross-cut saws or chainsaws. This is malarkey! It is the FS’s responsibility to ensure that it has one or more crews available that can use the cross-cut saw or chainsaws. This skill is needed for wilderness management and the FS must provide for its availability. It is the FS’s responsibility to ensure that there are enough crews to be able to mobilize and use cross-cut saws in wilderness. In addition, this skill can be used for other events where trees fall or endanger roads, campsites, or other sensitive areas where human safety is at risk. This is one way that training for use of such primitive equipment can be done. Wind events occur in the National Forests of Texas not infrequently that allow cross-cut saw crews to train and burnish their skills. This is part of the FS’s job and the FS cannot get out of this by saying that it may not be able to supply these crews.”
May 21, 2014, the FS attempted to organize a meeting with the LSC and others before the objection period began. The LSC was unable to attend this meeting because its representative was scheduled to take vacation on the dates suggested by the FS.
On June 10, 2014, a meeting was held before the objection period with the LSC, TCA, Wilderness Watch, and the FS about the EA for “Suppression of Southern Pine Beetle Infestations in Wildernesses in the National Forests in Texas”.
The FS agreed to make some changes about what would be required for documentation for private landowners and their SPB control which would allow SPB control in wilderness. The FS stated it would add a wilderness resource advisor to “balance wilderness versus RCW/private landowner needs”.
The FS stated that its goal was to “minimize impact on wilderness while meeting Endangered Species Act (ESA) and private landowner’s needs.” The FS said it would clearly state criteria used to make site-specific analysis for SPB control in a wilderness area.
The EA is a programmatic document so that SPB control can be implemented immediately based upon what the EA and decision-notice has determined and decided. A biologist, archeologist, entomologist, and wilderness resource advisor will be involved in decisions about SPB control in wilderness.
The disproportionate burden on wilderness must not occur and if there are infestations on private property and nothing is done then nothing will be done in wilderness.
The LSC stated that the SPB EIS was out-of-date and there was a need to use pheromones in wilderness. The FS said that a decision tree or list of criteria used to make the decision about SPB control must be clearly provided and used.
The LSC stated that it and others should be contacted when the FS weighs whether to conduct SPB control in wilderness. Cutting less is better than cutting more. Cutting down trees in wilderness is a last resort and not a first resort.
The EA and draft Decision Notice and Finding of No Significant Impact for “Suppression of Southern Pine Beetle Infestations in Wildernesses in the National Forests in Texas” was released on June 23, 2014.
The LSC, on June 26, 2014, sent an email to Mark Van Every, FS, Forest Supervisor, NFGT, about the EA and requested a change in the question that is asked of landowners about SPB control on their private property when SPB control was being considered in wilderness.
During this time, the LSC was not aware that the FS was preparing a “Minimum Requirements Decision Guide” for “Suppression of Southern Pine Beetle Infestations in Wildernesses in the National Forests in Texas”.
As early as May 2, 2014, on the signature page, FS officials signed this document. Three days before the June 10, 2014 meeting that the FS had with the Sierra Club, the Forest Supervisor signed this document and on June 17, 2014 the Regional Forester signed the document.
The “Minimum Requirements Decision Guide” helps the FS determine how to conduct management in a wilderness using the minimum tool. As stated in this document:
“The minimum tool is the method, equipment, device, force, regulation, practice, or use with the least impact that will meet management objectives in a wilderness context. The minimum requirement and minimum tool analysis assists the decision maker in determining the minimum requirement and minimum tool for the project. Tool use in wilderness is an administrative decision.”
Many years later, in 2021, the LSC found a final, complete, copy of this document on the internet and was surprised that the LSC had never been notified that the document was finished and hadn’t been sent a copy.
These actions by the FS feed the suspicion of the LSC that the FS isn’t serious about collaboration to ensure that wilderness, wilderness character, and wild wilderness (the lack of or lowest level of trammeling) is protected.
The FS finally completed the EA/FONSI/DN for the National Forests in Texas (NFT) “Suppression of the Southern Pine Beetle (SPB) Infestations in Wilderness” on August 31, 2015. Alternative 3 was chosen for implementation.
The EA/FONSI/DN has mitigation measures for the protection of biological diversity, ecosystem management, soil protection, water quality, snags, downed wood, and other important natural resource elements. Some of the mitigation measures required include:
“Action to Be Implemented in Wilderness”
“1. Alternative 3 requires cut and leave SPB infested trees and a buffer to suppress SPB infestations in wilderness within ¼ mile from adjacent private lands or Red-cockaded Woodpecker (RCW) clusters with limited foraging habitat.”
“2. Cut and leave treatments will be completed using hand tools and or chainsaws and based upon site-specific evaluation of each infestation by the Forest Entomologist.”
“3. Smaller, slow-moving infestations will be treated using hand tools when the infestation is determined that it can be successfully suppressed before it impacts adjacent private land or RCW clusters.”
“4. Larger and or swiftly expanding spots will be treated with cut and leave using chainsaws.”
“5. Before suppression methods for SPB in wilderness are used to protect adjacent private property, landowners must consent to the treatment and commit to suppress SPB on their land.”
“6. Landowner willingness to suppress SPB infestations on their land is obtained by contact before suppression action and being asked:”
“a. Do you want the FS to take action in wilderness which may prevent SPB infestations from impacting your land?”
“b. Are you willing to take suppression action on your land in the event of a SPB infestation and or have you suppressed infestations in the past?”
“7. Responses from adjacent landowners will be kept on file.”
“8. Before outbreaks occur a plan will be developed jointly by the FS and the Texas Forest Service (TFS) to assess the land management objectives of adjacent landowners and inform them of methods to reduce SPB hazard on their lands.”
“9. The NFT will work with TFS (Texas Forest Service) to determine if adjacent private landowners conduct activities to reduce susceptibility to SPB and or suppress SPB infestations. The FS DN goes on to say:”
“The Record of Decision (ROD) for the April 6, 1987, FS, Suppression of the Southern Pine Beetle (SPB) plan was amended by Regional Forester John Alcock on August 11, 1987, and states, “If a landowner is not taking “vigorous control efforts” to reasonably protect himself from SPB infestation occurring on his land, no action would be taken to protect from infestations in wilderness.” To meet the conditions established in the ROD and the Alcock letter for suppression of SPB infestations in wilderness to protect tree resources on adjacent private land, the following applies:”
“1. Adjacent landowners will be provided with information about prevention and suppression of SPB infestations on their property. The FS will work in conjunction with the TFS to educate adjacent landowners on SPB prevention and suppression.”
“2. Adjacent landowners will be informed when expanding infestations in wilderness threaten their pines. The number and value of pines at risk would be assessed based on discussions with landowners and a site-specific evaluation. No action would be taken in wilderness to protect adjacent landowner’s pines unless he/she is taking action on his/her land prior to or simultaneous to FS taking action. If the landowner decides to recoup his/her losses by removal of all pines on his/her land before it is impacted by SPB, no action would be taken in wilderness.”
“3. If there is historical evidence that a landowner has not taken action, then the FS would not suppress infestations within wilderness adjacent to private lands.”
“4. A site-specific evaluation will be conducted for any SPB infestation within ¼ mile of adjacent private land with susceptible host type. The evaluation will predict the likelihood of the infestation impacting pines on adjacent private land in the absence of suppression and analyze the expected damage. A spot growth model will be used to predict continued infestation growth when applicable. Some infestations are too large for existing spot growth models; in this instance the current rate of spot growth will be used to predict impacts.”
“5. The site-specific evaluation will also determine if suppression actions have a realistic expectation of protection of pines on adjacent private lands.”
“6. Only pines already infested or expected to be infected and killed by SPB will be included in suppression treatments.”
“To meet the conditions established in the ROD for suppression of SPB infestations in wilderness to protect tree resources for adjacent RCW clusters, the following applies:”
“1. A site-specific evaluation will be conducted for any SPB infestation within ¼ mile of adjacent RCW clusters. The evaluation will predict the likelihood of the infestation impacting pines on adjacent RCW clusters in the absence of suppression and analyze the expected damage. A spot growth model will be used to predict continued infestation growth when applicable. Some infestations are too large for existing spot growth models; in this instance the current rate of spot growth will be used to predict impacts.”
“2. The site-specific evaluation will also determine if suppression actions have a realistic expectation of protection of pines on adjacent RCW clusters.”
“3. Only pines already infested or expected to be infected and killed by SPB will be included in suppression treatments.”
“4. To Protect RCW habitat considered as high value Federal land, the wilderness infestation must be within ¼ mile of the wilderness boundary and the rate of spot growth must indicated that adjacent essential clusters and their limited foraging habitat will be affected within the next 30 days.”
“General Design Criteria Applicable to Alternative 3”
“The SPB treatments will be implemented in accordance with standards and guidelines from the Revised Land and Resource Management Plan (The Plan) and all applicable laws and regulations.”
“1. No pines within 50 feet of waterways will be felled unless necessary for the success of the treatment. No trees will be felled across streams or other waterways.”
“2. The minimal suppression tool that can effectively accomplish the required suppression will be selected.”
“3. No hardwoods will be felled except when necessary for the protection of workers.”
“4. Important wildlife trees, large trees, snags, and den trees will be protected during cutting.”
“5. As prescribed in cut and leave procedures, all treated trees will be directionally felled towards the center of the infestation when able to do so safely, minimizing damage to any pines and hardwoods not included in the treatment.”
“6. Any trees falling into MA-4 protected wetlands (baygalls/bogs/sloughs) will be removed manually by a chainsaw or hand tools at the direction of the Forest Botanist. Trees will be lopped and scattered outside the baygall/bog boundaries.”
“7. Any trees fallen onto sensitive plant locations within wilderness (Kentucky Ladies’ Slipper and Hibiscus dasycalyx sites) will be removed manually by hand tools or chainsaws at the direction of the Forest Botanist. Trees will be lopped and scattered outside the site boundaries.”
“8. Every area designated for treatment will be surveyed for threatened, endangered, and sensitive (TES) plants and, if found, the area delineated. Only chainsaw/hand tool crews will be allowed within the boundaries of the delineated area and every effort will be made to avoid felling trees within the delineated area.”
“9. When SPB infestations meeting suppression criteria occur near established hiking trails, suppression treatments will be designed to protect trees near the trails. Limit tree felling within 100 feet of the trails except when necessary to ensure successful infestation suppression.”
“10. Any access into treatment areas will be obscured post treatment by removal of any flagging that may have been used to locate the SPB infestation.”
“Monitoring”
“1. Pre-treatment”
“a. The Forest Entomologist will:”
“i. Determine if the infestation will impact pines on adjacent private or high value federal land.”
“ii. Work with the TFS to determine if adjacent private landowners are conducting activities to reduce susceptibility to SPB and or suppressing any SPB infestations and determine if a SPB infestation would cause unacceptable damage to their lands.”
“iii. Determine if hand tools alone would adequately suppress SPB infestations in wilderness or if chainsaws are needed.”
“iv. Assess if the suppression treatment has a reasonable chance of successfully protecting the adjacent lands and RCW clusters.”
“v. Delineate the treatment area including the buffer.”
“vi. Provide input to the Forest Supervisor for the decision making process.”
“b. The Wilderness Resource Advisor will:”
“i. Evaluate the potential effect of the proposed treatment on the wilderness resource.”
“ii. Provide input to the Forest Supervisor for the decision making process to ensure that the wilderness resource is considered with the needs of private landowners and the RCW.”
“c. The District Wildlife Biologist will:”
“i. Determine if there are any changes to the threatened and endangered and or the Regional Forester’s (Region 8) sensitive species list for the NFT.”
“ii. Determine if additional surveys for listed species or species proposed for listing are needed.”
“iii. Determine if new information about any species on the threatened and endangered species list for the NFT comes to light that may change the determination of effect made in the Biological Evaluation completed for this project.”
“iv. Determine if completion of a new or Supplemental Biological Evaluation and subsequent review by the Forest Supervisor are warranted.”
“d. The GIS Specialist will:”
“i. Assist with mapping needs.”
“e. The Botanist will:”
“i. Coordinate surveys for TES plants.”
“f. The Landscape Architect and or Recreation Manager will:
i. Coordinate treatment of any SPB infestation adjacent to the Lone Star Hiking Trail (Little Lake Creek Wilderness and the 4-C’s Trail (Big Slough Wilderness).”
“g. The Forest Archeologist will:”
“i. Research areas considered for SPB treatment in order to make a determination of the potential effects of the tree felling method on any remnants of home sites or cemeteries in the project area(s).”
“2. Implementation Monitoring”
“a. The Forest Entomologist will:”
“i. Monitor SPB infestations at least weekly to check for breakouts. Adjust treatment boundaries if necessary.””
“b. The Wilderness Resource Advisor will:”
“i. Monitor treatments at least weekly to ensure they are consistent with wilderness resource values.”
“c. The District Wildlife Biologist will:”
“i. Monitor RCW clusters at least weekly to determine if they are being disturbed by the treatments.”
“d. The Contract Administrator will:”
“i. Monitor treatment areas at least weekly to ensure that treatments meet contract specifications and treatments are not damaging resources.”
“e. The District or Forest Archaeologist will:”
“i. Ensure that the following measures are implemented on historical properties for unevaluated, eligible for listing or listed on the National Register of Historic Places (NRHP):”
“a. Measure HP1: Site Avoidance During Project Implementation”
“1. Avoidance of historic properties will require the protection from effects resulting from the undertaking. Effects will be avoided by establishing clearly define site boundaries and buffers around archeological sites where activities that might result in an adverse effect.”
“2. Buffers will be of sufficient size to ensure that integrity of the characteristics and value which contribute to, or potentially contribute to, the properties’ significance will not be affected.”
“b. Measure HP3: Other Protection Measures”
“1. If it is not feasible to avoid a historic property that may be harmed by a project activity (HP1) then the following steps will be taken:”
“a. In consultation with the Texas SHPO (State Historic Preservation Office) and Tribes, the site(s) will be evaluated against NRHP significance criteria (36 CFR 60.4) to determine eligibility for the NRMP. The evaluation may require subsurface site testing.”
“b. In consultation with the Texas SHPO, Tribes, and other consulting parties, if required, site specific mitigation measures will be developed to minimize the adverse effects on the site, so that a finding of No Adverse Effect results.”
“c. The agreed upon mitigation measures will be implemented prior to initiation of activities having the potential to affect the site.”
“c. Measure HP4: Discovery of Cultural Resources During Project Implementation:”
“1. Although cultural resources surveys were designed to locate all NRHP eligible archeological sites and components, these may go undetected for a variety of reasons. Should unrecorded cultural resources be discovered, all activities in the vicinity (minimum of 50 meters from the discovery) shall cease, and reasonable efforts shall be taken to avoid or minimize harm to the cultural resource; the resource will be evaluated by an archaeologist, and consultation will be initiated with the SHPO and Tribes to determine appropriate actions for protecting the resource and mitigating adverse effects.”
“2. Project activities at that locale will not resume until the resource is adequately protected and until agreed upon mitigation measures are implemented with SHPO approval.”
“3. The National Forests and Grasslands in Texas (NFGT) will adhere to the specific and comprehensive protocols for Unanticipated Discoveries articulated in Section VI of the Programmatic Agreement among the NFGT, Texas SHPO, and Tribes.”
“f. The Botanist will:”
“i. Monitor treatments near TES plant sties to ensure no impacts have occurred.”
“g. The Landscape Architect and or Recreation Manager will:”
“i. Monitor treatments adjacent to the Lone Star Hiking Trail and the 4-C’s Trail to ensure no impacts have occurred.”
“3. Effectiveness Monitoring”
“a. The Forest Entomologist will:”
“i. Monitor all treated infestations at least weekly for two weeks post treatment to check for breakouts. All breakouts will be evaluated to test if they meet treatment criteria for suppression of SPB in wilderness, and if so, will be treated as soon as possible. As per The Plan, all active SPB infestations within 1/3 mile of adjacent private land or RCW clusters will be monitored weekly between May and October, and at least monthly from November through April.”
“b. The Wilderness Resource Advisor will:”
“i. Monitor all treated infestations at least weekly to ensure that they remain consistent with wilderness resource values.”
“c. The District Wildlife Biologist will:”
i. Monitor RCW clusters threatened by a SPB infestation near the wilderness boundary. As per The Plan, all active SPB infestations within 1/3 mile of RCW clusters will be monitored weekly between May and October, and at least monthly from November through April.”
The LSC comments about Landowner Requirements for SPB Wilderness Actions were:
“This information is separate from what the FS says in the DN about SPB wilderness actions. The following is from the April 26, 2012 comments of the Houston Regional Group and Lone Star Chapter of the Sierra Club (Sierra Club) for U.S. Forest Service (FS) pre-scoping for the Environmental Assessment (EA) for southern pine beetle (SPB) in wilderness areas on the National Forests and Grasslands in Texas (NFGT). These wilderness areas include Little Lake Creek (Sam Houston National Forest); Big Slough (Davy Crockett National Forest); Upland Island and Turkey Hill (Angelina National Forest); and Indian Mounds (Sabine National Forest). These Sierra Club comments state:”
“On August 11, 1987, John E. Alcock, Regional Forester, incorporated a letter into the Southern Pine Beetle Environmental Impact Statement (EIS) and Record of Decision (ROD) concerning the Sierra Club v. Lyng, Civ. No. 85-2226, United States District Court for the District of Columbia final order and memorandum, about control of SPB in wilderness and the requirements for control that adjacent landowners must follow.”
“Regional Forester Alcock stated, "At argument on the motions the court voiced its concern that the Forest Service may act in wilderness to protect adjacent landowner's timber even though the landowners have not made any efforts to protect themselves. The Forest Service assured the court that no control efforts will be initiated in a Wilderness Area unless the owner of adjacent land to be protected has taken reasonable steps on the adjacent land to combat spread of the beetle and will continue such efforts. The court therefore included in its memorandum the caution that a site-specific determination of necessity for controlling wilderness SPB infestations must include a finding that the adjacent landowner is also making an effort to protect his land. Specifically, the memorandum opinion states that, “Vigorous control efforts along the borders of wilderness land will be undertaken, therefore, only when met by equally vigorous efforts on adjacent land, ensuring that the burden of beetle control will not fall disproportionately on the Wilderness Areas. Those who seek protection of their lands must demonstrate to the Forest Service a willingness to share the burden of acting in a manner that will minimize any necessary intrusions upon wilderness values.' (Memorandum at pgs. 10-11.).”
“This letter goes on to say, "The ROD states that adjacent landowners' forest management objectives and the threat to these lands from non-wilderness SPB sources are to be considered during the site-specific analysis. (ROD: pg. 1, third paragraph; pgs. 12 & 13, number 1; pgs. 20 & 21, number 5; pg. 32, number 5) Forest management objectives normally include control and protection activities to minimize SPB losses. However, in light of the court's ruling, I feel we need to be more specific regarding these forest management objectives. Therefore, I want to emphasize that during the site-specific analysis and decision making process, SPB suppression actions taken by adjacent landowners on their land will be evaluated and documented. If the landowner is not taking vigorous control efforts to reasonably protect himself from SPB infestations occurring on his land, no action would be taken to protect him from infestations in wilderness. This letter is hereby incorporated into the SPB EIS and ROD."
For the LSC, the above mitigation measures for SPB control for private lands and wilderness aren’t sufficient to meet the requirements that the Regional Forester set in 1987. In the future, this will continue to be a source of conflict between the LSC and FS.
The LSC asked about the “Minimum Requirements Decision Guide for Control of Southern Pine Beetle Infestations in Wildernesses on the National Forests and Grasslands in Texas”, in an email to the FS on August 31, 2021. In that email the LSC stated:
“I recently found on the web the "Minimum Requirements Decision Guide" (MRDG) for the "Control of Southern Pine Beetle Infestations in Wildernesses on the National Forests and Grasslands in Texas". I do not believe I have ever seen this document (May/June 2014).”
“I noted several documents that the MRDG referred to that I would like to get a copy of and have several comments or questions I want to make.”
“1) The first document is in a statement repeated throughout the MRDG but that I refer to on Page 2 which states, "Prior to outbreaks occurring, a plan will be developed jointly between USFS and Texas Forest Service (TFS) to assess the land management objectives of adjacent landowners and inform them of methods to reduce SPB hazard on their lands."
“I would like a copy of this document for the Sierra Club.”
“2) The second document is mentioned on Page 15 and states, "This project falls within the Exempted Activities Categories of the Programmatic Agreement process for the National Register of Historic Places (NRHP) 106 compliance (Programmatic Agreement regarding Undertaking on the National Forests and Grasslands in Texas dated 1/7/2013)."
“I would like a copy of this document for the Sierra Club.”
“3) Throughout the document (see page 2, for instance) it's stated that the FS asks adjacent landowners where SPB may escape onto their land from wilderness whether they want the FS to take action in wilderness to prevent SPB and are they willing to take suppression action on their land if SPB is in wilderness. It says the responses from adjacent landowners are kept on file.”
“If a landowner says yes, they will take control action on their land, but then does not do so does the FS check this in the future (check past responses that are kept on file) and take this into account before cutting trees in wilderness?”
“Can a landowner avoid cutting on his/her land by telling the FS yes he/she will control but then not take that responsibility to cut trees on his/her own land?”
“Is a record kept of whether a landowner controls (past actions) on his/her property as told to the FS and required for the FS to control in wilderness?”
“4) The FS did not use pheromones as an alternative in wilderness even though it has much less impacts in wilderness than cut and leave. My understanding of pheromones is that they have worked on SPB. The SPB EIS did not consider pheromones. I have heard that pheromones have been used on an emergency basis or as a research project.”
“The Sierra Club would like the FS to consider pheromones as an alternative in wilderness to treat SPB spots.”
“5) Page 22, when looking at the mechanized equipment cut and leave alternative, several environmental impacts are mentioned. One that is not mentioned is the damage that mechanized equipment has on other vegetation, like trees, shrubs, vines, etc. as it get to, is positioned, and cuts SPB pine trees.”
“Damage done by mechanized equipment to other vegetation when cutting SPB in wilderness is a significant environmental impact and should be recognized in the MRDG.”
“Thanks for listening and I look forward to receiving the documents requested in this email and a response to the Sierra Club's questions and concerns.”
The battle to save wilderness, wilderness character, and wild (untrammeled) wilderness from SPB control continues to this day.
VII. Sierra Club and Other East Texas Wilderness Areas Management
I don’t have all the information that I used to have to document wilderness management issues that ETWA have been faced with in the past almost 40 years. However, I do have memories and will use those in this section of this history along with documents.
The wilderness management issue in ETWA was brought to the attention of the highest level of the FS on November 1, 2004, when the HSC sent a letter to the Director, Wilderness and Wild and Scenic Rivers, Chief’s Office, FS. The HSC had talked with the Director during the 40th Anniversary National Wilderness Conference, October 2004, in Lake George, New York.
Seven wilderness problems were mentioned to the FS including an illegal trail in LLCWA; use of all-terrain vehicles in LLCWA to find lost hikers; illegal horse use on the Lone Star Hiking Trail (LSHT) in LLCWA; use of motorized equipment in wilderness during Columbia Space Shuttle search; SPB logging in wilderness; use of prescribed fire in wilderness; and oil/gas activities in wilderness.
Another document from the LSC, updated on July 1, 2022, referred to the following management problems in ETWA:
“1) Mineral rights have not been acquired for all five East Texas Wilderness Areas (ETWA). Upland Island Wilderness Area (UIWA) has gravel mineral rights outstanding and along with some other ETWA, has oil/gas mineral rights outstanding.”
“2) The U.S. Forest Service (FS) built a road into UIWA to plug an abandoned well that was in Graham Creek. The FS built a road into UIWA to plug an abandoned leaking oil well. It’s possible more of these activities will occur in the future in ETWA.”
“3) There is illegal horse use on the Lone Star Hiking Trail (LSHT) in Little Lake Creek Wilderness Area (LLCWA).”
“4) FS law enforcement personnel routinely use all-terrain vehicles (ATVs) to conduct search missions for lost people in LLCWA.”
“5) The FS can cut trees in ETWA within ¼ mile from boundaries to try to stop Southern Pine Beetle (SPB) infestations from leaving wilderness and going onto private or other forest lands.”
“6) The FS has introduced prescribed fire into UIWA to reduce fuels and fire risk. In some ETWA or some parts of ETWA ecosystems, fire rarely occurred. An unnatural fire regime may be the result of prescribed burning in these areas. The FS has not conducted the research to determine by historical, local, and site-specific information what the natural fire frequency is for ETWA.”
“7) Illegal trespass by off-road vehicles (ORVs/bicycles) occurs in the ETWA.”
“8) There are dumped materials in some of the ETWA that predate wilderness designation (1984) or have been dumped since that time. There are few attempts to remove this material.”
“9) Feral hogs roam the ETWA, surrounding national forest lands, and private lands. These exotic species dig up sensitive plant species and bog areas, cause soil erosion and water pollution, and compete with native wildlife for food, shelter, and space.”
“10) Chinese Tallows, Japanese Climbing Ferns, Chinaberries, and other non-native invasive plant species (NNIPS) are found in some parts of ETWA. These plants should be controlled before they take over vegetative communities.”
“11) There are littering and poor camping etiquette problems in ETWA.”
“12) ETWA are small, and during hunting season it’s not safe to hike or camp in them. Texas Parks and Wildlife Department encourages visitors to wear orange vests/hats during hunting season. No camping is allowed in ETWA during hunting season which is the best time to hike/backpack/tent camp.”
“13) The FS conducts few regular surveys, inventories, or monitoring in ETWA. Uses and resources of ETWA are poorly known.”
“14) Incompatible uses like roads, utilities, homesteads, gravel mining, farming, and ranching occur at the boundary of ETWA. You can see, smell, and hear these uses within ETWA.”
“15) The FS provides little education to inform the public about wilderness. Because of this, the public doesn’t know what can and can’t be done and why wilderness is important.”
“16) There are no ETWA wilderness rangers so there is no one that routinely visits and hikes in ETWA to assess conditions.”
“17) Little research is conducted in ETWA so human caused changes or important forest ecology questions are not documented or determined.”
“18) The FS has little recreation or other use data for ETWA so the magnitude and type of uses are not well known.”
“19) 3-D oil/gas seismic surveys have been conducted in the Turkey Hill Wilderness Area.”
“20) There is a wooden boardwalk and bench on the Three C’s Trail which goes through Big Slough Wilderness Area.”
The list of potential wilderness management problems is long and complex. Let’s discuss some of these issues further.
A. Sierra Club, East Texas Wilderness Areas, and Oil/Gas Exploitation
Oil/gas exploitation and its aftermath have played a role in wilderness management. For instance, on December 17, 1990, 6 years after the five ETWA were designated by the U.S. Congress, a FS public notice announced that there was a proposal for seismic exploration in the IMWA and non-wilderness Sabine National Forest (SNF).
This unfortunate event was caused because the U.S. Government didn’t buy all mineral rights under SNF, and thus IMWA, in the 1930’s. As stated in a scoping letter from a member of the public, “Wilderness is no place for mineral activities of any kind. These are two inherently incompatible uses that are in direct conflict.”
Another example of oil/gas effects on wilderness is when, in UIWA, in ANF, in 1995 and again in about 2001, the FS allowed drilling rigs to plug wells that were leaking saltwater tainted with oil. In doing so a road was constructed in the wilderness area and considerable damage was done to vegetation and soil.
The FS thought at that time that a board road, which was used, was a “state-of-the-art” mitigation measure. The LSC view was that board roads had been used to access drilling sites for decades and you couldn’t call this “state-of-the-art” technology. It wasn’t a pretty way to deal with wilderness and the LSC wanted a smaller rig or pumping units to reduce environmental impacts in UIWA. Sadly, this didn’t occur.
At about the same time, the LSC was told by the FS, District Ranger, ANF, that an oil/gas company wanted approval to drill a new well for oil/gas inside of UIWA. Fortunately, this proposal never went forward, and wilderness has been spared, at least for the time being, this insult of massive trammeling.
The Turkey Hill Wilderness Area also had a 3-D seismic exploration conducted within it in 1997. To this day oil/gas exploitation threaten the ETWA.
B. Sierra Club and Annual Wilderness Pow Wows
The Sierra Club and others participated in “Annual Texas Wilderness Pow Wows”. These events were geared toward the fight to have wilderness designated by the U.S. Congress, protected after its designation, and for the protection of the NFGT from over logging and development.
In 1998, the “Annual Texas Wilderness Pow Wow” was held in SHNF on April 3rd through the 5th. This was the first time in the 19-year history of these “Pow Wows” that SHNF would be the site of the Pow Wow”. A long planning period took place starting from late Spring and August 1997 to just before the Pow Wow” was held.
HSC volunteers helped arrange the outings that would be conducted during this “Annual Wilderness Pow Wow” via input to the primary sponsor, the Texas Committee on Natural Resources (TCONR, now called TCA), about where they should occur. The HSC recommended that Wilderness Watch should be invited as a participant and co-sponsor.
“Pow Wows” were celebrations of national forests and wilderness areas in East Texas. Activities included camping, guided hikes, musical entertainment, evening campfires and sing-alongs, inspirational speakers, a Saturday afternoon program about national forest and wilderness issues, comradeship, laughter, and fun.
The schedule of hikes for two days included:
1. Birding Tour
2. Little Lake Creek Wilderness Area
3. West Sandy Creek
4. West Side of Caney Creek
5. East Side of Candy Creek
6. Children’s Walk in Huntsville State Park
7. Little Lake Creek Wilderness Area
8. Little Lake Creek Wilderness Areas, Southern Pine Beetle Walk
9. Civil War Woods
10. East Sandy Creek
11. Birding at Huntsville State Park
12. Stubblefield Nature Trail
13. Chinquapin Creek
14. Little Lake Creek Wilderness Area
15. Blackland Prairie
16. Cathedral Oaks
Before the “Pow Wow” the HSC held a potluck reception for George Nickas, Policy Coordinator, Wilderness Watch in Houston, Texas. Mr. Nickas was also invited to be a speaker at the HSC general meeting on April 2, 1998.
During George’s visit the HSC took him to see the five ETWA. On April 11, 1998, the HSC sent a letter to Ronnie Raum, FS, Forest Supervisor, NFGT, to provide observations about what was seen in the wilderness areas. These observations included:
1. BSWA, benches in wilderness, orange marking for neotropical bird monitoring stations, the presence of fireflies, the lack of a sign-in box to record visitation;
2. UIWA, a Texas Department of Transportation rail corridor study, the desire for acquisition of an inholding near this wilderness area, the scenic beauty of Longleaf Pines, no sign-in box to record visitation;
3. IMWA, old FS roads are regenerating back into wilderness, interesting plants seen (Beech Drops, Green Dragons, Yellow Dogtooth Violets, and Southern Cranefly Orchids), the area is recovering from southern pine beetles, White Oak seedling regeneration on a road bed, the sign-in box had a wasp nest which was removed, there were no sign-in papers for the box, dumped mattresses, box springs, and bedframe just behind the trailhead sign.
4. THWA, saw large American Beech, recovery of areas from southern pine beetles, seepage areas, marking ribbon in the wilderness with reason unknown but concerned about seismic survey work and request for information about this marking ribbon.
The HSC ended the letter by saying that a letter was sent to the District Ranger of SHNF about observations made while visiting LLCWA. The letter said that observations made and transmitted in the letter were part of a Wilderness Watch Adopt-a-Wilderness Program which keeps the FS informed about what occurs in ETWA.
C. Sierra Club and Wilderness Non-Conforming Uses
One of the most significant problems encountered in wilderness management is non-conforming uses created by wilderness legislation or are implemented by federal land management agencies which degrade or destroy the very essence of wilderness which is wild land that is uncontrolled (untrammeled) by humans.
September 10, 2006, a “Draft Sierra Club Guidance on Wilderness Legislation, Public Lands, and Non-Conforming Uses”, was prepared by the LSC and HSC and submitted to NSC for consideration. This draft guidance was never approved by NSC.
The LSC and HSC also submitted comments on December 26, 2006 to NSC about its “Sierra Club Wildlands Committee Wilderness Advisory for Use in Developing and Implementing Wilderness Campaigns”.
D. Sierra Club, East Texas Wilderness Areas, and Water Resources
As NSC changed its focus to give priority to climate change, other problems cropped up for wilderness management. In a December 7, 2009 article, published by Houston Tomorrow, the HSC raised concern about a dam proposed by Montgomery County that would flood bottomland, slope and upland forests in SHNF, all of LLCWA, many miles of the LSHT, and thousands of acres of federally endangered RCW habitat.
The dam was proposed as an alternative water supply by the County Judge at a closed-door water meeting in late September between elected officials and leaders so that they could meet the Lone Star Groundwater Conservation District mandate to reduce groundwater consumption by 30% by 2015.
The San Jacinto River Authority said that it was willing to pursue every option to reduce groundwater consumption but would be difficult in the middle of a national forest. “The permitting could take 20 to 30 years.”
This proposal was brought to the Region H Water Planning Group by the Montgomery County Judge. The Region H Water Planning Group creates a state-sponsored regional water plan. The HSC sent a letter to the Chair of the Region H Water Planning Group in opposition to this dam proposal on December 2, 2009.
A fact sheet against the proposal was prepared and released to the public, Sierra Club members, and allies. A letter was sent to the Montgomery County Judge on January 14, 2010, stating the HSC opposition to this proposal. The proposal was not approved by the Region H Water Planning Group and didn’t move forward.
E. Sierra Club, Indian Mounds Wilderness Area, and Strip Lands on Toledo Bend Reservoir
Another case where water resources affect wilderness occurred from 2011 to 2014. The Sabine River Authorities, from the States of Texas and Louisiana, in July 2011 proposed a land exchange between the FS, NFGT, and themselves to get possession of 3,650 acres of federally owned land in Shelby, Sabine, and Newton Counties along and under the shoreline of Toledo Bend Reservoir, the largest reservoir in the State of Texas and Louisiana.
The FS, NFGT, sent the LSC an email on July 25, 2011 which stated:
“The NFGT has been contacted by Sabine River Authority wishing to do a land exchange for the Strip lands. Can you give me a call and let’s discuss. We have no intention of doing the land exchange without it being in the public’s best interest and without the public’s support”.
On September 2, 2011 the LSC sent an email to the FS which stated:
“As we discussed today, I request a copy of the letter that the Sabine River Authority sent recently to the National Forests and Grasslands in Texas … regarding the strip lands along the shoreline of Toledo Bend.”
The Sabine River Authorities stated in a July 1, 2011 letter to the FS:
“The Authorities believe that a successful land exchange agreement would be mutually beneficial and greatly improve management of both SNF (Sabine National Forest) and Toledo Bend. A part of the land exchange negotiations, for example, the Authorities would assist SNF in identifying lands that, unlike the current SNF acreage sought by the Authorities, could be placed into productive use. A land exchange agreement, moreover, could include an appropriately sized buffer zone to minimize interference and conflicts between the U.S. Forest Service’s management of SNF and the Authorities’ management of Toledo Bend. Finally, in light of the ongoing FERC relicensing of Toledo Bend, a land exchange agreement could and should include measures for the adequate protection and utilization of SNF during the upcoming FERC license term.”
A September 3, 2011 email from the LSC stated:
“Interest Shown by Sabine River Authority in Toledo Bend Strip Lands”
“Recently, the U.S. Forest Service (FS) contacted the Lone Star Chapter/Houston Regional Group of the Sierra Club about a proposal by the Sabine River Authority (SRA) to acquire by land exchange the so-called “strip lands” that border Toledo Bend Reservoir on the Texas/Louisiana Border within Sabine National Forest (SNF). The “strip lands” are found between the 172-175 foot contour of the Toledo Bend Reservoir and are federal land. These lands consist of about 3,650 acres of SNF and include about 300 acres in Indian Mounds Wilderness Area.”
“The SRA wants to acquire these lands so the FS will no longer be a legal party to the renewal of its Federal Energy Regulatory Commission (FERC) permit at any time in the future for Toledo Bend Reservoir. This desire for no FS participation in its permit renewal, which involves among other things reservoir operation, is probably because the SRA wants to sell huge amounts of water to other areas of Texas, including Houston, via large canals or pipelines.”
“The FS asked the Sierra Club if it was willing to discuss this issue to determine if the land exchange might work. The Sierra Club requested a copy of the SRA’s letter and a description of the proposal. For the Sierra Club to participate in any such discussions the Sierra Club nationally, not the Lone Star Chapter or Houston Regional Group, would have to agree to participate because significant federal issues, congressionally designated wilderness and federal permits, would be involved. An agreement to exchange these lands would require an act of the U.S. Congress to remove the 300 acres from Indian Mounds Wilderness Area. This could set a precedent for the National Wilderness System and encourage other attempts to reduce wilderness acreage around the United States.”
“The Sierra Club checked back with the FS and found that after reflection the FS decided not to consider the request by the SRA. For now, SNF and Indian Mounds Wilderness Area are safe and the FS remains a valuable public participant in the renewal of any permit to operate the Toledo Bend Reservoir. The Lone Star Chapter and Houston Regional Group will continue to follow this issue closely.”
A September 5, 2014 email from the LSC to NSC stated:
“About a year ago I had a discussion … about a proposal administratively to address this issue with public input and the outcome, if approved, would add at least an equal acreage to Indian Mounds Wilderness Area as the amount removed from it. At that time administratively the issue did not move and Mr. van Every (Forest Supervisor, NFGT) told me if it looked like it might move he would contact the Sierra Club. A year ago I let the Lone Star Chapter know about the administrative proposal and told them if the U.S. Forest Service (FS) began an administrative action about the proposal I would let the Chapter know because this is a national issue that deals with the precedent of removing acres from an already designated wilderness and that National Sierra Club would need to be involved.”
“Apparently, in October of 2013, Gomert (U.S. Congressman) introduced HB 3411 but it went nowhere. Mr. Van Every had heard there might be a hearing on HB 3411 in the future but was surprised when he was told September 9th was the date of the House hearing. Mr. Van Every said that acres that are adjacent to the Indian Mounds Wilderness Area are owned by Crown Pine Lands and that they had been heavily cut over. My. Van Every said that currently the FS is opposed to the bill because it deals with wilderness, the bill does not address lands that would be acquired in exchange, the FS does not know what lands would be offered in exchange (if any), there are questions about the survey, and there are questions about the cost of the lands.”
“I wanted to let you know as soon as possible so that the Sierra Club could let the appropriate U.S. Representatives and Senators know that it does not support and is concerned about HB 3411. Please keep me in the loop and let me know if I can do anything else.”
On December 3, 2014, the Forest Supervisor, NFGT, sent an email to the LSC that stated:
“Wanted to let you know that the National Defense Act which is rapidly moving through Congress has a provision in it for legislated land exchange for the Sabine River Authority including lands in the Wilderness.”
The LSC alerted the NSC and Wilderness Watch on December 4, 2014 about this situation and in an email to Wilderness Watch which stated:
“We’re preparing a sign on letter opposing the public lands’ riders in the Defense bill. It will start circulating for signatures tomorrow in the AM. I’ll send it to you … with the hope we can get the Sierra Club to sign on. We know the odds of turning this bill around, but it’s essential we let Congress know of our opposition. I’ve been pleased to see the Club expressing its opposition to the “deal”.”
A December 14, 2014 email from NSC stated that the Sierra Club did oppose the National Defense Authorization Act. The NDAA as passed on December 12, 2014 stated:
“SEC. 3088. TOLEDO BEND HYDROELECTRIC PROJECT.”
“Notwithstanding section 3(2) of the Federal Power Act (16 U.S.C.
796(2)), Federal land within the Sabine National Forest or the Indian
Mounds Wilderness Area occupied by the Toledo Bend Hydroelectric Project
numbered 2305 shall not be considered to be—"
“[[Page 128 STAT. 3858]]”
“(1) a reservation, for purposes of section 4(e) of that Act (16 U.S.C. 797(e));
(2) land or other property of the United States for purposes of recompensing the United States for the use, occupancy, or
enjoyment of the land under section 10(e)(1) of that Act (16
U.S.C. 803(e)(1)); or
(3) land of the United States, for purposes of section 24 of that Act (16 U.S.C. 818).”
The NDAA allowed the Toledo Bend Authorities not to pay the U.S. Government for Sabine National Forest and Indian Mounds Wilderness Area acres that were used by the Authorities in the operation of the Toledo Bend Reservoir.
F. Sierra Club, Indian Mounds Wilderness Area, and Marijuana Grow Site
In August 2016, the FS contacted the LSC and others about an illegal marijuana grow site that had been discovered in IMWA. The FS stated:
“All, I wanted to inform you of a Drug Trafficking Organization (DTO) marijuana grow site discovered in Indian Mounds Wilderness last week. Local and Forest law enforcement officers responded to the site last week and removed several thousand plants from the gardens and equipment used in the operation from within the wilderness. Access with an ATV was granted to the area for LE&I removal of the plants and equipment associated with the site. The impact to resources from the clearing and tending activities is quite extensive. Numerous trees were felled, canopy tops trimmed and limbed, as well as an irrigation system of ploy pipe transferring water from the streams to the plants. There was an established camp with garbage pit with refuse dumped in the pit. There is still a fair amount of pipe, garbage, and trash remaining at the site that will need to be addressed in an appropriate manner.”
“The forest will be meeting to determine the best course to address the cleanup and rehabilitation of this site as well as another site discovered on the Davy Crockett NF. Our goal is to determine the best approach to clean up the site, protect wilderness values, and foremost provide for the safety of the public and our employees.”
“As we value your opinions and insight to the challenges we face in addressing these issues, feel free to contact me directly for additional information and discussion. Thank you for your support and interest in the National Forest and Grasslands in Texas.”
The LSC emailed back to the FS about this situation and said:
“On behalf of the Lone Star Chapter of the Sierra Club I appreciate your notification about the illegal marijuana farm found in Indian Mounds Wilderness Area. I would like, when it is available, the report that documents the location of the area where the situation occurred, the size of the area, what was found, what was done to clean-up, and how the clean-up was conducted in the wilderness area.”
“It is important that any remaining clean-up complies with the spirit and letter of the Wilderness Act. This includes no use of motorized and or mechanized transport or other devices using the minimum tool procedure.”
“Please keep me informed of any further actions conducted in Indian Mounds Wilderness Area with regard to this situation. Thank you.”
The FS responded to this email and stated:
“Mr. Mannchen, thank you for the response and sharing your concerns. As of now the site is secured and we are approaching this issue carefully in regards to clean up and rehabilitation with your concerns, as well as others in mind. The criminal investigation is ongoing and we are gathering additional information. As we develop a strategy moving forward we will be sure to document our actions and share that information with our partners as appropriate, and as that information becomes available. This is an unusual situation and one that will unfortunately likely reoccur in the future. We are working diligently to develop a protocol that will be successful in mitigating to greatest extent possible this incident and hopefully guide our actions to others in the future. Your input and concern is greatly appreciated.”
“Thanks for responding. I look forward to hearing more from the U.S. Forest Service as this situation develops.”
Finally, the LSC forwarded this information to Wilderness Watch. Wilderness Watch sent back an email which stated:
“Hey Brandt,
“Thanks for forwarding all this stuff. Find out what they did with the pot.”
“Let me know what, if anything, we can do to help.”
Illegal marijuana farms continue to be a problem in the NFGT and throughout the National Forest System.
G. Sierra Club, East Texas Wilderness Areas, and Planning
The fate of wilderness is also addressed in planning. Planning can ensure that areas that are acceptable for potential wilderness designation are assessed and can also provide restrictions and management tools to ensure wilderness protection before and after wilderness designation.
I no longer have LSC or HSC comments for Forest Plans up to the 1996 Revised Land Resource Management Plan (RLRMP). This section will focus on the forest planning that has been done in preparation for a new Forest Plan which hopefully will occur soon.
There had been years of informal discussions about when the NFGT Forest Plan would be revised. The FS kept pushing the date back and allowing other National Forests to have their Forest Plans revised.
In 1996, the LSC provided “initial thoughts … regarding issues/concerns that should be addressed by the U.S. Forest Service (FS) in a revised National Forests and Grasslands in Texas (NFGT) Land management Plan (LMP).” The LSC input for wilderness in its April 25, 2016 letter was:
“32) Wilderness Areas – There is a need for wilderness rangers that educate people and prevent illegal actions in the five East Texas Wilderness Areas (Little Lake Creek (SHNF); Big Slough (DCNF); Upland Island and Turkey Hill (ANF); and Indian Mounds (SNF). There is a seeming overall lack of care or interest by the FS about the needs of wilderness. Wilderness management mostly consists of restraint and control of trammeling actions by users and the FS.”
Immediately, the LSC focused on the lack of interest by the NFGT in protection of wilderness and trammeling actions that should be minimized during human management and visitation.
More time, meetings, and discussions occurred and on April 8, 2017, the LSC provided additional input about the LMP and wilderness. These comments stated:
“d. Wilderness Areas – There are five U.S. Congress designated wilderness areas in the NFGT: Turkey Hill (5,473 acres) and Upland Island (13,331 acres) in Angelina NF; Big Slough (3,639 acres) in DCNF; Indian Mounds (12,369 acres) in Sabine NF; and Little Lake Creek (3,855 acres) in SHNF. Current and proposed scenic areas, roadless areas, and special management areas should be reanalyzed for wilderness potential. The need for wilderness grows as population and development increase in East Texas. In our lifetime we are seeing the urbanization of East Texas. Soon there may be no further opportunities for wilderness. We should not miss our chance now.”
“There is a need for wilderness rangers to educate people and prevent illegal actions in the five East Texas Wilderness Areas and other SMAs. There is a need for an educational program about wilderness, what it is, how it is different, what it protects, and how it is not managed. There appears to be a lack of interest by the FS about wilderness. Wilderness management mostly consists of restraint and control of trammeling actions by users and the FS. Please see Attachment 14.”
During this time, the LSC prepared fact sheets about the Forest Plan, entitled, “Tell Me About the National Forests and Grasslands in Texas” and “New 2017 Forest Plan Effort Begins With Assessment” and placed this on its website and sent it out to Sierra Club members and the public.
The FS announced it would hold meetings on September 12 and 14, 2017 to take comments and discuss the Forest Plan assessments about wilderness and wild and scenic rivers for the NFGT. The LSC recommended to members and the public the following about wilderness:
“2) Big Creek and Winters Bayou Scenic Areas should be considered for wilderness eligibility due to their natural and untrammeled conditions.”
These scheduled meetings were cancelled by the FS due to Hurricane Harvey and weren’t rescheduled. The LSC did submit comments to the FS about the wilderness assessment on December 14, 2017. Those comments stated:
“Previous Evaluation of Roadless Areas, Appendix D, Final Environmental Impact Statement, NFGT 1996 Land Resource Management Plan”
“The Sierra Club, in the early to mid-1990’s, when the Draft and FEIS’s for the 1996 Land and Resource Management Plan (LRMP) were prepared, criticized the FS for a Wilderness study that was biased and inaccurate. The Sierra Club believed then as it does now, areas like, Big Creek Scenic Area, Winters Bayou Scenic Area, and others, met the criteria of the Wilderness Act and should have been potential Wilderness Areas. It was evident to the Sierra Club that the scoring criteria were biased which artificially lowered scores. After scoring areas low, the FS stated that none of these possible Wilderness Areas scored sufficiently high on Wilderness criteria to be potential Wilderness Areas.”
“The Sierra Club is concerned that the current Wilderness Study process will not reflect all Wilderness Areas that meet Wilderness Act criteria for the NFGT Forest Plan revision.”
“Comments on the Initial Draft Wilderness Inventory for the NFGT Forest Plan Revision”
“The current Initial Draft Wilderness Inventory consists of a series of geographic information system (GIS) maps for each NFGT. These maps are on such a small scale that it is not possible for the Sierra Club to precisely determine where possible Wilderness Areas are in the areas that the FS has delineated. The Sierra Club recommends that maps be made available to the public that are large in scale (like the maps of each entire national forest that are sold to the public). These maps should include Compartments and stands where each potential Wilderness Area is, have easily seen existing roads (as well as their type and condition), include rivers and streams, oil/gas wells, other infrastructure, and have obvious boundaries for each potential Wilderness Area.”
“The Sierra Club believes that many of the acres that have been proposed as potential Wilderness Areas are crucial habitat for the federally endangered Red-cockaded Woodpecker (RCW). Management for the RCW includes thin logging, midstory removal logging, periodic prescribed burns, mulching, cavity inserts, cavity protection, and other intrusive and invasive mechanized management which disqualifies these areas from Wilderness Area consideration because the landscapes have been massively trammeled. It is not a wise or an economical use of hard-to-get FS dollars to analyze areas that will not meet Wilderness criteria now or in the future due to management requirements for the RCW.”
“The FS should look at areas that do not need to be “managed” in any normal sense of the word. The type of management that Wilderness Areas or Wilderness Study Areas need is minimal and may include marked boundaries; education of users about the history of Wilderness, what is Wilderness, what is and is not allowed in Wilderness, what is in each Wilderness, how to use and protect Wilderness, etc.; and patrol and enforcement so illegal uses do not occur in Wilderness.
“There are some areas that lend themselves more easily to potential Wilderness Area designation. In Sam Houston National Forest, the two scenic areas, Big Creek, and Winters Bayou, with minimal work (closing and obliterating a few roads), could be designated potential Wilderness Areas. To make a Wilderness study effective and more efficient the FS should focus on areas that are more Wilderness-like, could become Wilderness (recover from human impacts) quicker, and do not have endangered species management conflicts.”
“Other similar areas that could be potential Wilderness Areas include Beech Ravines Scenic Area and Upper Colorow Creek Scenic Area (Management Area 8c); Protected River and Stream Corridors along Winters Bayou in Sam Houston National Forest and the Neches River in Davy Crockett and Angelina National Forests (Management Area 8b); Bear Creek, Ayish Bayou, Yellowjacket Branch Creek, Attoyac River, and Upper Angelina River Special Bottomland Areas (Management Area 8e). Other places to consider analyzing for potential Wilderness Areas are lakes and their floodpools and streams or rivers and their floodplains and associated slopes and upland fringe.”
“The Sierra Club requests from the FS better and larger format maps with the information on them that is mentioned above. Then the Sierra Club and the public can visit these areas to view and more accurately analyze their Wilderness Area potential.”
The FS responded to these comments via email on January 4, 2018 and stated:
“1) The background information you provided regarding the last round of Revision planning related to Wilderness is really helpful. The “institutional memory” you provide is invaluable;”
“2) I appreciate your concern about the current Wilderness Study process. As you know, the process has not played out as we initially planned, largely because of complications related to Hurricane Harvey. In particular, we had plans to hold public meetings to explain the planning process for both Wilderness and Wild and Scenic Rivers. Absent those meetings, and all of the associated materials we planned to share, the information that we have provided is not very useful.”
“3) The schedule for re-initiating the planning process, including public involvement, has not been established, but I believe the process is sound.”
“4) Without getting into too much detail, I want to respond briefly to your concern that “many of the acres that have been proposed as potential Wilderness Areas are crucial habitat for the federally endangered Red –Cockaded Woodpecker.” I understand your concern that this “is not a wise or an economical use of hard-to-get FS dollars to analyze areas that will not meet Wilderness criteria now or in the future….” I’m sure, from a certain perspective, it looks pretty silly that we would include those areas, even in an initial draft; however, from another perspective, I think it could be seen as a positive sign. First of all, we are committed to following the process. We aren’t going to skip steps or cut corners (even if we know we could “get away with it” without compromising the end result). Also, I think it reflect the true spirit of the Rule and Directives to be as inclusive and thorough as possible. As with other parts of the Revision process (e.g. ecological sustainability), the planning process for Wilderness applies “course” and “fine” filters and many criteria. In part, the initial draft was based on size and adjacency criteria. These “coarse” criteria help to establish the “universe” of all lands that are potentially eligible (even if they are quickly eliminated from further consideration based on further analysis).”
“5) In subsequent steps we will focus our analysis, as you suggested, on “areas that do not need to be ‘managed’ in any normal sense of the word.”
“6) As always, I really appreciate the site specific suggestions you provide, including Big Creek and Winters Bayou as well as the many “other similar areas” you mentioned by name.”
The FS prepared a “Wilderness and Designated Area Assessment” report on December 28, 2017. The LSC obtained this report in 2018 and on June 15, 2018 provided comments which stated:
“2) Page 2, Wilderness, Current Conditions and Trends, it was not due to RARE II that five of sixteen areas evaluated became wilderness. It was due to the dedicated and hard work of thousands of people who supported the 1984 Texas Wilderness Act that passed the U.S. Congress on October 30, 1984.”
“The FS was against having wilderness in Texas for two decades and probably the only area that it really supported was the Big Slough Wilderness Area. After the Texas Wilderness Act passed, the FS logged, not just cut, Little Lake Creek Wilderness Area (LLCWA) supposedly because of southern pine beetle (SPB). The FS only stopped logging this wilderness when public outrage and media attention was so overwhelming that it made it impossible not to stop. The FS should give an accurate history of wilderness in the NFGT, so the public knows how difficult it was to save these lands against FS bias to log and not protect them.”
“4) Page 3, Wilderness, Turkey Hill, the description of Turkey Hill Wilderness Area of “… snakes, stinging insects, ticks and chiggers” is ridiculous and shows the FS’s continued bias against wilderness. The evidence of roads, which are no longer roads because they are in wilderness, is minimal and is acceptable because the Wilderness Act the U.S. Congress say this is okay. This is no longer an issue, but the FS keeps bringing it up to disparage wilderness. The FS bias against wilderness continues. This entire paragraph should be rewritten.”
“5) Page 3, Wilderness, Big Slough, the FS blames wilderness for maintenance of the “Big Slough Canoe Trail”. The reality is the FS has not maintained the trail because it did not want to use the tools that the Wilderness Act deems acceptable for maintenance, like crosscut saws. Wilderness and wild floodplains are supposed to change. That is why Big Slough is wilderness in a wild floodplain. Protection of wilderness character is more important than a canoe trail that is ephemeral at best in the wild Neches River Floodplain. If the canoe trail has been “decommissioned” the FS should let the public know this.”
“7) Page 4, Wilderness, Risk to Sustainability, the FS should acquire all mineral rights under the five East Texas Wilderness Areas. The FS should also require a no surface occupancy stipulation for wilderness so that oil/gas drilling will not occur inside the five wilderness areas.”
“The FS shows its bias when it uses the phrase, “hands off management”. This is an untrue statement which is used to degrade or denigrate the wilderness idea. This phrase should be removed from this report because it is false.”
“For wilderness areas the FS marks and keep boundaries for wilderness areas; the FS manages recreational use in wilderness to protect wilderness character; the FS oversees trail maintenance in wilderness areas; the FS cuts and logs when necessary when SPB’s appear in wilderness; the FS gathers recreation use data in wilderness areas; the FS conducts law enforcement actions to keep motorized vehicles out of wilderness; the FS monitors SPB activity in wilderness; the FS puts out wildfires in wilderness; and the FS prescribe burns in Upland Island Wilderness Area. None of these actions alone or together constitute “hands off management”.”
“The FS refuses to acknowledge that wilderness management, which allows nature to call the shots and where human intervention is minimized because we are visitors to wilderness, is a legitimate form of management that is recognized all over the world.”
“The FS acts like it has never heard of plant succession and natural disturbance which are two of the natural ecological processes that drive vegetation change and existence in wilderness areas. The FS assumes that wilderness is “more susceptible to insect and disease outbreaks” but forgets that one way to combat SPB attacks is to have a screen of hardwood trees between pine trees. This is what wilderness does. Besides insects and disease in wilderness, there are other natural disturbance factors that are supposed to operation in wilderness to shape the ecosystems. That is okay despite the negative response by the FS about natural disturbances in this report.”
“The FS seems to speak for citizens (unnamed) when it says, “Many private citizens and county officials view wilderness as removing potential revenue from timber sales from their communities.” The FS should provide the documentation and data for this statement. Many more people like wilderness and don’t want it logged.”
“The FS knows that the 3,855-acre LLCWA is a miniscule part of the 163,000- acre SHNF much less the larger NFGT. The LLCWA is 2.36% of SHNF that cannot be logged for commercial purposes. This is an overestimate since all of the 3,855-acre LLCWA does not have pine trees that are commercially valuable. It appears that the “balance” that the FS talks about does not exist since most of SHNF can be commercially logged and is not wilderness.”
“The FS should define what it means when it uses the word “encroachments” when talking about wilderness and future population growth. As far as the Sierra Club knows there have been no “land encroachments” in any of the five East Texas Wilderness Areas. If the FS properly manages wilderness areas and ensures that law enforcement and management personnel are available to conduct oversight to protect wilderness there will be no problem. There is no one who is assigned wilderness ranger duties for the five East Texas Wilderness Areas. There should be FS personnel who specifically conduct oversight on wilderness areas and designated areas.”
“8) Pages 4 and 5, Wilderness, Conclusions and Future Considerations, the FS states that “… management of Upland Island Wilderness is flexible to the needs of the area including management of woodpeckers and control of insects and disease.” The FS should explain what it means by this. The Sierra Club is not aware of any specific FS effort to make wilderness areas suitable for Red-cockaded Woodpeckers (RCW). The U.S. Fish and Wildlife Service and the FS a long time ago agreed that wilderness areas would not be managed for RCW and were not needed for RCW recovery. The FS should state specifically what “flexible” management refers to here.”
“27) Page 18, National Recreation Trails, Risk to Sustainability, since this section is not about wilderness the part that discussed e-bikes in wilderness does not go here. E-bikes are mechanized equipment and as such are not allowed in wilderness.”
“There are very few miles of trail in wilderness areas in the NFGT so when the FS states that“… it is difficult to keep ahead of vegetation encroachment on all trails but particularly those that traverse wilderness” this is not a significant problem. Rapid vegetation growth affects all trails in the NFGT and not just those in wilderness areas. Since hand-tools are used to clear the LSHT in LLCWA, and since there are few miles of trail in this wilderness area, trail maintenance on wilderness trails is not a significant problem. Upland Island, Turkey Hill, and Indian Mounds Wilderness Areas have no permanently maintained trails. Only a short segment of the Four C’s National Recreation Trail (most of which is a board walk) and about 3-4 miles of LSHT in LLCWA are found in wilderness areas in the NFGT. The Sierra Club believes trail maintenance in wilderness areas is a non-issue.”
“35) Pages i and ii, References, the Sierra Club finds it significant that the FS did not use and reference the only book that has been written about the five wilderness areas in the NFGT, “Realms of Beauty: A Guide to the Wilderness Areas of East Texas”, by Edward C. Fritz, University of Texas Press 1993. The FS should reference and use this book when it talks about the five wilderness areas in the NFGT.”
Unfortunately, before further discussions occurred between the LSC and NFGT about wilderness management, the FS in Washington, D.C. and Region 8 in Atlanta, decided to stop the process in May 2018 but didn’t inform the public. The LSC found out about the “halt” in the Forest Plan process and recorded it this way when it informed its members and the public:
“Forest Service Halts National Forest and Grasslands Forest Plan Revision”
“The U.S. Forest Service (FS) has halted all work on the National Forests and Grasslands in Texas (NFGT) Forest Plan revision. The revision process, which takes 3 to 4 years, will “pause” for an unknown time period. It is thought that the “halt” could be as long as two to four years.”
“The Chief’s Office in Washington, D.C. and the Southern Region (Region 8) of the FS in Atlanta, Georgia made the decision. The decision was communicated to the NFGT Forest Supervisor’s Office in May 2018. No official notification has been made to the public by the FS.”
“The reasons given by the FS for halting the NFGT Forest Plan revision include: lack of money, lack of personnel, no allowance for hiring personnel to prepare the forest plan revision, and prioritization of forest plan revisions for other national forests rather than for the NFGT.”
“Forest Plans are supposed to be revised every 10 to 15 years. The existing NFGT Forest Plan was approved in 1996. At over 22 years, the current NFGT Forest Plan is 7 years overdue for a revision.”
“A lot has occurred over the past 22 years that affects the NFGT. Some of the changes include: increased recreational use; improved endangered Red-cockaded Woodpecker (RCW) populations; greater human population growth, development, and urbanization around the NFGT, particularly around Sam Houston National Forest (SHNF); further fragmentation of the landscape surrounding and next to the NFGT; emphasis on restoration of Longleaf and Shortleaf pine ecosystems; more pressure to exploit oil/gas resources; increased prescribed burning; budget cuts; and reduced staffing. These and other issues should be addressed in an updated Forest Plan with citizen input now!”
“For the Lone Star Chapter and Houston Regional Group of the Sierra Club, this decision is a particular disappointment. As the Sierra Club recently told the Forest Supervisor of the NFGT, “The NFGT are as important as other national forests in the United States”.
“Since 2010, the Sierra Club has been told each year that the NFGT Forest Plan revision process may begin. In late 2015, the Sierra Club provided the FS with a list of people and organizations that should be notified when the NFGT Forest Plan revision begins. The revision process was set to begin in 2016, when the FS “paused” it. In 2017, the FS held several public meetings and then “paused” the process again.”
“In late 2017 and in 2018, the Sierra Club provided comments on draft natural resource reports that the FS prepared. These reports included: Air Quality Assessment; Cultural and Historical Resources Assessment; Social, Cultural, and Economic Assessment; Geologic Resources and Hazards Assessment; Energy and Mineral Resources Assessment; Land Status, Ownership, Access, and Use Assessment; Timber Resources Assessment; Recreation Assessment; Wilderness and Designated Area Assessment; Ecosystem and Species Concerns; System Drivers and Stressors Concerns; Wilderness Study; and Wild and Scenic Rivers Study. The effort by the Sierra Club to provide the FS with input early has apparently been wasted.”
To this day in 2023, the NFGT Forest Plan revision process hasn’t been restarted. It’s very disconcerting when the LSC and public organize to provide their input for their national forests and are treated in this manner.
H. Sierra Club, East Texas Wilderness Areas, and Use of Motorized Vehicles During Emergencies
The Wilderness Act provides an exception in the case of emergencies to the public for the use of motorized vehicles. Section 4(c), the Wilderness Act states:
“Except as specifically provide for in this Act … except as necessary to meet minimum requirements for the administration of the area for the purpose of this Act (including measures required in emergencies involving the health and safety of persons within the area), there shall be no temporary road, no use of motor vehicles, motorized equipment … no other form of mechanical transport, and no structure or installation within any such area.”
Although this exception is made for emergencies involving human health and safety of persons within a wilderness, the Wilderness Act speaks to how this must be done as compatibly as possible in wilderness. Section 2(a) of the Wilderness act states:
“… shall be administered for the use and enjoyment of the American people in such manner as will leave them unimpaired for future use and enjoyment as wilderness, and so as to provide for the protection of these areas, the preservation of their wilderness character”.
Section 2(c) of the Wilderness Act states:
“A wilderness … is hereby recognized as an area where the earth and its community of life are untrammeled by man, where man himself is a visitor who does not remain … which is protected and managed to as to preserve its natural conditions”.
Section 4(b) of the Wilderness Act states:
“Except as otherwise provided in this Act, each agency administering any area designated as wilderness shall be responsible for preserving the wilderness character of the area and shall so administer such area for such other purposes for which it may have been established as also to preserve its wilderness character”.
With this thought in mind, the HSC found out in October 2001, during a LSHT Annual Meeting with the FS, that FS law enforcement, “conduct a lot of search and rescue missions (about 4 times/yr.) and when this occurs in the Wilderness he lets the sheriff and others ride ATV’s and horse on the LSHT.”
A letter was sent by the HSC on December 4, 2001 to FS law enforcement which stated:
“You mentioned that about four times/yr., when people get lost in Little Lake Creek Wilderness Area (LLCWA), that you allow law enforcement personnel to ride ATV’s in LLCWA. I want to express to you my concern about this activity. I agree that in some cases using motorized vehicles for rescue in LLCWA may be necessary. However, I believe criteria are needed to determine when a situation requires motorized access.”
“A more acceptable alternative is to use horses, instead of ATV’s for rescue operations. Horses should be able to traverse LLCWA as quick or quicker than ATV’s. Horses can traverse areas of heavy vegetation where ATV’s cannot go. Since the U.S. Forest Service has a policy of using the minimum tool when conducting management activities in Wilderness this policy should also apply to rescue operations.”
“I urge you to adopt the minimum tool policy for rescue operations in LLCWA. Please send me a copy of the guidance that you have for using motorized access in LLCWA for rescue operations.”
Even with rescue operations, the minimum tool concept to reduce trammeling in wilderness is important.
Another example, much larger, more complex, and significant, of the need for the minimum tool in wilderness occurred when a national tragedy occurred and affected Texas, SNF, and IMWA.
When the space shuttle Columbia, on February 1, 2003, disintegrated while re-entering the Earth’s orbit thousands of pieces of this spacecraft either burned up or fell to the ground. This occurred across the United States and at least from near Fort Worth through East Texas. One place where many pieces fell to the ground and a search was conducted was in SNF and IMWA along the shoreline of Toledo Bend Reservoir in East Texas.
This required a massive recovery and clean-up of debris that fell to the Earth in the United States and the State of Texas. Clean-up of the debris was hindered by bad weather due to cold, windy, rainy days. Most searchers of the debris were either walking or riding horses. On some days 500 people conducted searches in SNF and nearby areas. Divers were used in Toledo Bend Reservoir.
Some FS officials showed their bias against wilderness and blamed the slow delay on, “briars and underbrush and at worst case become a jungle, like in the Indian Mound Wilderness Area … Hands-off wildlife management is a nice concept … Anywhere else in the U.S. it is a great idea but in the South, it doesn’t work because of the growing conditions in the South you get a complete jungle. That is what it is. Choked up undergrowth.”.
This was about to change. On February 7, 2003, a memo from the Supervisor’s Office, NFGT, stated:
“You are authorized to use aerial and mechanized equipment as necessary to locate and remove possible human remains and any potential hazardous materials associated with the Columbia space shuttle that disintegrated throughout a portion of East Texas. This includes Indian Mounds Wilderness Area in the Sabine National Forest.”
“Entry into the Indian Mounds Wilderness area should be limited to the least impacting equipment to minimize any long-term resource impacts.”
Low-flying helicopters. which followed cues given by vultures, were used but now permission was given for the use of four-wheel drive vehicles in IMWA.
It was reported on February 22, 2003, in the Lufkin Daily News, that, “… thousands of volunteers, National guardsmen and others have been walking through forests and tilling the muddy soil with four-wheelers and other motorized equipment.”
“Environmental groups … expressed concerned about the search’s effect on East Texas forests overall. This has been a pretty heavy footprint on the forest”, stated Richard Donovan of the Texas Committee on Natural Resources.
This was the first time that the HSC was aware of this motorized activity in IMWA. The FS had not kept the HSC informed about this action. A letter was sent on February 24, 2003 to Fred Salinas, FS, Forest Supervisor, NFGT, about the situation and stated:
“This evening I received an email that surprised me. This email included a copy of an article … The article stated that the U.S. Forest Service gave permission to use four wheel drive vehicles in the Indian Mounds Wilderness Area (IMWA) to search for debris from the space shuttle Columbia.”
“We understand the importance of finding as much debris as possible from the Columbia. We are concerned that the U.S. Forest Service has not notified the public and requested input on how searches can be accomplished and adhere to the spirit and letter of the Wilderness Act, cause as little damage to forest ecosystems as possible, and protect the Wilderness character in IMWA. The U.S. Forest Service should request public comment on an emergency, short, turnaround basis (one week).”
“As much of the search as possible in IMWA should be conducted by foot and not by motorized/mechanized mans. It is reasonable that initial searches should be conducted by foot to minimize damage to Wilderness character and resources. Only if large debris is found that cannot be removed by hand should the U.S. Forest Service consider use of motorized/mechanized vehicles. This is in keeping with the minimum tool policy of the U.S. Forest Service.”
“The U.S. Forest Service must eliminate or minimize impacts that searches have on IMWA. Any damage that occurs due to searches must be fully mitigated, restoration must be completely implemented, and motorized/mechanized access routes must be obliterated.”
“The HSC requests information about the types of activities that are associated with searches in IMWA for debris from the Columbia and that are currently ongoing, are being planned for, or are being contemplated for the future.”
On February 27, 2003, Richard Donovan, Chair, Forest Task Force, TCONR, sent a letter to the FS which stated:
“While the Texas Committee on Natural Resources (TCONR) finds no fault with the decision allowing 4-wheel drive vehicles to remove large pieces of the Columbia from the National Forests, we are concerned that the ATV’s will be used in the search for debris. It is our position that all reconnaissance for debris must be done on foot and motorized vehicles be used only in those extreme cases where the debris is too large to be carried by hand.”
“Further, when the recovery operations are completed, the USFS must not neglect to survey all damage done by the limited use of the ATV’s and move quickly to prevent any erosion that will surely occur if ruts at stream crossings are left unattended.”
The HSC sent a follow-up letter on February 26, 2003 to Forest Supervisor Salinas and stated:
“Other ways to remove debris from the Columbia that abide by the minimum tool concept include:
1) Helicopter
2) Mule
3) Horse
4) Oxen
5) Human pulled carts/wagons”
“The HSC provides this additional input so that the U.S. Forest Service is aware that it does have options other than the use of motorized/mechanized vehicles for search and removal of debris from the Columbia.”
The HSC continued to pursue the need for the minimum tool in wilderness during emergencies when this issue was mentioned at a meeting between the HSC and Forest Supervisor Salinas on July 1, 2003.
The HSC sent Forest Supervisor Salinas a letter on July 15, 2003. This letter dealt with several issues, one of which was IMWA searches for Columbia debris. The letter outlined a discussion with FS personnel about whether motorized use had occurred in IMWA due to the searches.
The HSC was told that it was thought that “no motorized vehicle use had occurred in IMWA” the HSC asked about whether someone from the FS had been monitoring motorized use in IMWA. The HSC was told that NSA, FEMA, and Texas A&M would have records of any motorized use in IMWA. The HSC expressed its concern that the FS had not monitored motorized use and did not have a copy of any documents about motorized use in IMWA from other agencies. The HSC then asked Forest Supervisor to answer some questions:
“Did motorized use of IMWA occur during the CSS (Columbia Space Shuttle) search?”
“Why was no monitoring conducted by the FS of motorized use in IMWA during the CSS search so that environmental impacts could be documented?”
“Why does the FS not know whether any motorized use occurred in IMWA during the CSS search?”
“Why does the FS not have records from FEMA, NASA, and Texas A&M that document motorized use or other entry of IMWA during the CSS search?”
“Did the FS apply and require the minimum tool policy for the CSS search in IMWA?”
“If the minimum tool policy was not required, why was it not required?”
“If the minimum tool policy was required I would like a copy of the analysis conducted to determine what the minimum tool was and the mitigation measures required to minimize any negative environmental impacts in IMWA.”
“The FS is the steward of wilderness for the public’s National Forests. As such it is important that monitoring of wilderness occur to ensure that it is protected. This is particularly important when the FS is aware of possible uses in the wilderness that may cause negative environmental impacts or that may be illegal.”
“I would appreciate a description from the FS about how it will handle such emergencies in the five East Texas Wilderness Areas in the future, based on what has been learned from the CSS search.”
The FS responded on September 25, 2003, to the HSC’s July 15, 2003 letter about several issues, including the CSS search and stated:
“(1) The first part of your letter has questions regarding Columbia Shuttle Recovery Efforts. You were given a copy of a letter that stated we had permission to enter the wilderness using mechanized equipment. Protocol dictated that the Incident Commander notify me before this option was used. I was never notified of plans to use mechanized equipment in the wilderness, and Rangers for both the Angelina and Sabine units assured me this did not occur. Since no motorized equipment was used, no monitoring of its use was required. In addition, the “minimum tool policy” was not mentioned for two reasons – most Forest Service employees are aware of the restrictions that apply to wilderness and foot traffic was all that was planned and occurred in the area.”
“Actions to be taken during emergencies that may occur in the future in the five east Texas wilderness areas will have to be evaluated on a case-by-case basis. These actions will be guided by provisions in Forest Service Manual 2320 or Forest Service Handbook 2309.19.”
Finally, on November 1, 2004, in a letter to the Director of Wilderness and Wild and Scenic Rivers, FS, the LSC stated about the IMWA and CSS searches:
“4) Possible Use of Motorized Equipment During Columbia Space Shuttle Search – During the search for debris from the Columbia Space Shuttle in 2003 the Forest Supervisor gave permission to use motorized equipment in Indian Mounds Wilderness Area (IMWA). The Sierra Club requested that a minimum tool analysis be prepared and that human pulled carts/wagons, oxen, horse, mule, or helicopter be considered as more acceptable ways to remove large debris. When the Sierra Club requested copies of documents about motorized use in IMWA we were told by the Forest Service that it did not have reports that would document this from other agencies and that we should contact NASA and FEMA. The Forest Supervisor stated by phone that he thought there was no motorized entry into IMWA because the Incident Commander was supposed to put out a plan for each day’s search and contact him personally if the wilderness was going to be entered. The concern the Sierra Club has is that the Forest Service could not give a definite yes/no answer about this question; that a minimum tool analysis apparently was not conducted by the Forest Service; and that the Forest Service did not have the reports that other agencies prepared when searching Sabine National Forest and Indian Mounds Wilderness Area. Please see that documents enclosed with this letter about this situation.”
The communications between the LSC and FS wasn’t sufficient and comprehensive enough to allay suspicion about what was occurring on-the-ground in IMWA during the CSS searches.
I. Sierra Club, East Texas Wilderness Areas, and Adopt-a Wilderness
Whenever a wilderness is designated, in statute, by the U.S. Congress, the responsibility for wilderness management begins. Those who support wilderness designation now have a responsibility to provide “citizen oversight” to ensure that wilderness remains wilderness.
The FS often has few personnel, money, and other resources. The FS uses its resources for other purposes rather than wilderness monitoring and management. It’s up to citizens to fill the gap and inform the FS about wilderness area protection and needs particularly when the FS doesn’t have the resources or doesn’t appear to be interested in the protection of wilderness.
“Citizen monitoring” programs in wilderness are often informal. Some organizations, like Wilderness Watch, have a more formal program which encourages citizens to “Adopt-a-Wilderness Area”, visit the wilderness area periodically, observe and record what they see, and share this with the FS, or other federal agency, and ensure that pressure is applied so that wilderness isn’t degraded with trammeling and “illegal uses” from the public and the management agency.
Informally, the LSC has conducted “citizen monitoring” for the five ETWA. An example of this is LLCWA. Since at least 1994, the LSC and HSC and members of the public have reported to the FS observations about what it has seen in LLCWA.
A December 21, 1994 letter to the SHNF, the HSC reported observations in LLCWA including: signs along roadways which state how far you are from LLCWA; vandalism of a trash receptable in a parking lot next to LLCWA; airplane noise over LLCWA diminished the feeling of solitude and quiet; the need for a sign at the beginning of the LSHT and LLCWA to let people know that the trail may be difficult to find and they may have to deal with logs across it; and the comeback of Switchcane in LLCWA since it is no longer grazed.
January 20, 1997, the HSC reported to the FS that there was illegal horse use on the LSHT in LLCWA; provided updated animal and plant lists for LLCWA; noted some rare ice or snow from recent cold weather; provided measurements of some large trees; reported seeps that feed into Little Lake Creek; feral hog damage and the need for control of these non-native invasive animal species.
The HSC in an April 26, 1997 letter to the FS made these observations in LLCWA:
1. Monitoring of SPB spot; active erosion from a woods road into a tributary of Little Lake Creek;
2. Need to remove barbed wire from an old fence;
3. In certain places barbed wire fences dis-wade illegal ATV use;
4. Illegal ATV use on a road next to LLCWA;
5. The need for a gate addition to close the gap where illegal ATVs can get in;
6. Updated plant list.
The HSC sent a letter on June 22, 1997 to the FS about a visit to LLCWA that occurred on Earth Day, April 22, 1997 and stated:
“The visit … uncovered an old eroded woods road that is generating sediment which is entering a tributary of Little Lake Creek … Enclosed are 5 photos of this area … I wanted you to see these phots so that you would be aware of this erosion source in Sam Houston National Forest’s only wilderness.”
On December 22, 1997, the HSC contacted the FS about what it detected during a “Forest Walk” in LLCWA. For the first time the HSC reported two illegal trails in LLCWA.
The HSC requested copies of the NEPA documentation for the construction of these trails. The HSC also reported illegal horse use on the LSHT, a problem that would reoccur over and over for the next 5-6 years. This letter requested a meeting with the Forest Supervisor and the District Ranger to “discuss trespass and other problems on the LSHT and how the Sierra Club and Forest Service can work together to reduce and eliminate these.”
January 7, 1998, the FS responded to a December 22, 1997 HSC information request about two illegal trails in LLCWA. The HSC asked for scoping notices, decision memos or notices, biological evaluations, environment assessments, and wilderness related analysis and evaluations for the two trails.
The FS stated that “No records exist at the district that are responsive to your request.” The FS went further to say:
“The trails you noted originate from a parking area adjacent to private land and FM 149 that we established to provide access to the southern end of the Little Lake Creek Wilderness. The parking area was developed in 1991 on a site that had historically been used for parking. In the time since then the trails you mention apparently have become established through regular use by the public. Both trails had apparently been unofficially maintained and posted with aluminum trial tags. In fact, the trail to the west was inventoried as part of the Lone Star Hiking Trail system and is shown on current maps as part of the LSHT. The trail to the north and west was not included in any inventory of the LSHT.”
“In 1996, my staff attempted to discourage the use of the trail to the north by removing the aluminum tags from a portion of the trail near the parking area. After I received your letter I had my staff remove the remaining tags from the trail.”
“I contacted Forest Supervisor Ronnie Raum about your request for a meeting concerning the Lone Star Hiking Trail. He is available to meet with you on March 3 at 10:00 a.m. at the district office in New Waverly. Please let me know whether or not you can meet at this date and time.”
This is the first mention that I have of two illegal trails that the HSC found in LLCWA. It would take about 7 years to get the FS to finally close these illegal two trails and the parking lot that provided access to them.
The HSC prepared for a March 3, 1998 meeting with the NFGT Forest Supervisor NFGT and SHNF District Ranger with a document entitled, “Meeting With Forest Service Concerning Illegal Uses on the Lone Star Hiking Trail and Other Issues”.
This document suggested that the illegal use of the LSHT by bicycles, horses, and ORVs is solvable and proposed a four-step program to reduce illegal use of the LSHT including:
1. Barrier installation program at each intersection of the LSHT with a road, powerline, pipeline, other possible illegal entry point and use Little Lake Creek Wilderness Area, Caney Creek area, and Big Creek Scenic Area/Double Lake Campground area with help from the HSC in installing the barriers
2. A sign installment program with wording on the sign of “Hiking Trail Only! No Bicycles, Horses, or ORVs.”
3. A systematic effort to increase law enforcement in places and at times that have been pinpointed as high illegal use areas with sensitive resources. The HSC would continue its trail monitoring and reporting efforts.
4. A public education and information program about proper trail use with a flyer that the HSC would work on with the FS and which could be passed out to people.
The FS sent a letter to the HSC on January 26, 1998 which stated that no NEPA documentation was on file for the two illegal trails found in LLCWA. The letter stated:
“You should receive a response from the Regional Forester within 20 days from their receipt of this letter.”
More about this response later in this history.
The meeting with the Forest Supervisor for March 3, 1998 was cancelled and rescheduled for later. The HSC sent a letter to the Forest Supervisor and SHNF District Ranger on March 3, 1998 and stated:
“On January 26, 1998, the National Forests and Grasslands in Texas responded to our FOIA requested and states, in part, “After searching our files, we have located no records of the information you are requesting. We are forwarding your letter, and our responses, to the Regional Forester in Atlanta for any records that may exist at that level, or for a final determination that the agency has no records that are responsive to your request. You should receive a response from the Regional Forester within 20 days from their receipt of this letter.”
“The Houston Sierra Club, with this letter, makes an official request that the environmental analysis and public participation process that is embodied in the National Environmental Policy Act (NEPA), the Council on Environmental Quality’s implementing NEPA regulations, and the Forest Service’s own regulations on NEPA, begin on these two trials and the parking area to determine their appropriateness in the Little Lake Creek Wilderness Area according to the Wilderness Act and all other applicable laws, regulations, rules and policies. We have included the parking area in our request with the trails because its placement apparently led to the establishment of the two trails, an impact that was not foreseen when the parking area was proposed and constructed. Revisiting the issue of the placement of the parking area can affect whether the trials are necessary or their generation can be prevented.”
“It is our belief that the construction, maintenance, and perpetuation of these two trails and the parking area cannot be categorically excluded because of the potential issues that exist regarding wilderness areas. Some of these issues include increased access for illegal uses, poaching, vandalism, littering, dumping, fragmentation of the wilderness area, the need for solitude and quiet, leaving wilderness areas untrammeled by humans, as much as possible, whether nay wilderness land was used for the parking area, and whether the trails are compatible and actually needed in the wilderness area.”
“We believe an environmental assessment or impact statement is needed to determine whether the trails and parking area should exist in or near the wilderness area, if the trails and parking area are necessary whether the correct locations have been found for these to minimize damage and impacts to the wilderness area, what the appropriate construction and maintenance of the trails are in the wilderness area, and how inappropriate use and damage to the wilderness can be avoided by proper construction, maintenance, education, and other mitigation measures for the trials and parking area.”
“The Houston Sierra Club has not taken a position about whether the trials and parking area should remain in or near the Little Lake Creek Wilderness Area. We are very concerned that appropriate environmental, site specific analysis be conducted and that all laws, regulations, rules, and policies be followed regarding wilderness protection and management.”
“The Club offers its assistance in any way possible during this environmental analysis process. We look forward to working with you on this issue. Thank you for your assistance.”
On March 9, 1998, the HSC provided the FS with materials about illegal use and illegal trails in LLCWA and the LSHT for a future meeting with the Forest Supervisor and SHNF District Ranger. On April 10, 1998, the HSC sent a letter to the FS about LLCWA and stated:
“On April 1, 1998, George Nickas, policy coordinator for Wilderness Watch, was in Houston. I took him to see Little Lake Creek Wilderness Area (LLCWA) and we hiked in the wilderness for about three hours. He enjoyed LLCWA very much, especially the small tread trail and the solitude you can find in the wilderness. We hiked the southern part of LLCWA, on the trail that has not undergone NEPA procedure.”
“We again found illegal horse use on the trail. This is the third or fourth time we have found this illegal use since December 1997 … It is obvious, as we have stated before, that someone is regularly using the trial illegally in LLCWA … We urge you to make it a high priority to find out who is illegally using the trials in LLCWA and write them a ticket so that this activity can be stopped. We also urge you to start installing barriers as soon as possible to prevent such illegal use of the trails.”
“We noted along this southern trail that links to the Lone Star Hiking Trail a lot of red and yellow ribbon. Apparently whoever used this ribbon left it in the wilderness. Wilderness is supposed to be a place where humans visit, but do not stay. Human impacts are supposed to be almost unnoticeable. We removed some of the ribbon but there was so much we could not remove it all. We request that the Forest Service remove the rest of the ribbon and ensure that its personnel is reminded that leaving ribbon in LLCWA is not acceptable.”
“We noted, about 100 yards west, on the southern trail, from the parking area, a gray post that had no apparent purpose. This does not appear to be a necessary structure and should be removed.”
“We noted, in several locations in LLCWA, Green dragons were growing and blooming. This is the farthest west in Sam Houston National Forest that we have seen this plant.”
In August 1998, the HSC wrote another letter to the FS and requested that a meeting be held with the Forest Supervisor and SHNF District Ranger to address illegal use issues on the LSHT. The HSC also requested “immediate initiation of the NEPA process regarding the illegal trails and a parking in in or near Little Lake Creek Wilderness Area.”
On September 27, 1998 a memo was sent to HSC members who worked on the LSHT and on forestry issues in SHNF that informed volunteers about the October 15, 1998 meeting in SHNF with the Forest Supervisor to discuss illegal use and illegal trails and possibly other trail issues.
October 15, 1998, the meeting was held with the Forest Supervisor and SHNF District Ranger and five HSC representatives about illegal trails and uses on the LSHT. Some of the issues discussed included:
1. The Forest Supervisor stated that the illegal trail was not built by the FS, it was not their fault, and that is why no NEPA documentation had been done.
2. The HSC stated that the FS has known about the trails for years and had allowed trail markers on it and inventoried it as part of the LSHT in the Little Lake Creek Wilderness and at the very least had passively accepted its presence.
3. The HSC stated that any trail in wilderness needs to go through the NEPA process and was not categorically excluded.
4. The FS disagreed with this statement but didn’t provide any information about why this was true.
5. The FS stated that the Limits of Acceptable Change (LAC) process was best to resolve wilderness issues, but they didn’t have $25,000 to conduct the process.
6. The FS couldn’t give the HSC a definite time when the LAC process would begin.
7. In January, the HSC would install some new no illegal use trail signs at entrances to the LSHT in LLCWA and the Caney Creek area.
8. The FS didn’t want to put up physical barriers against illegal uses
9. The FS said that the NFGT had the highest number of documented incidents and NOV’s issued of any southern national forest.
10. The FS stated that additional law enforcement personnel would cost a lot of money.
11. The HSC offered to print some signs that say “hiking only” and to pay for an educational flyer.
12. The FS didn’t make a firm commitment to prepare of pass out a flyer.
13. The HSC mentioned a protective LSHT corridor.
14. The FS didn’t commit to a LSHT protective corridor.
The HSC sent a letter on October 18, 1998 to the Forest Supervisor and SHNF District Ranger which thanked the FS for the October 15, 1998 meeting, provided a copy of the notes taken at that meeting, and outlined what was said at the meeting.
On October 22, 1998, the HSC sent a letter to the SHNF silviculturalist about the statement that he made that a new trail in wilderness could be categorically excluded. The HSC pointed out the FS CE regulations of September 18, 1992, 30., and CE categories for the Department of Agriculture 7 CFR a. part 1b did not pertain to, “establishing hiking trails in a wilderness area.”
The HSC also pointed out that the regulations required that “no extraordinary circumstances related to the proposed action” occur for a CE to be allowed but that the FS listed under “2. d. Congressionally designated areas, such as wilderness, wilderness study areas, or National Recreation Areas” as an extraordinary circumstance.
The HSC stated, “Scoping is required on all proposed actions, including those that would appear to be categorically excluded. If scoping indicates that extraordinary circumstances are present and it is uncertain that the proposed action may have a significant effect on the environment, prepare an EA.”
The HSC further stated, “at the very least an EA is needed for the Forest Service’s designation of a new segment of the LSHT in LLCWA.”
On October 27, 1998, the Regional Forester finally responded to the HSC’s December 22, 1997 FOIA request, 10 months after the request was made. The Regional Forester stated that, “We have just become aware of this request through your inquiry to the Forest Supervisor about its status. Evidently, the forwarded request became lost. We apologize for any inconvenience this may have caused you.”
“We have searched our files and determined that no records exist at the Regional Office that are responsive to your request.”
After 10 months, three searches. by three FS entities, all had no records that the illegal trails in LLCWA had undergone the NEPA process. The FS had documented the HSC concerns but hadn’t initiated the NEPA process or shutdown the trails.
Now, two years after first contacting the FS about the illegal trails in LLCWA, the HSC on January 17, 2000 sent the FS another letter about this issue and others. The HSC reported a hike in LLCWA where it observed:
1. Illegal horse use in LLCWA on the LSHT.
2. Poor signing such that people could get lost.
3. The visitation/registration cards in a box at the entrance to LLCWA on the LSHT had not been removed since February 1999, almost one year.
4. An illegal reroute of part of the LSHT had been conducted with no NEPA analysis.
5. The illegal trail in the southern part of LLCWA still had no resolution about NEPA analysis and being on the official trail inventory.
6. The HSC stated:
“We support legitimate trail reroutes for the LSHT. Such reroutes must be done within the requirements of environmental laws. We do not want trail activities to occur without proper documentation and authorization. A meeting of all trail maintenance groups or interested individuals to talk about the required environmental analysis and authorization needed in wilderness would be helpful to clear the air. We recommend such a meeting take place in the near future so we are all on the same page.”
The HSC also talked about how it had enjoyed the wilderness hike which included seeing large Loblolly Pines, Shortleaf Pines, Water Oaks, Water Hickories, Green Ashes, “in such a wild, quiet, place of solitude” and “was very relaxing and invigorating”.
Finally, the HSC noted the ecological changes in LLCWA:
“It was heartening to see the natural regeneration, restoration, and succession that is occurring on the Pole Creek part of the LSHT, where southern pine beetles killed most older pines in the early 1990’s. the pine seedlings that have naturally reseeded along with the continued growth of hardwoods makes this a natural laboratory that show how Nature can reclaim, restore, and heal an areas after a natural disturbance. This is a really good example of how pines will come back and reseed in an area where about 95% of the large pines were killed. This is one reason why wilderness is so important. It serves as a natural, biological, control laboratory to show how natural succession natural processes work.”
The FS sent a letter to the HSC on February 7, 2000 that noted that the rerouted LSHT found in January 2000 LLCWA was not approved by the FS. The FS stated:
“Apparently the trail changes you saw were completed without our knowledge. I am aware that we had discussed the need to fix this section of trail with some trail users in the past, but no formal proposal was made and we had not initiated any analysis under NEPA. We will be meeting on March 11 with the various trail user groups; the process we need to follow to implement projects such as this would be a good discussion topic at that meeting.”
In a letter in response on February 8, 2000, the HSC stated:
“You are right that a presentation and discussion about what can and cannot be done in wilderness for trail projects versus trail projects in the general forest without first conducting environmental assessment, evaluation, and analysis is needed.” We support and request a discussion of this issue specifically at the March 11th LSHT meeting.”
Two HSC members sent a letter to the FS on June 13, 2001, asking about the low water in LLCWA. The FS responded with a letter on June 21, 2001 and explained the lack of rainfall recently in LLCWA.
The HSC members sent a letter on June 27, 2001 to the HSC stating how much they appreciated getting copies of HSC and FS correspondence dealing with SHNF. The HSC responded back to the members and stated:
“What a great letter! Thanks for getting the Forest Service to actually serve the public they work for. After all we are all owners of Sam Houston National Forest. What a unique concept!”
“The Club needs lots of eyes and ears to find out what is happening. Sue, would you and Walt be interested in monitoring Little Lake Creek Wilderness Area (LLCWA) for the Houston Sierra Club. A great organization called, Wilderness Watch, has a program called, “Adopt-a-Wilderness”. The Houston Sierra Club has been monitoring LLCWA but we are limited since we can only get up there two or so times a year. There are so many issues and places to visit in Sam Houston National Forest it is hard to focus on just one area.”
“Monitoring LLCWA would entail doing what you are doing now. Visiting the area, enjoying it, and keeping your eyes open and reporting back to me what you find. For instance, there has been a lot of illegal horse use on the Lone Star Hiking rail in LLCWA. If you found recent signs of this activity you would let me know and I would document the problem in a letter to the Forest Service. But it is not just illegal activities we are interested in. I want to make a list of the trees, wildflowers, birds, etc. found in LLCWA and public a pamphlet for the public. You can help immensely by letting me know what you see.”
“Please think it over and tell me know you feel. I really appreciate your help and want to meet you and Walt and hike LLCWA with you. Let’s get together and enjoy our only Wilderness in Sam Houston National Forest.”
Letters from August 13, 2001, August 16, 2001, August 20, 2001, and September 3, 2001 were sent to and from the HSC by the “Adopt-a-Wilderness” volunteers to understand and determine what was expected and needed.
September 15, 2001, the HSC conducted a “Forest Walk” in LLCWA and LLC Roadless Area reported the observations made to the FS on September 25, 2001.
The observations included illegal horse use on the LSHT and a request from the FS for a summation of what the FS had done from 1998-2001 to stop illegal horse use in LLCWA, Sand Branch Loop, and the Richards Loop of the LSHT. The saga continued!
The HSC then sent the FS a letter on November 12, 2001, about a series of reports that the HSC “Adopt-a-Wilderness” volunteers provided about the LSHT and LLCWA. These reports stated for September 16, 2001 two horseback riders were seen on the LSHT and tracks of ATVs were also seen on the LSHT; October 16, 2001 horse-prints were seen in the bottomlands of LLCWA and a horse crossing was found at Pole Creek; and October 28, 2001 three horse trailers were seen at a LHST parking lot.
The HSC stated that a paragraph on the trailhead kiosk stated, “Sections of the Lone Star Hiking Trail transect the wilderness. Recreation opportunities include hiking backpacking, horseback riding …. Trailheads and parking areas for the wilderness area are located at”.
The HSC stated that the wording of this information “may lead people to believe they can ride on the LSHT. Revised wording saying that horseback riding is not allowed on the LSHT is appropriate.”
The HSC further stated, “We encourage the Forest Service to set-up a sting operation at the trailhead parking facilities around LLCWA on Saturday and Sunday mornings to catch the people who are illegally riding on the LSHT. The LSHT is being detrimentally affected (erosion and compaction) by illegal horseback and ATV use. The illegal use results in decreased enjoyment (less solitude, smell, sight, and feel of horse manure, noise of ATV’s) by those who want to hike on a hiking trail only trail.”
On November 14, 2001, the two “Adopt-a-Wilderness” HSC volunteers sent a letter to the FS about the need for decent maps and information to prevent illegal use of the LSHT by horseback riders, mountain bikers, and ORV’s. The present information was either not available at kiosks or was not helpful where people are allowed to recreate.
Additional reports or emails were made for November 14, 2001, December 9, 2001, January 12, 2002, January 20, 2002, January 27, 2002, February 3, 2002, February 10, 2002, March 10, 2002, March 24, 2002, April 7, 2002, and July 27, 2002.
On November 2, 2004, the HSC continued to press the FS about the illegal trails in LLCWA. The HSC requested the NFGT Forest Supervisor:
“1) Whether the spur trail in LLCWA is an official trail and is entered in the infra-trails database.”
“2) If the spur trail is entered as an official trail in the infra-trails database the HSC requests a copy of the infra-trails database information as well as the background data that documented and justified allowing this trail to be entered into this database including any NEPA documentation.”
“3) A meeting with you about implementing a NEPA process for this spur trail in LLCWA.”
“4) Alternatively, if you decide to being implementation of the NEPA process for this spur trial the HSC requests a letter documenting this and a project date when the NEPA process will begin.”
The Forest Supervisor responded on November 9, 2004 and stated:
“This user-made trail did not go through a NEPA process nor is it in the official INFRA database. However, the Sam Houston is evaluating the benefit of this trail segment. My staff is now researching the appropriate type of NEPA that should be conducted on the trail. As soon as this is determined I will contact you for a meeting.”
The HSC then wrote the Forest Supervisor and stated:
“This illegal trail, until it crosses Little Lake Creek, is sited so close to the boundary of LLCWWA that the sights, sounds, and smells of modern civilization, including motorization and mechanization, are clearly evident … The illegal trail does not protect Wilderness character which emphasizes solitude, natural sounds, and quiet. For the illegal trail to remain it would have to, in the words of the Wilderness act, Except as otherwise provided in this Act, each agency administering any area designated as wilderness shall be responsible for preserving the wilderness character of the area and shall so administer such area for such other purposes for which it may have been established as also to preserve its wilderness character.”
On December 3, 2004, the Forest Supervisor called the HSC and discussed the illegal trail in LLCWA. After that call the HSC pressed the District Ranger of SHNF about the illegal trail with a December 10, 2004 letter and an information request stated:
“I am concerned about the tenor of what I heard you say so I am sending you this letter.”
“In his November 9, 2004 letter to the Houston Sierra Club … supervisor Salinas stated that, “My staff is new researching the appropriate type of NEPA that should be conducted on the trail.” The HSC expects that this analysis will be conducted with an open mind.”
“During the phone call you asked me whether the HSC was in favor of keeping the trail or removing it. I told you that I was not sure but that the National Environmental Policy act … process and the Wilderness act should be used to determine the answer to this question. I said that the Wilderness act required that the trail be necessary for administration of the Wilderness Area. Your response indicated that you did not want to go through this process although you were still analyzing this issue.”
“You stated that the trail had been in place for 20 years. This is a statement that you did not make when the HSC met with you and Ronnie Raum six years ago. I have hiked the Lone Star Hiking Trial since the late 1970’s and in LLCWA since its establishment in 1984. Until the mid01990’s I was not aware of the existence of this trail. It appears that trail markers were not in place until the 1990’s and, as you stated in 1998, the parking lot was not constructed until 1991.”
“Supervisor Salinas has stated that the trail is not on the INFRA database and has not gone through the NEPA process. This trail is not officially part of the U.S. Forest Service trail system. In our conversation on December 3, 2004, you stated that the trail was not in the INFRA database but was on your trail map. None of the forest maps for Sam Houston National Forest that I have show the existence of this trail. The trail is not a part of the Lone Star Hiking Trail as it was constructed, completed, and turned over to the U.S. Forest Service in 1972 and 1978.”
“On behalf of the HSC I request the information that you have which documents the assertion that this trail has been in existence for 20 years. I also request the information that documents when this trail was put on your trial map and a copy of that trail map.”
The final letter that I have from this over 7-year episode is one on January 3, 2005, from the SHNF District Ranger, which stated:
“During our telephone call on December 3rd we discussed how long the trail was known to exist and I indicated it could have been 20 years from information I have received from others. We do not have dated maps or other printed documented showing this trail existed 20 years ago. First map known to include this trail was done by the Lone Star Hiking Trail Club when they GPS’d the Lone Star Hiking Trail.”
At some point after this letter was sent to the HSC, without notification to the HSC, the FS closed the trail and parking lot. For over seven years the HSC had tried to get the FS to make a decision that it hadn’t wanted to make. Now there is no illegal trail in the southern end of LLCWA and wilderness character is protected better than before.
After this date my records are incomplete and provide little information about the “Adopt-a-Wilderness” effort until April 23, 2023. The HSC submitted an email and notes on a visit to LLCWA on April 19, 2023. The report stated:
“On April 19, 2023, 9 am to 2:15 pm, the Sierra Club (Brandt Mannchen and Brandon Sanchez) visited Little Lake Creek Wilderness Area (LLCWA) in Sam Houston National Forest (SHNF) and hiked the Lone Star Hiking Trail (LSHT) from the FM 149 parking lot (Trailhead #4, southern-most parking lot, nearest Montgomery, Texas, on the east side of FM 149) across LLCWA to its western boundary.”
“The purpose of this visit was to take photos of LLCWA for Sierra Club nationally to show East Texas Wilderness as part of the 60th anniversary of the Wilderness Act for 2024 celebration and to begin a LLCWA plant list. This report provides details about the observations that were made during that visit. These observations include:”
“1) The LSHT is in poor condition in many places in LLCWA as it goes to and crosses Little Lake Creek and its tributaries. The LSHT has become a important source of eroded soil and sediment in Little Lake Creek and its tributaries in LLCWA. There are extensive areas where root systems are exposed, particularly at stream crossings, on the LSHT, which make hiking the trail and crossing the stream very difficult.”
“There are extensive areas where the trail goes through floodplains and swamps which result in compaction and puddling of soil on and off the LSHT. Boardwalks and bridges, in most places, are degraded, destroyed, or inoperable.”
“The Sierra Club will request a meeting in-the-field with the FS to view where erosion occurs and determine what options are possible. It may make sense to re-route the LSHT outside, but alongside, the boundary of LLCWA at this location to reduce or eliminate soil erosion, water quality, and biodiversity negative impacts, reduce trail maintenance costs, and make trail maintenance easier since motorized equipment is allowed outside wilderness.”
“A discussion with the Sam Houston Trails Coalition, Lone Star Hiking Trail Club, and interested members of the public is desirable to address this problem. The Sierra Club will revisit LLCWA for photos and provide those to the FS.”
“2) LLCWA has recovered well from southern pine beetle (SPB) events that occurred from the 1970’s-1990’s. The recovery of areas where SPB killed trees and the U.S. Forest Service logged or cut down trees is remarkable.”
“Most of the downed trees are either unrecognizable or can barely be seen on the forest floor. A mix of mostly hardwood trees and some pine trees has repopulated these disturbed areas. Wilderness is working well in LLCWA, where wild “Nature calls the shots” and ecological succession is moving forward!”
“3) The Sierra Club saw a group of feral hogs just north and south of where the LSHT crosses Little Lake Creek. Feral hog tracks were found on many parts of the LSHT, and feral hogs rooted up parts of the LSHT.”
“Control of feral hogs in LLCWA should be a priority because of the soil, water quality, and biodiversity impacts that have occurred due to the presence of this non-native invasive animal species. The Sierra Club supports a feral hog control program in LLCWA which adheres to Wilderness Act restrictions.”
“4) LLCWA, along Little Lake Creek and its tributaries, consists of mature and or old growth forests. The Sierra Club saw many large Green Ash, American Elm, Loblolly Pine, Sweetgum, and other hardwood trees. The trees we measured included:”
“Green Ash, 39.17 inches diameter breast height (DBH)
American Elm, 44.59 inches DBH
Sweetgum, 33.44 inches DBH”
“5) The Sierra Club heard or saw several bird species. Birds that were identified included, Red-shouldered Hawk, Pileated Woodpecker, Yellow-billed Cuckoo, Barred Owl, Red-bellied Woodpecker, and American Crow.”
“6) The Sierra Club saw three snake species. These included, Eastern Hognose Snake, Northern Cottonmouth, and Broad-banded Water-snake. We heard frogs and saw tadpoles in some of the ponds in the floodplains and saw a Green Anole.”
“7) The Sierra Club has begun a plant list for LLCWA which is included with this report. There appears to be little information on the internet about what plants grow in LLCWA. The Sierra Club will share this plant list with the U.S. Forest Service and others who are interested.”
“8) There are several plants which the Sierra Club found in LLCWA that it considers unique/unusual and that do better with the little or no groundcover compaction or human disturbance, as has occurred in LLCWA for the past almost 40 years.”
“Some of these plants are Walter’s Violet, Virginia Snakeroot, Texas Dutchman’s Pipe, Rattlesnake Fern, Green Dragon, Strawberry Bush, Black Walnut, Canadian Black Snakeroot, American Basswood, Mayapple, Partridge Berry, and Red Mulberry.”
“9) The Sierra Club looks forward to working collaboratively with the U.S. Forest Service now and in the future to ensure that LLCWA remains wild and untrammeled and that it is protected via restrictions that the Wilderness Act places on human manipulation and intrusion.”
“The Sierra Club appreciates this opportunity to provide this information and these observations to the U.S. Forest Service.”
The next section of this history, Wilderness and Hiking, provides further information about the degraded LSHT in LLCWA.
J. Sierra Club, East Texas Wilderness Areas, and Hiking Trails
The Adopt-a-Wilderness section of this history records a lot of what has occurred with trails in LLCWA. There are some additions that this section will cover about trails and ETWA.
On May 12, 1997, the HSC sent a letter to the FS about trail maintenance that had been performed on May 10, 1997 on the Richards Loop of the LSHT which stated:
“3) We are also concerned that the area used by the cattle is not far from the Little Lake Creek Wilderness Area. We do not want to have any cattle trespass problems. We want to know what barriers and measures are being taken to keep cattle out of Little Lake Creek Wilderness Area.”
Then on September 9, 1997, the HSC sent a letter to the FS concerning the upgrading and maintaining of the LSHT for its entire length including bridge repair, erosion control devices, maintenance of the treadway, and removal of limbs, branches, and shrubs that encroach on the trail. The HSC letter stated:
“While we do not have any problem with this proposal for much of the trail, the portion of the trail that lies in the Little Lake Creek Wilderness Area … must be treated differently. We are concerned, first, that LLCWA was not mentioned as being affected by this proposal. No member of the public would know about this fact based on reading the letter.”
“We are very concerned that the part of the LSHT in the LLCWA presents an extraordinary circumstance and you must at least go through the CE and decision memo process and have public scoping. We request that the part of the LSHT in the LLCWA go through this process to determine if an environmental assessment or impact statement is needed.”
The FS responded on September 11, 1997 in a letter and stated:
“The main concern appears to be whether additional public scoping and analysis should be done prior to making a decision on trail maintenance in the wilderness … My letter … was designed to inform the public that we intended to continue our regular maintenance program … As I said in my letter, any relocation of trails or bridges would require additional public involvement before a decision … I share your concern about Little Lake Creek Wilderness and the LSHT. We appreciate your comments and will keep you informed.”
Sometimes the HSC would report the results of trail maintenance on the LSHT in and near LLCWA. For instance, on June 8, 1999, the HSC reported to the FS about a May 8, 1999 trail maintenance hike:
“Six people put in a total of 48 hours of trail maintenance. The work consisted of trail clearing from the second parking lot on FM 149 (west side) in Little Lake Creek Wilderness Area to the main trail, down the main trail, and then back over on the San Branch Loop to the parking lot.”
Other times the HSC would advertise and celebrate an anniversary of the Wilderness Act. A flyer by the HSC states:
“On Sunday, January 16, 2000, the Houston Sierra Club will celebrate the New Millennium and the 35th Anniversary of the Wilderness Act with a Forest Walk through Little Lake Creek Wilderness Area … Our only wilderness in Sam Houston National Forest, LLCWA stretches along FM 149 for 3,800 acres. Little Lake creek is a beautiful example of a poorly drained creek with large Loblolly Pines, Green Ash, Hackberry, and other hardwoods. Beaver and Wood Ducks abound and the Lone Star Hiking Trail meanders through part of your wilderness.”
There was further discussion about the LSHT and LLCWA at the March 11, 2000 meeting with the FS and trail maintenance volunteers. March 17, 2000, the HSC, in a letter to the FS, stated:
“We appreciate the meeting … We covered a lot of ground and believe the meeting was helpful. We wanted to give you feedback about some of the issues that were brought up at the meeting … The Houston Sierra Club found illegal horse use on the trail … almost every time we visit LLCWA we find illegal horse use on the LSHT … The other three locations are ones where the Lone Star Hiking Trail Club would like to have logs brought into the wilderness and used as bridges … The Houston Sierra Club is not opposed to a log bridge at these locations if downed material is used from inside the wilderness and brought to the location by human power. We do not support bringing logs from outside the wilderness and do not support using mules or horses to do so. The damage would be considerable to vegetation, soil, and the trail. LLC is a wilderness. Maintaining the wilderness character of untrammeled Nature must come before recreational needs. Wilderness provides a challenge … We did see downed material … that could be used to bridge the mud here. However, this material may wash away during floods … Please note that illegal horse use has made trail conditions far worse with regard to holding water on the trials and making walking on the LSHT very uneven and difficult … This crossing would require a 30 foot log (we measured the distance across the creek). A log of this size brought into this location would cause considerable damage to the trail and vegetation. It may be feasible to lay additional downed material from inside the wilderness on top of the existing material … Again, when floods occur this material could be swept away. Crossing here will be a continual problem. At some point it may make more sense to route the LSHT out of this part of LLCWA to avoid the constant water and mud problems.
The conflict between wilderness and its untrammeled condition and the recreational desires of hikers has continued to the present.
On March 19, 2001, in a letter to the FS, the HSC stated:
“We conducted trail maintenance along two miles of LSHT in the Little Lake creek Wilderness Area … We found illegal horse use on the LSHT where it is joined by the old pipeline ROW … We urge that you obliterate this old pipeline ROW, fence it off so that no further illegal horse used occurs, and put signs up to make it very clear that horse use at this location is not appropriate … At the intersection of Bethel Road and Little Lake Creek erosion is scouring out large areas around the culvert … this sediment is being deposed in LLCWA and is increasing the turbidity and scouring out the sides and bottom of the creek as it travels down Little Lake Creek … We are very impressed at the natural pine and hardwood regeneration that is occurring in the upper part of LLCWA. Hardwood structure is being created after 17 years with little or no logging. The many small pines that have regenerated make this an excellent area to study how natural regeneration occurs for Loblolly Pine.”
Another letter on May 15, 2002, reported on a May 11, 2002 trail maintenance hike where illegal horse use on the LSHT was found again:
“We found illegal horse use along the trail. There was extensive compaction, trail widening, and puddling on the LSHT which made it very difficult to use. We urge the Forest Service to make a special effort to catch those who degrade and destroy the LSHT in LLCWA.”
In recent years problems continued. On June 12, 2023, the HSC sent a letter to the District Ranger, SHNF, which stated:
“On June 10, 2023, the Houston Sierra Club hiked in Little Lake Creek Wilderness Area (LLCWA) on the Lone Star Hiking Trail (LSHT) in Sam Houston National Forest. This is the part of the LSHT that starts from Trailhead parking lot #4, at FM 149, and goes east through the southern part of LLCWA.”
“The photos we took (attached) document that the LSHT, at a considerable number of locations, is in poor condition. This is particularly true at its intersection with streams. There is significant soil erosion due to rainfall runoff which carries sediment into streams and causes water quality degradation. The trail has been captured by runoff (probably exacerbated by climate change) and acts as a drainageway into natural streams.”
“There are extensive areas where erosion has uncovered tree root systems. This has made hiking difficult and more dangerous due to slipping and tripping hazards. Small bridges that were used to cross extensive wet floodplain areas, have been destroyed over time via floods and due to a lack of appropriate trail maintenance.”
“There is also a rerouted part of the LSHT that apparently didn't undergo National Environmental Policy Act (NEPA) analysis when the reroute was conducted, which should be addressed. This reroute is where the LSHT used to cross Pole Creek. The LSHT now has been rerouted to parallel Pole Creek until it leaves LLCWA at a U.S. Forest Service (FS) road (near a primitive campsite), crosses Pole Creek outside LLCWA, and then reenters LLCWA on the west side of Pole Creek.”
“The result of all of these actions is a degradation of wilderness character and a reduction in hiking experience. LLCWA is an area that is supposed to have little or no footprint of human presence.”
“There are various ways to address these problems. Some of these options include:”
“1. Rerouting the LSHT out of this part of LLCWA.”
“2. Conducting extensive restoration of the existing LSHT path (done in accordance with wilderness restrictions for trail management).”
“3. Realigning the LSHT in certain areas in LLCWA.”
“4. Rerouting the LSHT out of LLCWA and then relocating it in areas of LLCWA where there is less conflict with water flows.”
“All of these alternatives will create challenges particularly with the preservation of wilderness character (untrammeled nature).”
“It's the Sierra Club's contention that the poor condition of the LSHT in LLCWA make this a priority issue for the FS (and a priority trail management issue) because of its presence and impacts in wilderness. The 1996 Revised Land and Resource Management Plan, Management Area 7, Wilderness, Trails Management, Standard/Guideline, MA-7-127, states, "Trails are designed, constructed, reconstructed and maintained to the standard necessary to minimize or prevent resource damage, to protect visual quality, and for the safety of visitors." The LSHT, currently, in this part of LLCWA, doesn't meet this standard and degrades LLCWA.”
“The Sierra Club would like to begin, with the U.S. Forest Service and other interested persons or groups, collaborative discussions about what to do about the LSHT in this part of LLCWA. Continued allowance of the degradation of LLCWA by the LSHT will result in further damage to water, soil, wilderness character, solitude, wildlife, and other values in LLCWA. In the Sierra Club's view, this is not an acceptable option.”
“Please let me know when we can talk about this issue and begin to prepare a plan for its resolution.”
“Thanks for your help”
Human problems are endless in wilderness. Humans just can’t keep their hands off wilderness and let it be what it will be. Onward toward enlightenment and humility!
K. Sierra Club, East Texas Wilderness Areas, and Monitoring
Monitoring the health of wilderness is another issue that management must address. Wilderness and fire monitoring was addressed in detail above in the “East Texas Wildernesses and Fire” section of this history.
August 28, 2002, the HSC provided input to Wilderness Watch about a draft “A Protocol to Monitor and Evaluate Wilderness Character”, U.S. Forest Service Wilderness Monitoring Committee. Some quotes from that letter include:
“The FS states that “wilderness management often requires significant tradeoffs”. This type of talk bothers me. I hope it was said with great understanding and concern about Wilderness. I do not believe there are many tradeoffs if you stick to the Wilderness Act.”
“Untrammeled”, the “generally” in the last sentence bothers me. How much “generally” is allowed? The FS needs to define this term along with “minimal”, “substantially”, “unintentionally”, and “experiences”. Why can we not keep more to the language of “solitude and primitive and unconfined type of recreation” and the ability to have quiet and hear natural sounds? Again I feel a sense of unease because the words are not defined. I call these words “weasel words” because they can mean anything to anyone. We need more specific definition and we need to leave nothing up to chance when it comes to clarifying and or defining Wilderness character.”
“Untrammeled” table, Core Monitoring Variable, listing all of these possible manipulations makes me very nervous. I do not agree that most of these can be used in Wilderness. For instance, biocontrol agents, herbicides to reduce fire fuels, control of insects, management ignited fire, and seeding or planting non-native plant species for restoration do not seem to me to be allowed under the Wilderness Act. I am particularly amazed that the FS says that non-native plants can be planted for “restoration”. If the plant is non-native how can it be part of restoration. This includes rye grass for erosion control. There seems to be a strange dichotomy here and a contradictory undertone in this document that shows confusion about what Wilderness is.”
“I am concerned that this protocol is too indefinite. It contains as many weasel words as a typical FS prescription. In other words, by following this protocol the results could be very good or they could be very bad. The protocol is too flexible and allows for too much interpretation of the arbitrary and capricious variety. The FS can do better than this!”
In the Fall of 2014, the LSC attended the 50th Anniversary Wilderness Conference. A presentation was made about a monitoring survey that the FS had conducted on all wilderness areas in the United States.
After returning from that conference, in December the LSC contacted the Forest Supervisor, NFGT, and requested information about the monitoring conducted on the five East Texas Wilderness Areas. In December 2014, the FS sent the LSC some of the documents that were used for the monitoring survey of ETWA.
On January 4, 2015, the LSC/HSC sent Mark Van Every, Forest Supervisor, NFGT, a letter which stated:
“Enclosed are the initial comments of the Houston Regional Group and Lone Star Chapter of the Sierra Club (Sierra Club) regarding the U.S. Forest Service (FS) “Wilderness Areas Managed to Minimum Stewardship Level” for the five East Texas Wilderness Areas (Upland Island, Turkey Hill, Indian Mounds, Big Slough, and Little Lake Creek) found in the National Forests and Grasslands in Texas (NFGT).”
“The Sierra Club has not received all of the background information for all ten of the elements that was used to define and score “Wilderness Areas Managed to Minimum Stewardship Level”. The Sierra Club will work with Ms. Nancy Snoberger of your staff to obtain this information. The Sierra Club will then provide you with additional input. This letter responds to the information that the Sierra Club does have and requests information about the other elements that it does not have.”
“This letter reviews each element of the “Wilderness Areas Managed to Minimum Stewardship Level” and the response by the NFGT and makes comments or asks questions. A meeting with you and or your staff about how the scores were derived and future tracking of the 10 elements would be helpful. At the end of this letter will be a request for information based upon what was used by the FS to score each element of the “Wilderness Areas Managed to Minimum Stewardship Level”.”
“1) Element 1, Wilderness Fire Management”
“This “Vegetation Manipulation” section mentions wilderness on page 22 as follows: “Prescribing fire in some wildernesses for fuels reduction and maintenance of fire-dependent ecosystems … use of fire in wildernesses is provided with the development of burning plans that would amplify the natural fire processes that have not been allowed to develop since establishment.”
“Responses that the Sierra Club wants from the FS about this element include:”
“Should wilderness be managed for “Vegetation Manipulation” when the Wilderness Act requires that wilderness be “untrammeled”?”
“Which specific wildernesses (the quote says “some wildernesses” so the assumption is that prescribed fire will not be used for all five wilderness areas) will prescribed fire be used for fuels reduction and or maintenance of fire-dependent ecosystems? The Sierra Club is aware of the prescribed fire plans for Upland Island Wilderness Area but not for the four other wilderness areas.”
“What specific parameters (prescription) will be used to allow wildfire (whether of lightning or human origin) to burn in the five wilderness areas?”
“What is the specific Fire Management Plan for each of the five wilderness area?”
“What is the prescribed fire action plan for each of the five wilderness areas that identifies the specific areas where prescribed fire can be applied to reduce fuel loading so that outside resources many be protected and maintain a fuel level that would allow fire to play its natural role (page 183, MA-7-47)?”
“Has the FS implemented and evaluated the effectiveness of the Fire Management Plans for each of the five wilderness area? If so, what are the results and if not when will this occur?”
“2) Wilderness Non-Native Invasive Plant Species (NNIPS)”
“This element refers to surveys and management actions that occurred in 2008 and 2012. Responses that the Sierra Club wants from the FS about this element include:”
“What were the results of the survey for NNIPS in each of the five wilderness areas?”
“What specific management action(s) was taken in each of the five wilderness areas and what were the results (evaluation) of that action(s)?”
“What are the highest priority areas for treatment in each of the five wilderness areas?”
“3) Wilderness Air Quality”
“Responses that the Sierra Club wants from the FS about this element include:”
“What type of specific air monitoring (air pollutants, air pollutant damage, etc.) was conducted within or next to each of the five wilderness areas?”
“What were the results of the air monitoring that was conducted within or next to each of the five wilderness areas?”
“What future air monitoring will be conducted within or next to each of the five wilderness areas?”
“When will the NFGT conduct an inventory for priority sensitive receptor for each of the five wilderness areas?”
“What sensitive receptors are there for each of the five wilderness areas?”
“When will the NFGT establish a baseline for priority sensitive receptors for each of the five wilderness areas?”
“When will the NFGT monitor for priority sensitive receptors for trends for each of the five wilderness areas?”
“4) Wilderness Education”
“Responses that the Sierra Club wants from the FS about this element include:”
“What local conservation education programs at local events and through District programs have been given for each of the five wilderness areas?”
“What priorities identified in the wilderness education plan have been implemented and what priorities have not, and why not for each of the five wilderness areas?”
“When will the wilderness education plan be fully implemented for each of the five wilderness areas?”
“When will an evaluation to determine the effectiveness of the activities of the wilderness education plan be done for each of the five wilderness areas?”
“How long will it take to make any modifications to the wilderness education plan after the evaluation has been done for each of the five wilderness areas?”
“5) Wilderness Solitude or Primitive and Unconfined Recreation”
“Responses that the Sierra Club wants from the FS about this element include:”
“What is the NFGT protocol to inventory conditions in each of the five wilderness areas relative to opportunities for solitude or primitive and unconfined recreation?”
“What specific conditions are being monitored in each of the five wilderness areas for solitude or primitive and unconfined recreation?”
“Have any management actions been taken in each of the five wilderness areas to reduce unacceptable levels of degradation and if so what have the results been?”
“Have any trends occurred for specific conditions that are being monitored for each of the five wilderness areas and what are those trends?”
“Have any conflicts between wilderness activities been found in each of the five wilderness areas and if so how were these conflicts resolved?”
“What predetermined standards over what time and space are being monitored for each of the five wilderness areas?”
“The Sierra Club is concerned that “adequate direction” provided to protect opportunities for solitude or primitive and unconfined recreation may not be provided by the NFGT since group size, encounters, carrying capacity, access management direction for trail classes and management objections, length of stay limits, campsite location, quotas/permit requirements, and presence of permanent improvements or evidence of modern human occupation requirements or limitations are not implemented in each of the five wilderness areas.”
“Minimum Protocol Campsite Inventory of East Texas Wilderness Areas”
“The Sierra Club appreciates that the FS sent it the “Minimum Protocol Campsite Inventory of East Texas Wilderness Areas”, September 8, 2014. There are several comments the Sierra Club wants to make about this document:”
“Not all social impacts were covered or analyzed completely in the inventory. For instance, noise, vandalism, flagging, and social trails either are not assessed and analyzed or are given no score or a low score in the inventory.”
“The campsite inventory, therefore, was not indicative of and does not fully determine all the social impacts and protections needed for solitude or primitive and unconfined recreation.”
“Social trails, which can have significant cumulative impacts on soils, vegetation, solitude, natural sounds, quiet, wildlife disturbance, illegal motorized access, poaching, hunting, etc., are apparently not viewed as impacts or are viewed as lesser impacts than campsites because they are given no scores in the campsite inventory, even though without social trails there would be no campsites. Therefore the scores for campsites only (apparently) for the five wilderness areas are too high (too optimistic) given the total social impacts that occur due to social trails and other human impacts in the five wilderness areas.”
“It is of concern that the report suggests repairing a culvert in wilderness (page 3). A culvert is a human created permanent improvement or structure, that should not be in wilderness. If the culvert cannot be removed in a non-motorized way, then it should be left to degrade over time. The report fails to mention the erosion on the trail (what the report calls CR 348B which is a road number and is which is no longer a road but has been wilderness for 30 years) that is clearly depicted in Figure 1 as a environmental impact of the social use of this area.”
“The report refers to “feral hogs” (page 3) as a “severe safety risk” for visitors. The Sierra Club does not view “feral hogs” as any more a severe safety risk for visitors as other non-native animals or native wildlife. People have to approach wilderness in a different manner where they are not in control and they need to adapt to the conditions of wilderness and not the other way around. The Sierra Club has hiked in all five wilderness areas and in many places in the four national forests in Texas and does not consider “feral hogs” a “severe safety risk” for people. The “feral hogs” the Sierra Club has seen or heard have almost 100% of the time run away before being seen. Removal of a non-native animal would be beneficial for wilderness as long as it is done in a manner that is consistent and complies with the Wilderness Act.”
“Page 4, in reference to Indian Mounds Wilderness Area, since garbage is a problem (see pages 4 and 9) it would have been helpful for the authors' of the report to provide recommendations about how to deal with garbage dumping and removal of existing garbage which would be consistent and complies with the Wilderness Act.”
“Pages 5 and 12-17, the report should not include campsite inventories for Indian Mounds Recreation Area, which is outside the wilderness area. If this is to be done then the title of the report should be changed. The report is supposed to be about the condition of campsites within the five wilderness areas.”
“If one of the problems is the use of the Indian Mounds Recreation Area as a trash dump and if this recreation area is being vandalized or in other ways degraded then recommendations are needed to address this problem. Some recommendations to resolve this problem are additional law enforcement, closing the recreation area, education of the public about the problem, and holding a town hall meeting to discuss the problem and get public input.”
“Page 5, discusses three social campsites in Little Lake Creek Wilderness Area (LLCWA). There is a reference to downed trees at a stream crossing and that these make progress difficult. It is hard to know if the report's authors are referring to campsites within LLCWA or outside of it on the Lone Star Hiking Trail (LSHT). It would be helpful if the authors of the report would clarify this with a map. In addition, the discovery of a horseback trail that parallels the LSHT in LLCWA and that is not a designated trail means that a significant human impact has occurred in this wilderness. The existence of this horseback trail should affect, but apparently does not, the scoring in the report for LLCWA and the “Wilderness Areas Managed to Minimum Stewardship Level”. All social impacts found in each of the five wilderness areas should be factored into the scoring for this element and the next element, Wilderness Recreation Site Inventory to ensure an accurate and complete analysis, evaluation, and assessment.”
“Pages 10-17, the ratings do not make sense. For instance, there is no scoring for litter, human waste, noxious/exotic weeds, user created trails, and user created structures. For litter, the word “Some” or “Abundant” is used but there is no scoring for this degradation of wilderness. User Created Tails are acknowledged with a “Yes” or “No” and there is no score.”
“Pages 18 and 19, the authors state that “... some trails are becoming indistinguishable. These sites could benefit from clearing the trails”. The report suggests that trails should be maintained in the five wilderness areas when people are not using these trails. This recommendation is antithetical to wilderness as expressed in the Wilderness Act which focuses on minimizing or eliminating human impacts (trammeling). The report's authors state “This could also aid in keeping established trails intact and free from overgrowth preventing additional social trails.”
“It is the Sierra Club's understanding that the only “established trails” in the five East Texas Wilderness Areas are the LSHT in LLCWA and the 4 C's Trail in Big Slough Wilderness Area. Therefore all the other trails that the authors refer to are not “established trails but are social trails. No trails can be established in these five wilderness areas without documentation that they are required to manage and protect wilderness. Creating more established trails or keeping social trails open in the five wilderness areas is not necessary. As mentioned previously so-called designated or established trails are either social trails or former roads that are not designated trails and should be allowed to naturally be restored to forest and should not be maintained and kept open.”
“Page 19, the Sierra Club agrees that larger wilderness areas would be beneficial and would support a study, with public input, where expansion of the five wilderness areas might occur. Additional wilderness areas, for example in Sam Houston National Forest, Big Creek Scenic Area, and Winters Bayou Scenic Area, are also a desirable option.”
“6) Wilderness Recreation Site Inventory”
“Responses that the Sierra Club wants from the FS about this element include:”
“When will a complete (not partial) recreation site inventory be done for all five wilderness areas?”
“When will a recreation site inventory plan be completed for all five wilderness areas?”
“When will a recreation site monitoring protocol be done for all five wilderness areas?”
“What is he name of the protocol for all five wilderness areas?”
“When will all likely sites be assessed for all five wilderness areas?”
“What is the most recent fiscal year that data has been entered for all five wilderness areas?”
“When will an analysis of the recreation site inventory be conducted for all five wilderness areas?”
“Will the public have input into the inventory, monitoring, analysis, and plan for all five wilderness areas?”
“7) Wilderness Outfitter and Guides”
“Responses that the Sierra Club want from the FS about this element include:”
“When will the FS assess again whether an outfitter/guide operating plan is needed for the five wilderness areas?”
“8) Wilderness Degradation”
“Responses that the Sierra Club want from the FS about this element include:”
“How does the FS use, in combination, the LAC, campsite inventories, and NVUM data, as a protocol to inventory conditions to prevent degradation of the five wilderness areas?”
“What conditions are used to inventory and evaluate degradation of the wilderness resource to develop direction in the five wilderness areas?”
“What appropriate protective measures (RLRMP, Page 187, MA-7-84) will the FS require to explore and develop mineral rights in the five wilderness areas?”
“What trails have been constructed or maintained beyond wilderness standards before wilderness designation (RLRMP, Page 190, MA-7-132) have been allowed to return to appropriate standard through natural processes in the five wilderness areas?”
“How has adequate direction been established in the RLRMP in the five wilderness areas when it does not address noise, quiet, natural sounds, social trails, and other impacts?”
“What conditions are monitored for changes to the wilderness resource according to RLRMP schedule in the five wilderness areas?”
“What schedule is used for wilderness condition monitoring for the five wilderness areas?”
“Have any unacceptable levels of degradation been found in any of the five wilderness areas?”
“What appropriate management actions have been taken to reduce unacceptable levels of degradation in the five wilderness areas and are the conditions stable or improving?”
“9) Wilderness Data Collection”
“Responses that the Sierra Club want from the FS about this element include:”
“What is the documented data collection protocol that is used to hold inventory and monitoring data collected in the file to address priority management issues in the five wilderness areas?”
“How many and what are the conditions or wilderness resources that the data collection system holds data on for the five wilderness areas?”
“How many and what analyses of inventory and monitoring data have been conducted in 2011, 2012, 2013, and 2014 for the five wilderness areas?”
“How many local decisions were made based upon analysis of inventory and monitoring field data collected for the five wilderness areas?”
“Has mandatory upward reporting data been entered completely and accurately into Infra-WILD by the due date for the five wilderness areas?”
“Was a structured information needs assessment completed and is it being used to provide direction for local data collection, storage, and analysis activities for the five wilderness areas?”
“What were the results of that information needs assessment for the five wilderness areas?”
“10) Wilderness Baseline Workforce”
“Responses that the Sierra Club want from the FS about this element include:”
“What does the 0.95 baseline workforce target, 0.15 baseline workforce, and 15% percent of baseline workforce equate to in FS personnel providing oversight in the field at the five wilderness areas?”
“How and within what time-frame will the FS meet the 50%, 70%, 100%, or 125% baseline workforce targets in the future for the five wilderness areas?”
The Sierra Club then requested additional information about the wilderness monitoring including:
“1) Element 1, May 20, 1987, “Fire Land Management Plan”; “Wilderness Checklist for Fire Management Plans”; and Letter Re 2320, October 7, 2010, Wilderness Response Plan”
“2) Element 2, 2008 survey for non-native invasive plant species in the five wilderness areas and 2012 Annual partnerships and Challenge Cost Share Agreements with local university to treat NNIPS”
“3) Element 3, March 8, 2010 “Air Quality Values Monitoring Plan”, NFGT”
“4) Element 4, December 5, 2007, “Wilderness Education Plan for the NFGT”
“5) Element 5, 2003 LAC; 2008 NVUM; 2011 Campsite Inventory”
“6) Element 6, 2011 partial recreation site inventory via “Participating Agreement” with local University (09-PA-110813-003); 2013 recreation site inventory”
“7) Element 7, November 2011 needs assessment for outfitter/guides operating plan”
“8) Element 8, 2007 fiscal year inventory; LAC's; campsite inventories; and NVUM data”
“9) Element 9, 2011 fiscal year inventory or monitoring and local database of recreation camp site monitoring”
“10) Element 10, Baseline workforce target; workforce (FTEs); and % of baseline workforce background information”
The NFGT Forest Supervisor didn’t respond to the January 2015 LSC letter. The LSC didn’t follow-up until February 24, 2016, when an email was sent to the Forest Supervisor, NFGT, stating that the January 4, 2015 letter hadn’t been responded to and the questions and information requested hadn’t been answered or sent.
The NFGT Forest Supervisor responded and stated, “I will work with our staff to gather the info and get it to you. I am still traveling and unable to open the zip file on my phone, so will call you next week.”
The LSC heard nothing from the Forest Supervisor and so April 9, 2016, sent an email which stated, “I have not heard from you about this. Please let me know.”
A phone conference was set up for April 20, 2016 with NFGT staff about the questions to be answered and the information to be provided. The phone conference was held, and additional information was sent to the LSC on April 20, 2016, April 25, 2016, April 27, 2016, and April 29, 2016.
This search for information was not entirely successful. At the end of the search the LSC was convinced that the monitoring presented by the NFGT wasn’t completely accurate and that its questions had either not been answered or had been answered incompletely.
The FS prepared a document for wilderness monitoring. Initially this document was entitled, “Keeping it Wild”, also known as “Keeping It Wild 1”. After several years the FS revised this document and now the document is called, “Keeping It Wild 2: An Updated Interagency Strategy to Monitor Trends in Wilderness Character Across the National Wilderness Preservation System.”
This document was published in 2015 and was prepared by Dr. Peter Landres, et. al. Several organizations and individuals contacted the FS and pointed out problems with “Keeping It Wild 2”.
September 15 2015, a critique of the interagency strategy to monitor trends in wilderness character was published and submitted to the FS. This document was entitled, “The Definition of Wilderness Character in “Keeping It Wild” Jeopardizes the Wildness of Wilderness”, and was prepared by David, Cole, Ed Zahniser, Doug Scott, Roger Kaye, Kevin Proescholdt, and George Nickas. These long-time wilderness researchers and advocates stated:
“We must remember always that the essential quality of wilderness is its wildness”, Howard Zahniser”
“… the future of our wilderness system is dependent on how wilderness character – something that is not explicitly defined in the Act – is interpreted.”
“KIW2 defines wilderness character … We have little problem with this. However, this conceptual definition is not used either in the KIW2 monitoring framework or as a guide to making wilderness stewardship decisions … These five qualities … they are considered to be equal in importance and often in conflict with each other … making the concept of wilderness character internally contradictory rather than a single coherent stewardship goal.”
“We disagree. The purpose of the mandate to protect wilderness character above all else is to focus the attention of wilderness stewards on preserving the “essence” of wilderness – those qualities that are most unique and distinctive about wilderness and make it “a contrast with those areas where man and his own works dominate the landscape” … For this purpose, wilderness character must be defined as a coherent whole, in a manner that is not internally contradictory. It cannot be broken down into separate qualities.”
“We believe that wilderness character is fundamentally about wildness and that it should be defined as the degree to which wilderness is free from deliberate human modification, control, and manipulation of a character and scope that hampers the free play of natural ecological processes.”
“The five-quality KIW2 definition confuses wilderness character with a list of all the things we value in wilderness and would like to protect and preserve … this definition negates the intended purpose and meaning of wilderness character. Most onerously it undervalues the importance of protecting wildness … wildness cannot be emphasized when it is just one of many values that manages might protect.”
“… our concerns about the inappropriate KIW2 definition of wilderness character have grown, as those who developed it have promoted its use – not just as a monitoring framework – but as the basis for wilderness stewardship … Without meaningful public involvement, the agencies charged with wilderness management have incorporated the five-quality definition into their stewardship policy and guidance and it has been incorporated into stewardship decision making processes such as the Minimum Requirements Decision Guide … Of particular concern is the internally contradictory nature of the KIW2 framework, which makes it acceptable to trade-off degradation of a quality such as “untrammeled” for improvement in another quality such as “natural.”
“In this article, we provide a more appropriate definition of wilderness character … arguing that our definition is more consistent with the Wilderness Act”.
“… This reflects our belief that wilderness character is more useful as an overarching principle to guide stewardship decisions than something tangible that can be meaningfully assessed and monitored. When it comes to assessing the success of wilderness stewardship, it is better to monitor a range of wilderness conditions … So-called wilderness character monitoring should simply be recognized for what it is – a protocol for comprehensively monitoring conditions in wilderness – and labeled more appropriately.”
“An Appropriate Definition of Wilderness Character”
“Wilderness character is fundamentally about wildness. It should be defined as the degree to which wilderness is free from deliberate human modification, control, and manipulation of a character and scope that hampers the free play of natural ecological processes … Manipulations where the intent is more to remove evidence of humans than to intervene in ecological processes, such as restoration of an impacted campsite, are not a concern. Actions that seek to modify wilderness ecosystems significantly, such as a program of herbicide spraying or prescribed fire, are much harder to justify because they degrade wilderness character.”
“Our rationale for asserting that wilderness character should be defined as wildness, as opposed to all five of the wilderness values in the KIW2 definition, reflects our belief that wilderness character is the essence of wilderness – not everything about wilderness. It is also consistent with our believe that wilderness character must provide an internally consistent stewardship goal, rather than consist of separate qualities that conflict with each other, forcing stewards to choose which qualities of wilderness character to protect.”
“Wilderness Character is the Essence of Wilderness – Not Everything about Wilderness”
“… what is most unique and distinctive about wilderness is its wildness, particularly its untrammeled conditions … But outside wilderness, few public lands are deliberately administered with humility and restraint, as the last places that lie “beyond the control of human institutions and cultural imperatives … as places where even the goal of restoring degraded ecosystems is not a sufficient justification for human control and manipulation.”
“We have already noted that the most unique and distinctive attribute of wilderness – the greatest contrast between wilderness and other public lands – is its wild and untrammeled nature.”
“Subsection 2(c) of the Act contains two sentences that define wilderness. The first, “A wilderness, in contrast with those areas where man and his works dominate the landscape, is hereby recognized as an area where the earth and its community of life are untrammeled by man, where man himself is a visitor who does not remain” ... a second sentence was added … it was added “in response to requests for additional and more concrete details in defining areas of wilderness … This sentence includes undeveloped Federal land without permanent improvements of human habitation”, “imprint of man’s work substantially unnoticeable,” “outstanding opportunities for solitude or a primitive and unconfined type of recreation,” and other features of value … stated that the first sentence describes the nature of wilderness as an ideal concept while the second sentence provides practical detail on areas that should be considered for wilderness designation …”.
“The two sentences that define wilderness have different functions. The first sentence defines what wilderness should ideally be, what stewardship hopes to attain or maintain; the second sentence defines characteristics that wilderness lands may have. Where we differ from KIW2 is in our contention that the sentence that defines the ideal is more relevant than the second sentence to understanding what Congress considered the essence of wilderness to be – to an appropriate definition of wilderness character – land where humans do not dominate, that are untrammeled and without human occupation.”
“… Howard Zahiser … In the only explicit statement of what wilderness character is, he explained at one of the final hearings on the bill:”
“In this definition the first sentence is definitive of the meaning of the concept of wilderness, its essence, its essential nature – a definition that makes plain the character of lands with which the bill deals, the ideal. The second sentence is descriptive of the areas to which this definition applies – a listing of the specification of wilderness areas; it sets forth the distinguishing features of areas that have the character of wilderness … The first sentence defines the character of wilderness, the second describes the characteristics of an area of wilderness …”.
“Wilderness Character Should be Defined in an Internally Consistent Manner”
“… That is why we have developed a definition of wilderness character – with its emphasis on the complementary attributes of wildness, untrammeled and undeveloped – that is internally consistent … Wilderness stewards have a complex job that can involve deciding among competing wilderness values, but those choices should not be internal to the overriding principle guiding wilderness stewardship, the preservation of wilderness character.”
“However, natural can be defined in multiple ways … It can be considered equivalent to untrammeled and means not deliberately controlled or manipulated by humans. Alternative, it can be defined, as KIW2 does, to be equivalent o undisturbed rather than untrammeled.”
“Interpreting natural to mean undisturbed instead of untrammeled violates several rules of statutory construction … “Terms in a statute should not be interpreted so as to create contradictions with other terms … whenever it is possible toa void them using another reasonable interpretation based on a plain reading.” For the Wilderness Act, this means that “natural conditions” must be defined – as it can be – in a manner that supplements rather than contravenes the requirement that wilderness retain its untrammeled wildness.”
“This is why Gordon Steinhoff recently concluded that “the Wilderness Act does not present managers with conflicting requirements, … and that the dilemma (managers find) within the Act – to either maintain wildness or restore naturalness – arises only because “natural conditions” has been misinterpreted …”.
“Wilderness character, defined as we suggest, provides a single coherent stewardship goal – most succinctly stated as the protection of wildness. That said, we consider wildness to be consistent with both the untrammeled and undeveloped qualities of KIW2 … and even with naturalness, defined properly to mean not deliberately controlled or manipulated by humans … The other qualities that define wilderness, such as outstanding opportunities for solitude or a primitive and unconfined type of recreation are important characteristics of wilderness that should be protected to the extent that doing so does not have substantial adverse effects on wilderness character.”
“Wilderness Character and Wilderness Stewardship”
“They are supposed to protect wilderness qualities that are important but not central to wilderness character … Where these can be provided for and protected without substantial adverse effect on wilderness character, managers are required to do so.”
“We have heard concerns that, with our definition of wilderness character, wilderness managers would be unable to actively manage wilderness … Nothing could be further from the truth. While we advocate caution and restraint – particularly with the reintroduction of a species – such actions are entirely appropriate if they are not “of a character and scope that hampers the free play of natural ecological processes … Our perspective is more at odds with the traditional management ethos – one that emphasizes doing things and in which there is no reward for inaction.”
“Conclusions and Recommendations”
“Our greatest concern with how KIW2 conceives of wilderness character is that it bolsters the innate desire of managers to act – to manipulate and control. By making protection of the wild and untrammeled just one of five qualities of wilderness character – rather than the overriding quality of wilderness character - it negates the strongest argument that can be made against constant action and intervention in wilderness.”
“Rather than being holistic, wilderness character is divided in a reductionist manner into five qualities, each of which is monitored and evaluated separately.”
“… the Minimum Requirements Decision Guide … this analysis is conducted by individually (rather than holistically) evaluating each of the five quantifiable quality of wilderness character (none of which reflect the host of intangible values), deriving summary ratings based on trading off these qualities, as if they were of equal importance. This makes it easy to justify an action that degrades wildness but benefits several of the values less central to wilderness character. In this manner, actions that degrade what is most unique and distinctive about wilderness are encouraged – not by managers abusing the process, but by managers following an inappropriate process based on a misinterpretation of wilderness character. The inevitable result is degradation of wilderness character and harm to Wilderness.
“… In fact, by doing so they defeat the purpose of the concept of wilderness character, which is to identify the most distinctive and important of wilderness conditions and values, those to be given preference when it is not possible to simultaneously protected all values. Given our concerns, we have two important recommendations.”
“KIW2’s five-quality definition of wilderness character should be replaced with a definition centered on the concept of wildness. We suggest defining it as the degree to which wilderness is free from deliberate human modification, control and manipulation of a character and scope that hampers the free play of natural ecological processes … The five qualities, properly defined, can be maintained as a useful vocabulary for talking about the conditions wilderness stewards are required to protect, but everyone must understand that they are not all qualities of wilderness character … Since these five qualities of wilderness character have already been incorporated into agency policy, agency reports and plans and wilderness training materials, this must involve more than simply revising KIW2.”
“The program of comprehensive wilderness monitoring begun a decade ago … should continue … The protocol needs an accurate name, perhaps “wilderness condition monitoring.” The output of monitoring should be more appropriately referred to as trends in wilderness conditions, trends that reflect the success of wilderness stewardship, including the protection of wilderness character. Narratives that describe the special values of each wilderness … can be retained, but they are wilderness value narratives not wilderness character narratives. Again, wilderness character has been confused with the list of values that management wishes to protect in wilderness.”
The LSC also submitted comments to Dr. Peter Landres, Research Ecologist, Aldo Leopold Wilderness Research Institute, about KIW2. Some of the comments provided by the LSC in a letter on March 16, 2016 included:
“1) First, I appreciate all that you … the entire Interagency Team (IT), have done. I know this is difficult and oftentimes a thankless task. The agencies must work together to protect and preserve “Wilderness” or we will have it “in name only”. I am glad that everyone is working together. I hope this continues.”
“2) One of the concerns that I have is that “Wilderness Character” monitoring (WCM) does not occur in all National Forests. I have seen no WCM in the National Forests and Grasslands in Texas. I will push hard during the upcoming Land Management Process … for WCM in the five East Texas Wilderness Area”.
“3) … I am very concerned about the ability of agencies to ensure “national consistency”. With all the National Forests … we are talking about hundreds of line officers and their staffs that must implement WCM. “Simplicity” must be a key factor if “national consistency” is to be attained.”
“I am concerned that the proposed WCM is too complex and multifaceted to implement with a great deal of “national consistency”. I know how much National Forests and other agencies have had their budgets and personnel rosters slashed … If there is any hope for implementation of WCM it must lie within a context that is simple, easy to understand, and take a minimum of time to do.”
“One way simplification can occur is in the definition of “Wilderness Character” (WC). It is my believe that the IT has over complicated the definition of WC and perhaps misapplied it in certain circumstances.”
“I find it ironic that the IT is still confounded about the untrammeled (wild) versus natural argument. It seems obvious to me that is humans remain humble and restrained and reduce their activities so that “Wilderness” is uncontrolled, unmanipulated, unimpeded, unshackled, unconfined, unhampered, free, and uninhibited (whether on purpose or not) that “Wilderness” will be what Howard Zahniser and others saw it to be when the wilderness bill was first drafted.”
“It almost seems as if the IT and Dr. David Cole have changed places. Dr. Cole used to insist that there was a dichotomy between untrammeled and natural. Now he comes down on the untrammeled side with regard to WCM. Now the IT seems to emphasize the conflict (which I believe is an illusion) and insists that untrammeled and natural are in conflict.”
“I believe the defining meaning of WC is “untrammeled” (wild), in part because Zahniser and others who drafted the bill and fought for “Wilderness” said so in their writings and because no other law has the “untrammeled” requirement. There was a reason Zahniser used “untrammeled” and the conservation community agreed with him after he explained about its importance.”
“We do not need five qualities of “Wilderness” when “untrammeled” contains within it natural, undeveloped, solitude and primitive and unconfined recreation, and the other values mentioned in this document”.
“It almost seems like the definition for WC has been broadened so much by the IT that by substituting five qualities we start to allow anything by finagling with what these qualities mean and what they will allow in “Wilderness”.
“4) … I see trouble when the document says “The same set of indicators applies nationwide to all wildernesses managed by all agencies” but then states “Each agency has the responsibility to develop its own procedures to ensure implementation of this monitoring strategy.” This is a recipe for “variation” when you want “national consistency”.
“5) … I believe it is misleading to say that “This uniqueness means that it is inappropriate and misleading to compare wilderness character from one wilderness to another”. I understand that each “Wilderness” is unique, however if we are to have a “National Wilderness System” then we need to be able to determine how the different agencies are doing in different parts of the country and in different ecosystems with WCM. Comparisons, as long as we understand that each “Wilderness” is a different ecosystem location, are helpful and are needed to determine how the entire “National Wilderness System” is doing.”
“6) … I believe that a 5-year time period between WCM will ensure that damaging actions to WC may occur or be allowed to fester. Ideally we need yearly WCM and if this cannot be done then we need WCM every two years.”
“7) … It appears that the IT overlooks the wild and untrammeled aspects of WC while looking for Congressional intent for individual wildernesses. This results in bypassing “The Wilderness Act and what it says about WC and the standard it sets for the entire National Wilderness System.”
“8) … I do not believe that climate change and regional development are beyond direct management control. Certainly, President Obama has emphasized to all agencies that they should begin the process of climate change adaptation and emission reductions and working with other local, state, and federal agencies can reduce regional development impacts.”
“9) … the examples given of a toilet and a barrier in a stream are both trammelings and should be reported as such. Otherwise the IT under reports trammelings and gives a distorted picture of the problem.”
“10) … I do not believe that “Wilderness stewardship commonly involves such tradeoffs”. What the WCM should show is steady progress toward better WC and not tradeoffs. Since the standard should be “zero” for number of trammelings in Wilderness, that is the goal that should be pursued even if it is never reached. To maintain the integrity of the “National Wilderness System” nothing else will do.”
“11) … I do not believe that poor quality data or “interpolated data” should be used. Such data verges on being “made-up data” and should not be relied upon. If there is “no data” then admit it and determine if the data can be obtained as part of the WCM or not. The “best available scientific information for each measure” does not mean we should use “poor quality data”. It means if there is no scientific data that is worthy of that name we need to go out and get that data in an acceptable way.”
“13 … the complications of this WCM protocol just get greater. We have individual qualities, monitoring questions, indicators, measures, and thresholds to determine C. This is too complicated to expect that each Ranger District, National Forest, staff member, … will be able to understand and accomplish such a WCM program.”
“14 … the “primary customer” is not the “decision-maker” but the “public”. I do not like using the word “customer”. I am an owner of the National Wilderness System” and not a “customer”. We need to understand that public lands, including “Wilderness”, are not commercial or business enterprises but are a common public heritage held in trust for all of us. We do not get to this point by calling the owners of that trust “customers”.
“16 … I do not support averaging out component indicators to provide an average monitoring question result. If something is important enough to include in WCM then it should be looked at and a determination made how it trends. Averaging out several component indicators hides that some of the indicators may be doing exceptionally poorly but others are doing exceptionally well. This does not get us to better WC but obscures this problem.”
“17) … we don’t need “simple linear regression”. We need WCM that is simple enough where we can add, subtract, divide, and multiply ourselves and understand the trends easily. This is not an exercise for scientific curiosity but is one for management and public ease of use and understanding.”
“18) … I do not support averaging out the indicators which obscures a bd trend in an indicator. “Stable” is the wrong word to use. If you have 50% trammeling and this holds at that level for several years this is not “stable”. This means that trammeling is 50% greater than it should be. The goal after all, is “zero” trammeling and a trend toward that level is the right trend.”
“19) … “tiebreakers” have no place in WCM. Just report the data, make a sample graph, the trend will be obvious, and what we need to do to reach “zero” will also be obvious. You don’t need rules for WCM you need data that are simple to collect, simple to show the public and decision-makers, and simple for documentation of trends. This entire calculation and averaging system is too complicated for managers and the public.”
“20) … it appears that the magnitude is very important when we talk about “trammeling”. It is good if all trammeling actions are recorded and then shown on a simple graph. Only by showing the entire picture of unacceptable trammeling can we reduce the level toward “zero”. Allowing managers to “create their own indices” for area, intensity, frequency, or duration makes no sense. Such allowances will create or promote inconsistencies in WCM and documentation of trammeling.”
“21) … I do not agree that only “all significant actions” of trammeling should be recorded. This opens up WCM to arbitrary actions of every District Ranger, Forest Supervisor, other employees … We need to record all trammelings, period. Then state if some trammelings are of a greater magnitude than others and why. Allowing only “significant actions” of trammeling injects uncertainty and bias into WCM. We do not need this.”
“In addition, the examples given, guzzlers, suppressed fires, stocking of lakes … are all trammelings and should not be allowed.”
“22) … when the IR states that “a guzzler should not be used as a proxy measure … it should be counted as an installation” I disagree. The guzzler should be labeled as a trammeling and should not be allowed.”
“23) … I do not agree that “There is a tension in the Wilderness Act between realizing the act’s recreational purpose and preserving wilderness character in general”. This is not true. There is no tension. Preserving WC always comes first before recreation. The purpose of “Wilderness” it to preserve its WC and not for it to give way to recreation. Recreation has to bend to WC.”
“24) … an example of “Actions taken inside the wilderness on a physical resource or natural process to intentionally affect the earth and its community of life” should include trail construction or improvements.”
“25) … I do not agree that climate change, air pollutants, installation of meteorological or scientific instruments, helicopter landings for any reason, and non-native invasive plant species are not trammeling actions. They are not accidental since humans know that these actions negatively affect WC and yet we continue to do these actions or create these conditions. The old adage applies that “Ignorance is no excuse for violating the law”.
“26) … I do not agree, with regard to climate change, that when we can see a long-term change in temperature that this is not an appropriate measure to record. The statement that “Because indigenous apices are included as an inherent component of ecological systems, they cannot therefore be considered a threat to that same ecosystem” is untrue because humans can change the vegetation or predator-prey relationships so that native species do cause problems. For instance, state wildlife agencies want to kill wolves in “Wilderness”. This creates a situation where native ungulates, like elk, cause vegetation changes and damage that normally would not occur in “Wilderness”.”
The FS also published, “Wilderness Character Monitoring Technical Guide”, in December 2020. The NSC submitted comments on September 29, 2016 about the “Wilderness Character Monitoring Technical Guide” draft. The NSC comment about the draft stated:
“The Forest Wilderness Subteam members agree on the following points:”
“The Forest Service should monitor the condition of wilderness areas under its administration and use monitoring data to refine stewardship actions and resource allocation.”
“The five descriptors of wilderness drawn from the language of the Wilderness Act – untrammeled, undeveloped, natural solitude, other – should not be equally weighted in a monitoring methodology.”
“Wildness is the essence of wilderness and should therefore be the compass for wilderness condition monitoring and reporting.”
“Wilderness stewards in the field are in the best position to evaluate the wildness of a place, but they need tools to objectively measure and report trends. It appears that the FS wants an uncomplicated monitoring tool that will measure each component of wilderness to determine whether an area’s wilderness “character” has improved, worsened, or is unchanged. While such a tool may be useful for the Fs, it may not capture subtle changes occurring in these unique places.”
“1. Rather than being holistic, as claimed in the Guide and KIW2, the Guide and the protocol break wilderness character into five separate categories. The Technical Guide has major flaws because the flow of information is based on separate categories rather than a holistic view of Wilderness.”
“3. … These five categories, considered equal in importance, are frequently defined in conflict with each other. The rules of statutory construct dictate that a statute be read an internally harmonious, not as inherently in conflict with itself.”
“5. While monitoring is well and good, since the five attributes are used in making decisions about Wilderness, via the Minimum Requirements Analysis (MRA) process, they are used in making decisions.”
“The MRA process is formulated so that untrammeled is downplayed in decisions. While this concern does not directly address the questions the agency has posed, it does reflect on how the protocol would be used in future decision making by the agency.”
“6. … The business concerns of the agency are somewhat addressed. However, there is little background as to why the agency uses the word “business” when it is a governmental entity designed to serve the public interest, rather than to generate profit – the usual definition of business. It would be preferable for agency personnel to view themselves as in public service rather than viewing the agency through the lens of business.”
“There does seem to be a disconnect between the intentions described in Section 1 to preserve wilderness, and the simplistic methodology laid out in the remaining sections. Equating the five “qualities” without assigning weights to each indicator may make reporting easier but is unlikely to yield a meaningful understanding of how “wildness is faring.”
“… With this in mind, the Guide may not well serve the National Wilderness Preservation System. Rather, a truly holistic process that values restraint in our relationship to Wilderness its – untrammeled nature – would better ensure an enduring resource of Wilderness.”
“I. Untrammeled as a Quality of Wilderness Character”
“Magnitude, other than as a screening tool, is explicitly not used as a consideration in this document for pragmatic reasons. This may be good for scorekeeping of trends, but it fails in terms of real on-the-ground effects. For example, multiple prescribed fires count as one trammeling if they are all part of the same burn plan. Putting out lightning-caused fires, however, counts as separate trammelings.”
“II. Natural as Quality of Wilderness Character”
“The current draft of the Guide states, “The object of monitoring the Natural Quality is to assess the impacts of human-caused changes.” This includes all suspected human-caused changes to plants animals, air, water, and ecological processes and implies that all changes are caused by humans. The approach could be simplified as in the original KIW.”
“III. Undeveloped as Quality of Wilderness Character”
“The measures in this section exclude recreation-related structures. These structures detract from the undeveloped nature of Wilderness just as other structures do. Their omission is a serious oversight. Placing them only in the solitude and primitive recreation category seems odd. While recreational installations may affect the primitive recreation and solitude of a Wilderness, they also have an impact on the undeveloped nature of Wilderness. Wilderness is harmed by development whether the development is considered necessary or not.”
“For example, the policy in Denali National Park Wilderness and the Arctic Wildlife Refuge … is to have no developed trails. The reason fir this is simple: to have a truly undeveloped Wilderness. Installations and structures, even trail water bars or the trails themselves, do detract from the undeveloped character of an area.”
“Also, considering certain structures as a negative for the undeveloped quality … but positive for other values of Wilderness falls into the trap mentioned in the introduction to this comment.”
“IV. Solitude or Primitive and Unconfined Recreation as Quality of Wilderness Character”
”Including indicators and measures of opportunities for solitude or primitive and unconfined recreation in the methodology draft is both appropriate and paradoxical. Appropriate because it recognizes that wilderness is under siege by humans, not only due to population growth, urbanization and resource extraction outside wilderness areas, but also due to human activities inside wilderness. Paradoxical because they very qualities being monitored and measured are the cause of their own degradation: too many people seeking solitude degrades solitude; too many people seeing unconstrained or primitive recreation triggers the need for increased management restrictions on behavior in order to protect wilderness from further damage.”
“Examples provided in the Guide – building a bridge to prevent further erosion by hikers or pack animals, and installing toilets to deal with human waste – demonstrate the difficult tradeoffs wilderness administrators must make. Nevertheless, the monitoring protocols should squarely face the need to prioritize untrammeled, natural, and undeveloped qualities over accommodating human visitation which, cumulatively, is destructive to wildness.”
“While most indicators and measures within this category make sense, one does not: the index of visitor management restrictions. It is inconsistent and contradictory to include “management restrictions on visitors’ behavior “as a negative aspect of wilderness quality, because those restrictions are crucial to protecting all other wilderness values.”
“Other Features of Value as Qualities of Wilderness Character”
“The “ecological, geological, or other features of scientific, educational, scenic, or historic value” may exist in a designated wilderness area, but those features are not necessary to concluding that the area possess wilderness character. The Sec. 2(c) definition makes it clear that the wilderness character of an area is the first thing that must be established before it can be designated as a wilderness area. The area is untrammeled and it is practicable to preserve and use it in an unimpaired condition.”
“The “other features” listed in Sec. 2(c) are not qualities of a wilderness area. Rather, when present, such features can assist the area’s user’s in experiencing, using, and valuing the wilderness area. Utilizing the “other features” as an indicator of wilderness quality in the manner proposed in the Wilderness Character Monitoring Technical Guide is inappropriate and detracts from the central character trait of wilderness: its wildness.”
“Summary”
“As noted throughout our comments, our primary concern with the proposed monitoring methodology is that equating the five categories – untrammeled, undeveloped, natural, solitude, and other – could distort agency conclusions and priorities. We can offer two potential options for addressing this concern, both of which would retain the Forest Service team’s many well-conceived indicators and measures of wilderness condition.”
“The first option is to simply eliminate the step of aggregating indicators within the five categories.”
“The second option is to report only the subtotals each of the five categories. Without a grand total of all five categories, Forest Service specialists would not be able to report an overall trend in the condition of a wilderness area or a set of wilderness areas; they would have to report on each category separately. They could, however, total the results of each category across a region, or nationally, and report the direction in which each is trending.”
The FS inadvertently has implemented a monitoring protocol that will degrade or denigrate the most important part of wilderness character and condition, its untrammeled nature and wildness. This wouldn’t be good for wilderness. The NSC/LSC/HSC, as this history shows, will have more discussions with the FS to change direction in wilderness mismanagement in the future.
As mentioned above under “East Texas Wilderness Areas and Fire”, these monitoring concerns and the underestimation of effects on “untrammeled” and “wildness” in wilderness have been raised for UIWA.
K. Sierra Club, East Texas Wilderness Areas, and Erosion
Some wilderness management problems are much more straightforward, although not necessarily easy, to see and or address. An example of this concerns UIWA. Larry Shelton, Texas Conservation Alliance (TCA) representative, reported via email to the FS on June 4, 2021 about an erosion problem in Upland Island Wilderness Area (UIWA) due to runoff from two wing ditches along Forest Road (FR) 314, which splits the wilderness.
The road runoff from FR 314 was channeled through a bog and resulted in a 6-foot-deep gully in UIWA. TCA stated:
“The bog is an ecologically important site with at least one FS-listed sensitive species: Grasspink Orchid-Calopogon tuberosus. I have spoken with Brandt and we both agree that the problem area should be stabilized and restored since it is close to the road.”
“I would like to participate in a site visit with you or other FS personnel to assess the damage and repair options.”
On that same day, the LSC sent an email in support of TCA’s concerns about the erosion and degradation of the bog in UIWA. This email stated:
“On behalf of the Lone Star Chapter of the Sierra Club (Sierra Club), I support Larry Shelton of the Texas Conservation Alliance and his description and assessment of the ongoing damage to and within Upland Island Wilderness Area (UIWA). Although I have not visited the site, Larry's photos show that convincing unacceptable damage is occurring right now in UIWA.”
“It appears that FR 314, outside of UIWA, has caused significant environmental impacts (6 foot deep erosion channel) and degradation of wilderness character within UIWA. This is due to excessive directed water flows from FR 314 outside UIWA into a sensitive bog area, inside UIWA.”
“Low impact and wilderness compatible restoration or rehabilitation is needed to stop the erosion of soil, reduce water quality degradation (sedimentation/siltation), halt damage to wilderness character, and prevent further destruction of a significant herbaceous bog.”
“The Sierra Club urges the U.S. Forest Service (FS) to address this situation immediately before unnecessary and additional damage occurs to the enduring resource of UIWA.”
“The damage is due to the design of FR 314 and the increase in rainfall that has occurred this Spring, undoubtedly caused, in part, by human created climate change. Additional rains are forecast for this and next week which will cause more damage.”
“The Sierra Club wants to work with the FS so that this situation is addressed as soon as possible. The Sierra Club appreciates expedited action by the FS to resolve this problem. Thank you.”
The FS, District Ranger, Angelina/Sabine National Forests, responded on June 8, 2021 with an email and stated:
“I have received your messages from yesterday … regarding concerns with erosion impacts within UIW from FSR 314.”
“We will follow up with you both once we’ve had an opportunity review the location and concern.”
The FS followed up via email about this erosion concern on June 22, 2021 and stated:
“I visited the location from your June 4th email on Thursday 6/17 with personnel from the District’s engineering shop. We were able to locate the area of interest and did some field reviews. We came up with the following steps to address the concerns in light of parameters associated with Wilderness:”
“Utilize straw wattles (or other appropriate erosion) to create a J-hook feature at the end of the wing ditch. The intention will be to slow water down so that it can be absorbed into the soil or at least reduce velocity.”
“Additionally, we’d install straw waddles in several other locations down slope from the end of the wing ditch in order to provide a pooling terrace type features again aimed at slowing water as it drains down slope. One of these locations would be near (but not on top of) the head of the seep.”
“I think dealing with the runoff and slowing it’s velocity is the most beneficial steps to be taken at this time. It appears this has been an issue for a while, but likely was exacerbated by the deep freeze in February, followed by our prescribed operations in early April and then by the torrents of rains we received during the end of April and all of May.”
“I’m concerned that taking direct action on the area around the seep may result in more damage. As such, we’re looking at focusing uphill as described above. We’re currently doing some research on best locations to purchase weed-free straw wattle. Once found and purchased we’ll install erosion control structures consistent with wilderness values (aka appropriate tools and materials) and then we’ll monitor following the next major rain event to see if we’ve been successful. If not, there are some additional options we’ve discussed, but they are more intensive and may not ultimately be appropriate given the Wilderness designation of the area. Hopefully, this approach will work and we won’t have need to examine other more intensive options.”
“Finally, we will do some additional work within the existing wing ditch by adding larger rocks to again help slow the flow of water coming off the hill into that wing ditch and then subsequently flowing overland down into that gully.”
“I’ve included a rough sketch of the concept we’re thinking to apply. Also attached is a photo of the straw wattle that we’re investigating to use although it may not be exactly like this nor from this company. Again just an example.”
“We’ve flagged the general locations we thought placement of wattle would be best placed and I’m willing to schedule time for a site visit with you to review in the field.”
“Please let me know if you have any additional thoughts or concerns about this approach.”
“Brandt, I’ve cc’d you on this message since you’d expressed interest in the topic as well.”
The LSC responded by email and stated:
“Thanks Kimpton. I want to talk with Larry before providing any further input. I would like to visit the site.”
Larry Shelton, TCA, sent the FS an email on June 23, 2021 which stated:
“Thank you for visiting the site and providing a starting point for discussions to stabilize the erosion. I agree with Brandt that it would be helpful to visit the site as a group to help visualize potential solutions.”
“I envisioned using sections of dead pine poles gathered locally. Once cut to length, outside the Wilderness with a chainsaw, they could be put into place by hand. How long could the straw wattles be expected to last with ongoing fire management?”
“I also envisioned doing away with the wing ditches and letting water run down the bar-ditch to below the seep before diverting it off of the road. The bar-ditch would have to be reinforced with rip-rap.”
“I'll discuss the issue with Brandt. Also, I would appreciate you scheduling a site visit to discuss solutions in the field.”
The FS emailed the LSC and TCA on July 2, 2021 and stated:
“We’ll schedule some time to do a site visit and discuss further when I return to the office in a couple of weeks. I have reservations about eliminating the wing ditch, but let’s discuss further later in the month when we can get together.”
Unfortunately, then there was no further response from the FS. The LSC sent an email to the FS on October 8, 2021 as a reminder about meeting in UIWA to view the road erosion which stated:
“We talked about meeting in Upland Island Wilderness Area with Larry to look at an eroding seepage area that is due to road runoff. The days are beginning to cool off so it might be a good time to meet, look at, and discuss this wilderness management situation.”
“There is a parking lot on the south side of FR 314 as it goes through Upland Island Wilderness Area. We could meet there and then drive to the location and take a look. Let me know what you think.”
In December 2021, the LSC visited the site of the erosion in UIWA. The LSC submitted an article about the erosion to the HSC to be published in the Bayou Banner. December 17, 2021, the LSC sent an email to the FS and stated:
“On December 16, 2021, I visited Upland Island Wilderness Area (UIWA) with Adrian Van Dellun to view where Forest Road (FR) 314, via a wing ditch, is draining run-off into UIWA and causing soil erosion on a seepage slope and damage to seepage areas and creeks.”
“The water from intense and frequent rains (probably exacerbated by climate change) is draining off the road into UIWA. The first photo I have attached to this email (29 photos in all), shows where a second such drainage from the road is beginning soil erosion at a site about 100 feet east on the road from the present wing ditch location.”
“The photos I have attached are arranged from last photo taken to first taken. They are best reviewed going to the last photo and then moving forward. The photos begin by showing some ferns and other vegetation that exist on the seepage slope that are being eroded and destroyed by the excessive run-off downslope.”
“Then you see the road and wing ditch and a progression of photos that show the trace of the run-off and the erosion and damage done near the bottom of the slope and finally what the seepage creeks look like beyond this point when they resume natural flow characteristics.”
“The seepage slope has evidence of groundwater near the soil surface via the existence of Royal Fern, Sphagnum Moss, crawfish chimneys, Sweetbay Magnolia, Red Maple, American Holly, Red Bay, Southern Wax Myrtle, Wood Fern, and seepage creek flows. There also are photos of hog wallows and rooting which destroys bog vegetation and creates fecal contamination of water.”
“The photos also show that the U.S. Forest Service (FS) has placed a coir bundle at the top of the slope to reduce erosion and slow down the flow of the road run-off. The FS may want to place additional bundles at the top to further reduce this erosive run-off as an initial (short-term) mitigation in UIWA.”
“A long-term mitigation plan is needed to reduce or eliminate road run-off into UIWA. The Sierra Club wants to work with the FS and the Texas Conservation Alliance to prepare such a plan.”
“The Sierra Club requests that the FS determine when, in the near future, would be a good time to visit the site and discuss how to move forward to stop this external damaging road soil erosion. This soil erosion degrades wilderness conditions and character, like surface and groundwater quality, and leaves this part of UIWA unnecessarily trammeled.”
“Thanks for your help and I look forward to hearing from you soon.”
The new FS District Ranger for Angelina/Sabine National Forests responded on December 17, 2021 about a date that would be sometime between January 10th and the 14th for all parties to gather at UIWA to look and discuss the erosion site.
The NFGT Supervisor’s Staff, responded on December 23, 2021, via email, which stated:
“Just letting you know we are working on this issue. I’ll get with Tom (Botany), Adam (Wildlife), and ben (Wilderness) after the first of the year.”
The new District Ranger for the Angelina/Sabine National Forests also responded via email on December 26, 2021 and stated:
“I understand. Yes, we can move the meeting … When I get back on the 3rd, I will coordinate with staff members and check their availability for a meeting. I will stay connected and let you know available dates and times.”
On January 26, 2022, the LSC, TCA, and FS met in UIWA to look at the runoff erosion problem. A report written by the LSC after this meeting stated:
“Road Erosion Addressed in Upland Island Wilderness Area”
“On January 26, 2022, the Lone Star Chapter of the Sierra Club (Sierra Club) and the Texas Conservation Alliance (TCA) met with the U.S. Forest Service (FS) to discuss soil erosion and sedimentation from Forest Road (FR) 314 rainfall runoff and how it affects Upland Island Wilderness Area (UIWA).”
“The rainfall runoff erodes seepage slopes (bogs with Sweetbay Magnolia and other wetland plants) and deposits soil into seepage creeks which smothers aquatic life and reduces water quality.”
“Sierra Club, TCA, and FS representatives walked in UIWA and along FR 314 and observed the active soil erosion that has occurred from road rainfall runoff.”
“Discussions included the condition of the three wing ditches that take runoff from FR 314 and places it within the 33-foot (from the center of the road) right-of-way. This results in the soil carrying runoff that intrudes on UIWA. The FS has installed several coir mats to reduce the velocity of runoff that flows into UIWA but deposits of sediment could be seen in the wilderness area.”
“There were conversations about placing rock, cut logs, and additional coir mats in or near the wilderness boundary to reduce the velocity of the water as it flows down the seepage slopes. There were suggestions about detention ponds, culverts, and rock placement in a road-side drain along the road.”
“These preliminary discussions resulted in the FS proposing to install a culvert under FR 314. The culvert would take some rainfall runoff from the north side to the south side of the road where non-wilderness national forest land is located. This would reduce volume and flow speed of water on the north side of FR 314, where the erosion and sedimentation occur in UIWA.”
“The FS also proposed placing rock in the side drain on the north side of FR 314 to reduce erosion and speed of water going downhill. There are at least three wing ditches may need to be cleaned out.”
“At the bottom of the north FR 314 road slope, there is a site where water is leaving FR 314, eroding soil, carrying that soil into a seepage creek, and capturing the seepage creek with rainfall runoff water. The FS will determine what will be done about this site based upon the success of the culvert and side drain rock placement.”
“Other means of reducing rainfall water erosive volume and speed from FR 314 runoff may be considered in the future based upon the performance of the culvert and drain rock placement.”
“Thanks go to Mr. Logan Gallant, Acting District Ranger, Angelina/Sabine National Forests, and other FS personnel for meeting with the Sierra Club and Larry Shelton of the Texas Conservation Alliance UIWA to discuss this concern/issue. The Sierra Club appreciates the pro-active stance that Acting District Ranger Gallant and the FS have taken on this issue.”
“The Sierra Club looks forward to continued collaboration with the U.S. Forest Service on this important road maintenance project to protect UIWA.”
The LSC sent the FS and email on January 27, 2022 about the meeting in UIWA which stated:
“Thanks to you and other U.S. Forest Service (FS) personnel for meeting with Larry Shelton of the Texas Conservation Alliance and I (Sierra Club) at Upland Island Wilderness Area (UIWA) to discuss runoff from FR 314 that is sending sediment into the Wilderness Area and causing erosion of seepage creeks and slopes. I really appreciate the pro-active stance you took on this issue.”
“As I understand our preliminary discussions, the FS will place a culvert under FR 314 to take some rainfall runoff from the north side of the road to the south side of the road where non-wilderness national forest land is to reduce volume and flow speed on the north side, where the erosion and sedimentation occurs in UIWA.”
“The FS also will place rock in the side drain of FR 314 on the north side to reduce erosion and the speed of the water going downhill. There are at least three wing ditches may need to be cleaned out.”
“There also is, at the bottom of the north FR 314 road slope, a site where water is leaving FR 314, eroding soil, carrying that soil into a seepage creek, and capturing the seepage creek with rainfall runoff water. The FS will determine what will be done about this site based upon the success of the culvert and side drain rock placement.”
“Other means of reducing the rainfall water erosive volume and speed from FR 314 runoff may need to be considered in the future based upon the performance of the culvert and drain rock placement.”
“The Sierra Club looks forward to working with the U.S. Forest Service on this important road maintenance project to protect UIWA.”
The NFGT Staff, on January 27, 2022, sent an email to the LSC which stated:
“Glad the field trip was productive. I know there has been a lot of internal email traffic about this issue. Ben Richardson has been involved from Recreation. Zone Peavy from Engineering. Tom (Botany), Adam (Wildlife), and Casey (NEPA) have been involved from my shop.”
“Thanks for sharing your notes.”
The LSC sent an email to the FS, District Ranger, Angelina/Sabine National Forests, on January 27, 2022 which stated:
“Attached are photos I took when we met on January 26, 2022 to look at the erosion/sedimentation from FR 314 that has impacted Upland Island Wilderness Area (UIWA).”
The LSC prepared and submitted an article on January 28, 2022 for the HSC Bayou Banner and website which detailed the January 26, 2022 meeting about erosion in UIWA.
January 31, 2022, FS, District Ranger, Angelina/Sabine National Forests, sent an email to the LSC that included an email from Engineering from January 28, 2022 that discussed what may be done about the erosion from FR 314 in UIWA. This email stated:
“Please see the follow up email below from Zane. I have added everyone’s email to the group so everyone will be aware of any conversations or questions. Please reply all if asking a question or seeking additional clarification.”
From email of Zane Peavy, FS, Engineering:
“In our 1/26/2022 trip to FSR314 we found some erosion that could be being accelerated by the wing ditch that takes water from the road and disperses it into the wilderness area.”
“Our proposal is to place a culvert before the first wing ditch that will take water from the north side of the road to the southern side. Additionally there is a culvert taking water from the south side and moving it to the northern side that we are recommending that we remove. The wing ditch on the southern side of the road just down stream from the culvert that we are going to remove will need to be cleaned out and reshaped to take the extra flows that will be added to the southern ditch.”
“The location of these two culverts were marked with flagging.”
“After these culvert are removed/added we should monitor the erosion and take further mitigation measures as necessary.”
“If you need any further clarification or have any questions, please let me know.”
When the LSC hadn’t heard further from the FS for nine months, an email was sent on October 12, 2022 which stated:
“It's been since January that I heard anything about FR 314 and mitigation for its impacts on Upland Island Wilderness Area (see below). Would you provide the Sierra Club with a status update of what work has been completed, what work still needs to be done, and an estimated schedule when the work will be complete? Thanks for your help.”
The FS, District Ranger, Angelina/Sabine National Forests, responded by email on October 12, 2022 and stated:
“We were able to get the culvert installed last month. We have partnered with the county to bring rock and armor the culvert. They plan to haul the rock and complete the work next week. Once the culvert is armored this project will be complete. Hopefully, the culvert will divert the water as we intend. We will attempt to check periodically to verify the effectiveness of this measure.”
The LSC on October 12, 2022 responded to the FS and stated:
“Thanks Logan. I appreciate your efforts on this important project.”
The TCA responded on October 19, 2022 and stated:
“Thank you for your update on the culvert/road work on FSR 314. TCA greatly appreciates your involvement in the effort to stabilize the situation and protect a valuable resource. I’ll take a look next time I’m in UIW.”
That appeared to be the conclusion of the story. However, on February 1, 2023, TCA sent a letter to the FS, District Ranger, Angelina/Sabine, which stated:
“This letter pertains to the upcoming 2-7-2023 meeting to discuss fire management issues for Upland Island Wilderness (UIW). The attached photos depict active erosion at UIW that is being exacerbated by the removal of ground cover from fire. These pictures are from the southern part of the Hopson Fire that took place in August 2023. This situation predates the Hopson Fire and each fire that removes all ground cover results in fresh soil movement. I have encountered a number of widely scattered similar erosion situations across the upland part of the Catahoula Burn Unit.”
“There have been three controlled burns under the current fire management initiative as well as natural and/or possibly man-caused fires. The controlled burns have burned to the mineral soil in places that led to increased erosion. I want to raise the topic of increased erosion from controlled burning for discussion at the 2-7-2023 meeting.”
“The photos below are a sequence of the same drainage area, from uphill, going downhill. The last photo is below the eroded areas uphill and shows that there is no drainage channel. This indicates that the uphill gulley was a result of erosion, independent of natural stream hydrology.”
“Looking forward to the meeting.”
So it begins again. A never-ending battle for protection of wilderness and a reduction of human generated erosion.
VIII. Summary Sierra Club and East Texas Wilderness Areas Management
Without the NSC/LSC/HSC’s steady and constant focus on FS wilderness management, the five ETWA would be in much worse shape and their quality would indicate less wilderness character, untrammeled nature, wildness, and the benefits that wilderness provides to people.
The trick in the future is who and how many NSC/LSC/HSC members will come forward and continue this public interest advocacy to protect wilderness. I hope there will be many and that they too will carry the “pride and dedication” that past Sierra Club members have had, into the fight to protect our five ETWA. That is my hope and dream.
References
I. Introduction
II. East Texas Wilderness Areas
1) “Fingertip Facts”, National Forests and Grasslands in Texas, January 2017.
Lone Star Chapter of the Sierra Club Policies and Positions on Wilderness Areas and Related Issues Through 1978
1) Public Law 88-577, 88th Congress, September 3, 1964, “Wilderness Act”.
2) Public Law 98-574, 98th Congress, October 30, 1984, “Texas Wilderness Act of 1984”.
3) October 25, 1984, Letter from George Russell, Chair, East Texas Wilderness and Forest Practices Chair, to Executive Committee, Lone Star Chapter of the Sierra Club, about resolution for wilderness management policy to prevent prescribed burning and control of southern pine beetles.
III. Sierra Club National Policies on Wilderness Areas and Fire
1) “Wilderness Management”, Sierra Club, November 5-6, 1977, amended July 8, 1995.
2) “Fire Management on Public Lands”, Sierra Club, March 17-19, 1989.
IV. Sierra Club, East Texas Wilderness Areas, and Fire
1) “Merriam-Webster’s Collegiate Dictionary, 11th Edition”, 2014.
2) “Wilderness Fire Action Plan National Forests in Texas, November 1984”, U.S. Forest Service, National Forests in Texas, November 1984.
3) “The Hidden Consequences of Fire Suppression”, Carol Miller, Park Science, Volume 28, Number 3, Winter 2011-2012.
4) “Fire Management Action Plan for Turkey Hill Wilderness”, U.S. Forest Service, National Forests and Grasslands in Texas, April 14, 1994.
5) “Fire Management Action Plan for Big Slough Wilderness”, U.S. Forest Service, National Forests and Grasslands in Texas, January 18, 1994.
6) “Fire Management Action Plan for Upland Island Wilderness”, U.S. Forest Service, National Forests and Grasslands in Texas, April 14, 1994.
7) “Fire Management Action Plan for Little Lake Creek Wilderness,” U.S. Forest Service, National Forests and Grasslands in Texas, no approval date but recommended date of December 2, 1992.
8) February 15, 1999, Letter from Houston Regional Group of the Sierra Club, to Ronnie Raum, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, in reference to a January 6, 1999 Sierra Club Freedom of Information Act request.
9) “Fires in the Forest: Are They Bad or Good?”, Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, September 2000.
11) March 10, 2003, Letter from Dr. Craig Rudolph, U.S. Forest Service, Southern Forest Experiment Station, to Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, about wilderness and fire management.
12) April 1, 2003, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Dr. Craig Rudolph, U.S. Forest Service, Southern Forest Experiment Station, about wilderness and fire management.
13) “Management Problems in East Texas National Forest Wilderness Areas,” Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, September 2, 2005.
14) May 2, 2007, Public Notice, U.S. Forest Service, National Forests and Grasslands in Texas, for scoping comments for prescribed burns in Upland Island Wilderness Area to reduce hazardous fuels.
15) May 29, 2007, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to William E. Taylor, U.S. Forest Service, District Ranger, Angelina National Forest, National Forests and Grasslands in Texas, scoping comments on proposal to prescribe burn 13,300 acres of Upland Island Wilderness Area to reduce hazardous fuels.
16) “Upland Island Wilderness Fire Management Briefing Paper”, U.S. Forest Service, National Forests and Grasslands in Texas, March 3, 2007.
17) “Upland Island Wilderness Ecosystem Restoration Initiative Slideshow”, U.S. Forest Service, National Forests and Grasslands in Texas, March 7, 2007.
18) “Draft Upland Island Wilderness Fire Management Plan 2006”, U.S. Forest Service, National Forests and Grasslands in Texas, March 8, 2007.
19) “When is Trammeling With Fire in Wilderness Justified?”, Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, June 3, 2007.
20) July 26, 2007, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to William E. Taylor, U.S. Forest Service, District Ranger, Angelina/Sabine National Forests, National Forests and Grasslands in Texas, about proposal to prescribe burn Upland Island Wilderness Area for hazardous fuels purposes.
21) September 3, 2009, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Lynn Jackson, U.S. Forest Service, Forest Planner, Supervisor’s Office, National Forests and Grasslands in Texas and William E. Taylor, U.S. Forest Service, District Ranger, Angelina/Sabine National Forests, National Forests and Grasslands in Texas, providing comments on Environmental Assessment for the Upland Island Wilderness Fire Management Initiative.
22) September 25, 2009, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Lynn Jackson, U.S. Forest Service, Forest Planner, Supervisor’s Office, National Forests and Grasslands in Texas and William E. Taylor, U.S. Forest Service, District Ranger, Angelina/Sabine National Forests, National Forests and Grasslands in Texas, about additional mitigation measures for the proposal to prescribe burn Upland Island Wilderness Area for hazardous fuels purposes and a Freedom of Information Request.
23) March 29, 2010, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Linda Brett, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas the “Tick Seed Fire” Freedom of Information Act that was received from the U.S. Forest Service.
24) “Upland Island Wilderness Fire Management Initiative”, Final Environmental Assessment, Decision Notice, and Finding of No Significant Impact, U.S. Forest Service, National Forests and Grasslands in Texas, Angelina National Forest, November 2009, signed on April 28, 2010.
25) June 11, 2010, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to USDA Forest Service, Ecosystem Management Coordination, Attention: Appeals, Washington, D. C., appealing the Upland Island Wilderness Fire Management Initiative.
26) June 24, 2010, Notes taken by Brandt Mannchen, Forest Management issue Chair, Lone Star Chapter of the Sierra Club about a meeting with the U.S. Forest Service, Linda Brett, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, which discussed the appeal of the Upland Island Wilderness Fire Initiative, written up on June 28, 2010.
27) June 25, 2010, Letter from Linda Brett, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about the Upland Island Wilderness Fire Initiative meeting and resolution.
28) June 27, 2010, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Linda Brett, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, about agreed resolution to the appeal of the Upland Island Wilderness Fire Initiative.
29) October 20, 2010, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Linda Brett, U.S. Forest Service Forest Supervisor, National Forests and Grasslands in Texas, about initial input for the Wilderness Information Needs Assessment for prescribed burning via the Upland Island Wilderness Fire Initiative.
30) October 26, 2010, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Linda Brett, U.S. Forest Service Forest Supervisor, National Forests and Grasslands in Texas, about the need for specific standards to address “trammeling” for prescribed burning via the Upland Island Wilderness Fire Initiative.
31) February 13, 2012, Email from Ike McWhorter, U.S. Forest Service, Fire Ecologist, National Forests and Grasslands in Texas, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, with an invitation to observe the first prescribed burn in Upland Island Wilderness Area.
32) April 18, 2012, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Ike McWhorter, U.S. Forest Service, Fire Ecologist, National Forests and Grasslands in Texas, about an April 17, 20212 visit to Upland Island Wilderness Area to observe effects of the March 1, 2012 prescribed burn.
33) “Upland Island Wilderness Fire Management Plan 2012”, U.S. Forest Service, National Forests and Grasslands in Texas and Arthur Temple College of Forestry in Stephen F. Austin State University, November 2, 2011.
34) “Prescribed Fire Plan”, U.S. Forest Service, Upland Island Wilderness Area, Angelina National Forest, November 2013.
35) January 4, 2015, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Mark Van Every, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, about the “Wilderness Areas Managed to Minimum Stewardship Level”.
36) “Fire Effects Monitoring Report for the Upland Island Wilderness Prescribed Burn on March 25, 2015”, U.S. Forest Service, National Forests and Grasslands in Texas, undated, probably 2015.
37) “Supplemental Documentation to Support the FY 2014 Accomplishment Report of Wildernesses “Managed to a Minimum Stewardship Level, for Five Wilderness Areas,” U.S. Forest Service, National Forests and Grasslands in Texas, December 16, 2014.
38) “Crosswalk from 10YWSC to Wilderness Stewardship Performance”, U.S. Forest Service, National Forests and Grasslands in Texas, February 12, 2015.
39) “Wilderness Performance Measure Accomplishment Report”, U.S. Forest Service, National Forests and Grasslands in Texas, December 16, 2016.
40) “Revised Fire Effects Monitoring Plan and Sampling Design for NFGT March 8, 2017”, U.S. Forest Service, National Forests and Grasslands in Texas, Draft, March 19, 2017.
41) March 19, 2021, Email from Larry Shelton, Texas Conservation Alliance, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club with an attached email from February 9, 2021, which discusses wildfire in Upland Island Wilderness Area.
42) March 26, 2021, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Kimpton Cooper, District Ranger, Angelina/Sabine National Forests, about agreement between the U.S. Forest Service and Sierra Club about notification and collaboration for prescribed burning in Upland Island Wilderness Area.
43) March 26, 2021, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Kimpton Cooper, District Ranger, Angelina/Sabine National Forests, about agreement between the U.S. Forest Service and Sierra Club about notification and collaboration for prescribed burning in Upland Island Wilderness Area.
44) “Wilderness Tram Fire”, handout with map and data on the fire, U.S. Forest Service, Davy Crockett National Forest, April 1, 2021.
45) April 5, 2021, Email from Kimpton Cooper District Ranger, Angelina/Sabine National Forests, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club about Upland Island Wilderness Areas Agreement Reminder letter, March 26, 2021.
46) April 9, 2021, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Kimpton Cooper District Ranger, Angelina/Sabine National Forests about April 5, 2021 U.S. Forest Service email about Upland Island Wilderness Area Fire Management Initiative Implementation.
47) May 10, 2021, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to national Sierra Club about invitation to attend U.S. Forest in-the-field meeting to observe where a wildfire had burned in Big Slough Wilderness Area.
48) “Prescribed Fire and Wildfire Visit to Upland Island Wilderness Area”, Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, May 14, 2021.
49) May 20, 2021, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Larry Shelton, Texas Conservation Alliance, about prescribed fire in wilderness and the trammeling this causes.
50) “Notes about Big Slough Wilderness Area Wildfire Visit in Davy Crockett National Forests”, Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, May 27, 2021.
51) May 26, 2021, Letter from Kimpton Cooper, U.S. Forest Service, District Ranger, Angelina/Sabine National Forests, National Forests and Grasslands in Texas, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, in response to April 9, 2021 Sierra Club letter about the Upland Island Wilderness Area Prescribed Burn Project.
52) June 1, 2021, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club Sierra Club, to Jamie Sowell, U.S. Forest Service, Forest Fire Management Officer, National Forests and Grasslands in Texas, about fire and wilderness.
53) June 2, 2021, Email from Jamie Sowell, U.S. Forest Service, Forest Fire Management Officer, National Forests and Grasslands in Texas, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club Sierra Club, about fire and wilderness.
54) June 6, 2021, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Kimpton Cooper, U.S. Forest Service, District Ranger, Angelina/Sabine National Forests, National Forests and Grasslands in Texas, about the U.S. Forest Service May 26, 2021 letter dealing with the Upland Island Wilderness Area Fire Management Initiative.
55) July 26, 2021, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to William E. Taylor, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, about the Upland Island Wilderness Fire Management Plan of 2012.
56) July 26, 2021, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to William E. Taylor, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, about the Upland Island Wilderness Fire Management Plan of 2012.
57) July 29, 2021, Email from William E. Taylor, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about information requests.
58) July 29, 2021, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to William E. Taylor, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, about discussing information requests.
59) “Notes on a Phone Call Between the NFGT Forest Supervisor and the Sierra Club About Information Requests for July 30, 2021”, Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, August 1, 2021.
60) August 7, 2021, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club to William E. Taylor, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, about Upland Island Wilderness Fire Management Plan.
61) August 17, 2022, Email from Joey Silva, U.S. Forest Service, Acting District Ranger, Angelina/Sabine National Forests, National Forests and Grasslands in Texas, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about Upland Island Wilderness Area “Hopson Fire”.
62) August 17, 2022, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Joey Silva, Acting District Ranger, Angelina/Sabine National Forests, National Forests and Grasslands in Texas about Upland Island Wilderness Area “Hopson Fire”.
63) August 22, 2022, Email from Joey Silva, U.S. Forest Service, Acting District Ranger, Angelina/Sabine National Forests, National Forests and Grasslands in Texas, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about Upland Island Wilderness Area “Hopson Fire”.
64) September 15, 2022, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Joey Silva, U.S. Forest Service, Acting District Ranger, Angelina/Sabine National Forests, National Forests and Grasslands in Texas, about Sierra Club visit to Upland Island Wilderness Area “Hopson Fire” site.
65) “Notes on Visit to Hopson Fire Location in Upland Island Wilderness Area”, Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, September 15, 2022.
66) “Fire Effects Monitoring Report for the Upland Island Wilderness Fire Management Initiative”, U.S. Forest Service, National Forests and Grasslands in Texas, November 14, 2022.
67) “Wilderness Character Monitoring Report for the Upland Island Wilderness Fire Management Initiative”, U.S. Forest Service, National Forests and Grasslands in Texas, January 18, 2023.
68) January 30, 2023, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Logan Gallant, U.S. Forest Service, District Ranger, Angelina-Sabine National Forests, National Forests and Grasslands in Texas, about fire effects and wilderness character monitoring reports.
69) “Notes on Upland Island Wilderness Area (UIWA) Prescribed Burning and Wilderness Monitoring Meeting, February 6, 2023”, Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, February 10, 2023.
70) February 17, 2023, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Logan Gallant, U.S. Forest Service, District Ranger, Angelina-Sabine National Forests, National Forests and Grasslands in Texas, which contains recommendations about how the U.S. Forest Service can improve its fire effects and wilderness character monitoring for Upland Island Wilderness Area.
71) February 17, 2023, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Logan Gallant, U.S. Forest Service, District Ranger, Angelina-Sabine National Forests, National Forests and Grasslands in Texas, which contains recommendations about how the U.S. Forest Service can improve its fire effects and wilderness character monitoring for Upland Island Wilderness Area.
72) February 17, 2023, Email from Logan Gallant, U.S. Forest Service, District Ranger, Angelina-Sabine National Forests, National Forests and Grasslands in Texas, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about recommendations about how the U.S. Forest Service can improve its fire effects and wilderness character monitoring for Upland Island Wilderness Area.
V. Sierra Club, East Texas Wilderness Areas, and Southern Pine Beetles
1) “Long-Term Control of Southern Pine Beetles in East Texas Forests”, Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, July 28, 2018.
2) “Wilderness Harvest in Texas”, Forest Planning, Volume 5, Number 8, November 1984.
3) “Plan for battling beetles irks environmentalists”, Harold Scarlett, Houston Post, Page 22A, November 8, 1984.
4) November 8, 1984, Letter from Brandt Mannchen, Chair, Wildlife Committee, Lone Star Chapter of the Sierra Club, to William M. Lannan, U.S. Forest Service, Forest Supervisor, National Forests in Texas, about input for amending the Environmental Assessment for Southern Pine Beetle infestations in wilderness areas.
5) November 9, 1984, Letter from William M. Lannan, U.S. Forest Service, Forest Supervisor, National Forests in Texas, to Brandt Mannchen, Chair, Wildlife Committee, Lone Star Chapter of the Sierra Club, about completion of Amendment Environmental Assessment for Southern Pine Beetle Control in RARE II Further Planning and Recommended Wilderness Areas, National Forests in Texas.
7) November 30, 1984, Letter and “National Forests in Texas Wilderness Areas Interim Direction”, from William M. Lannan, U.S. Forest Service, Forest Supervisor, National Forests in Texas, to George Russell, Chair, Forest Practices and Wilderness, Lone Star Chapter of the Sierra Club.
8) “Forest Service Logs Texas Wilderness”, Earth First!, Yule Edition, The Radical Environmental Journal, Volume V, Number 2, December 21, 1984.
9) “Wilderness area dedicated amid debate”, Tammy Valentine, The Huntsville Item, Volume 134, No. 357, January 19, 1985.
10) “Tree-cutting to eliminate bug rapped”, Bill Dawson, Houston Chronicle, January 19, 1985.
11) September 12, 1985, Letter from Cy Rhode, Chair, Gulf Coast Regional Conservation Committee, Sierra Club, to John Alcock, Regional Forester, U.S. Forest Service, about NEPA scoping comments for an environmental impact statement on southern pine beetle suppression in all forests of the Southeastern U.S.
12) “Pine beetle blight devastating”, Houston Post, William Pack, Page 3A, September 16, 1985.
13) “Beetlemania Sweeps the Southeast: SCLDF Sues to Halt Cutting in Wilderness”, In brief: A quarterly Newsletter on Environmental Law, Sierra Club Legal Defense Fund, May 1986.
14) “Napalming American Forests”, Mark D. Uehling, Daniel Shapiro, and Bob Cohn, Newsweek, October 20, 1986.
15) “Sierra Club v. Lyng, 663 F. Supp. 556 (D.D.C. 1987)”, Wilderness Stewardship Reference System, Legislative, Administrative, Judicial and Scientific Information, Wilderness.net, http://leopold.wilderness.net/WSRS/index.cfm?fuse=WSRS&sec=JD&search=issue&ID=50, April 28, 2013.
16) “Sierra Club v. Lyng, 662 F. Supp. 40 (D.C.C. 1987, 663 F. Supp. 556 (D.C.C. 1987”, Law School Case briefs, The Online University for Texas, http://www.invispress.com/law/natural/sierra4/html, April 28, 2013.
17) “Mitigation Measures From the April 6, 1987 Final Environmental Impact Statement (FEIS) and Record of Decision (ROD) for the Suppression of the Southern Pine Beetle (SPB),” Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, April 16, 2021.
18) “Groups criticize tree cutting”, Houston Chronicle, Page 24A, May 8, 1990.
19) May 25, 1992, Letter from Brandt Mannchen, National Forest Protection Campaign, Lone Star Chapter of the Sierra Club, to Andy Sansom, Executive Director, Texas Parks and Wildlife Department, about use of verbenone on Southern Pine Beetle spots in sensitive areas.
20) May 25, 1992, Letter from Brandt Mannchen, National Forest Protection Campaign, Lone Star Chapter of the Sierra Club, to David Hankla, Supervisor, U.S. Fish and wildlife Service, about use of verbenone on Southern Pine Beetle spots in sensitive areas.
21) May 25, 1992, Letter from Brandt Mannchen, National Forest Protection Campaign, Lone Star Chapter of the Sierra Club, to Alan Newman, U.S. Forest Service, Forest Supervisor, National Forests in Texas, about use of verbenone on Southern Pine Beetle spots in sensitive areas.
22) June 28, 1992, Letter from Brandt Mannchen, National Forest Protection Campaign, Lone Star Chapter of the Sierra Club, to Wesley A. Nettleton, Entomologist, U.S. Forest Service, about the reassessment of new information about southern pine beetle control.
23) “Wilson wants to cut trees to fight beetle infestation”, Bill Dawson, Houston Chronicle, Page 31A, October 15, 1993.
24) “Logging wilderness won’t curb nature’s pests”, Tom Maddux, Opinion-Editorial, Chair, National Forest Protection Campaign, Lone Star Chapter of the Sierra Club, Houston Chronicle, Page 11C, November 24, 1993.
25) “Wilderness Wildfire Hazard as Related to Tree Kill by Southern Pine Beetles on the National Forests in Texas”, Larry P. Ford, Fire Management Officer, National Forests in Texas, January 31, 1994.
26) “Control of the Southern Pine Bark Beetle and its Relationship to the Survival of the Red-cockaded Woodpecker”, Final Report, Steven P. Lewis, Ph.D., A report prepared for the Houston Regional Group of Sierra Club, February 1994.
27) “Statement of the Sierra Club and the Wilderness Society”, Thomas L. Maddux, Chairman, National Forest Protection Campaign, Lone Star Chapter of Sierra Club, Before the U.S. House of Representatives, Committee on Agriculture, Subcommittee on Specialty Crops and Natural Resources, about Rep. Charlie Wilson’s H.R. 3233 and its effects on the Wilderness Act, June 1, 1994.
28) June 7, 1994, Letter from Brandt Mannchen, National Forest Protection Campaign, Lone Star Chapter of the Sierra Club, to Alan Newman, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, about H.R. 3223 and SPB control in Wilderness.
29) “Wilderness Management”, Sierra Club national policy, adopted by the Board of Directors, November 5-6, 1977, amended July 8, 1995.
30) April 26, 2012, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Starr Chapter of the Sierra Club, to Steve Clarke and Lynn Jackson, U.S. Forest Service, National Forests and Grasslands in Texas, about pre-scoping comments for Environmental Assessment for Southern Pine Beetle control in East Texas Wilderness Areas.
31) September 20, 2012, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Starr Chapter of the Sierra Club, to Mark Van Every, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, about scoping comments for Environmental Assessment for Southern Pine Beetle control in East Texas Wilderness Areas.
32) June 11, 2013, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Starr Chapter of the Sierra Club, to Mark Van Every, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, about meeting held on Environmental Assessment for Suppression of Southern Pine Beetle Infestations in Wildernesses in the National Forests in Texas.
33) August 23, 2013, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Starr Chapter of the Sierra Club, to Steve Clarke and Lynn Jackson, U.S. Forest Service, National Forests and Grasslands in Texas, about scoping for Environmental Assessment for Suppression of Southern Pine Beetle Infestations in Wildernesses in the National Forests in Texas.
34) December 8, 2013, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Starr Chapter of the Sierra Club, to Mark Van Every, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, about comments on draft Environmental Assessment for Suppression of Southern Pine Beetle Infestations in Wildernesses in the National Forests in Texas.
35) May 21, 2014, Email from Lynn Jackson, U.S. Forest Service, National Forests and Grasslands in Texas, to Brandt Mannchen, Forest Management Issue Chair, Lone Starr Chapter of the Sierra Club, about meeting before the objection period to discuss the Environmental Assessment for Suppression of Southern Pine Beetle Infestations in Wildernesses in the National Forests in Texas.
36) June 10, 2014, notes about appeal meeting on “Environmental Assessment for Suppression of Southern Pine Beetle Infestations in Wildernesses in the National Forests in Texas”.
37) “Environmental Assessment, Draft Decision Notice and Finding of No Significant Impact for Suppression of Southern Pine Beetle Infestations in Wildernesses in the National Forests in Texas”, U.S. Forest Service, National Forests and Grassland in Texas, June 23, 2014.
38) June 26, 2014, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Starr Chapter of the Sierra Club, to Mark Van Every, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, about the Environmental Assessment for Suppression of Southern Pine Beetle Infestations in Wildernesses in the National Forests in Texas.
39) “Minimum Requirements Decision Guide for Control of Southern Pine Beetle Infestations in Wildernesses on the National Forests and Grasslands in Texas”, U.S. Forest Service, National Forests and Grasslands in Texas, June 17, 2014.
40) “September 2015 Environmental Assessment (EA), Finding of No Significant Impact (FONSI), and Decision Notice (DN) for the National Forests in Texas (NFT) Suppression of the Southern Pine Beetle (SPB) Infestations in Wilderness”, U.S. Forest Service, National Forests and Grasslands in Texas, August 31, 2015.
41) “Mitigation Measures From the September 2015 (August 31, 2015) Environmental Assessment (EA), Finding of No Significant Impact (FONSI), and Decision Notice (DN) for the National Forests in Texas (NFT) Suppression of the Southern Pine Beetle (SPB) Infestations in Wilderness”, Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, August 18, 2021.
42) May 31, 2021, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Rob Potts, U.S. Forest Service, Natural Resources and Planning Team Leader/Staff Officer, National Forests and Grasslands in Texas, about the "Minimum Requirements Decision Guide" (MRDG) for the "Control of Southern Pine Beetle Infestations in Wildernesses on the National Forests and Grasslands in Texas".
VI. Sierra Club and Other East Texas Wilderness Areas Management
1) November 1, 2004, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Mary Wagner, U.S. Forest Service, Director, Wilderness and Wild and Scenic Rivers, about management problems in the five East Texas Wilderness Areas.
2) “Management Problems in East Texas National Forest Wilderness Areas”, Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, July 21, 2022.
3) December 29, 1990, Letter from Brandt Mannchen, to Isaac Hawkins, U.S. Forest Service, District Ranger Yellowpine Range District, Sabine National Forest, about proposed seismic exploration in Indian Mounds Wilderness Area.
4) August 9, 1997, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Ned Fritz, Chair, Texas Committee on Natural Resources, about possible hikes for the 19th Annual Wilderness Pow Wow in Sam Houston National Forest.
5) December 8. 1997, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Ned Fritz, Chair, Texas Committee on Natural Resources, about Wilderness Watch.
6) December 10, 1997, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Friends of the Forest, about the 19th Annual Wilderness Pow Wow.
7) December 15, 1997, Hand-out, Houston Sierra Club Forestry Meeting, Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club.
8) “Nineteenth Annual Texas Wilderness Pow Wow Set for April 3-5, 1998, in Sam Houston National Forest”, Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, date unknown, probably in late 1997 or early 1998.
9) “Wilderness Watch, Sierra Club, and Pow Wow Team Up in April”, Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, date unknown, probably early 1998.
10) “Hikes Shaping Up for Pow Wow; PotLuck to Be Held for Wilderness Watch”, Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, undated, probably early 1998.
11) “Forest Walk in Wilderness Pow Wow, April 3-5, 1998, List of Hikes Now Available”, Brandt Mannchen, Houston Regional Group of the Sierra Club, undated, probably early 1998.
12) February 12, 1998, Email from Janice Bezanson, Executive Director, Texas Committee on Natural Resources, to Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, about changes to the list of outings for the 19th Annual Wilderness Pow Wow.
13) March 21, 1988, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Forest Lovers, invitation to a potluck reception for George Nickas, Policy Coordinator, Wilderness Watch.
14) April 11, 1998, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Ronnie Raum, U.S. Forest Service, Forest Supervisor, National Forests in Texas, about observations made at visits to East Texas Wilderness Areas by Wilderness Watch and Sierra Club.
15) “Draft Sierra Club Guidance on Wilderness Legislation, Public Lands, and Non-Conforming Uses”, Brandt Mannchen, September 10, 2006.
16) December 26, 2006, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Clayton Daughenbaugh, Sierra Club Wildlands Committee, about “Advisory for Use in Developing and Implementing Wilderness Campaigns”.
17) “Sierra Club says project will flood Sam Houston National Forest”, Vilas Bhuchar, Houston Tomorrow, December 7, 2009.
18) December 2, 2009, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Mark Evans, Chair, Regional H Planning Group, about proposal to construct Little Lake Creek Dam in Sam Houston National Forest and Little Lake Creek Wilderness Area.
19) “Don’t Flood the Sam Houston!”, Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, undated, probably December 2009 or January 2010.
20) January 14, 2010, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Alan Sadler, Montgomery County Judge, about proposal to construct Little Lake Creek Dam in Sam Houston National Forest and Little Lake Creek Wilderness Area.
21) August 28, 2002, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to George Nickas, Executive Director, Wilderness Watch, about a draft protocol to monitor and evaluate wilderness character.
22) January 4, 2015, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Mark Van Every, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, about Wilderness Areas Managed to Minimum Stewardship Level for the five East Texas Wilderness Areas.
23) July 1, 2011, Letter from the Toledo Bend Project Joint Operation, Sabine River Authorities of Texas and State of Louisiana, to Linda Brett, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas and Eddie Taylor, U.S. Forest Service, District Ranger, Sabine National Forest, about proposal for possible strip lands exchange agreement.
24) July 25, 2011, Email from William E. Taylor, U.S. Forest Service, District Ranger, Sabine National Forest, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about proposal for possible strip lands exchange agreement.
25) September 2, 2011, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to William E. Taylor, U.S. Forest Service, District Ranger, Sabine National Forest, about proposal for possible strip lands exchange agreement.
26) September 3, 2011, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to various Sierra Club employees and leaders, about proposal for possible strip lands exchange agreement.
27) September 5, 2014, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Athan Manuel, national Sierra Club, about National Defense Authorization Act and strip lands.
28) December 3, 2014, Email from Mark Van Every, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about National Defense Authorization Act and strip lands.
29) December 4, 2014, Email from George Nickas, Executive Director, Wilderness Watch, to Athan Manuel, national Sierra Club, about National Defense Authorization Act and strip lands.
30) December 4, 2014, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Athan Manuel, national Sierra Club and George Nickas, Executive Director, Wilderness Watch, about National Defense Authorization Act and strip lands.
31 December 14, 2014, Email from Wayne Y. Hoskisson, national Sierra Club, to Sierra Club email listserv, about National Defense Authorization Act and how it deals with conservation lands.
32) April 20, 2023, Congress.gov, text of H.R. 3979, approved as Public Law No: 113-291, National Defense Authorization Act of 2015.
33) August 24, 2016, Email from James Sowell, U.S. Forest Service, Acting District Ranger, Angelina-Sabine National Forest, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about illegal marijuana grow site in Indian Mounds Wilderness Area.
34) August 24, 2016, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to James Sowell, U.S. Forest Service, Acting District Ranger, Angelina-Sabine National Forest, about illegal marijuana grow site in Indian Mounds Wilderness Area.
35) August 24, 2016, Email from James Sowell, U.S. Forest Service, Acting District Ranger, Angelina-Sabine National Forest, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about illegal marijuana grow site in Indian Mounds Wilderness Area.
36) August 25, 2016, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to James Sowell, U.S. Forest Service, Acting District Ranger, Angelina-Sabine National Forest, about illegal marijuana grow site in Indian Mounds Wilderness Area.
37) August 25, 2016, Email from George Nickas, Executive Director, Wilderness Watch, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about illegal marijuana grow site in Indian Mounds Wilderness Area.
38) “Notes for Lone Star Hiking Trial Annual Meeting of October 13, 2001”, Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, October 22, 2001.
39) December 4, 2001, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Region Group of the Sierra Club, to James Scott, U.S. Forest Service, Law Enforcement Officer, Sam Houston National Forest, about emergency use of ATV’s in Little Lake Creek Wilderness Area.
40) “Weather hinders Recovery”, Christine S. Diamond, The Lufkin Daily News, Page 1A, February 7, 2003.
41) “Memo: Columbia Recovery in the Indian Mounds Wilderness Area”, Larry H. Bonner, U.S. Forest Service, Acting Forest Supervisor, National Forests and Grasslands in Texas, February 7, 2003.
42) “Searchers can use vehicles in Indian Mounds Wilderness”, Lisa Falkenberg, Associated Press Writer, The Lufkin Daily News, Page 1A, February 22, 2003.
43) February 24, 2003, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Region Group of the Sierra Club, to Fred Salinas, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, about Columbia debris removal in Indian Mounds Wilderness Area.
44) February 26, 2003, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Region Group of the Sierra Club, to Fred Salinas, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, about Columbia debris removal in Indian Mounds Wilderness Area.
45) February 27, 2003, Letter from Dick Donovan, Chair, Forest Task Force, Texas Committee on Natural Resources, to Fred Salinas, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, about Columbia debris removal in Indian Mounds Wilderness Area.
46) “Concerns About the National Forests and Grasslands in Texas Mentioned to Mr. Fred Salinas, Supervisor, at a Meeting on July 1, 2003”, Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club.
47) July 15, 2003, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Region Group of the Sierra Club, to Fred Salinas, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, about Columbia debris removal in Indian Mounds Wilderness Area.
48) September 25, 2003, Letter from Fred Salinas, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, to Brandt Mannchen, Chair, Forestry Subcommittee, Houston Region Group of the Sierra Club, about forest issues including Columbia debris removal in Indian Mounds Wilderness Area.
49) November 1, 2004, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Region Group of the Sierra Club, to Mary Wagner, Director, Wilderness and Wild and Scenic Rivers, U.S. Forest Service, about wilderness issues including Columbia debris removal in Indian Mounds Wilderness Area.
50) April 25, 2016, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Robert Potts, U.S. Forest Service, Natural Resources and Planning Team Leader/Staff Officer, about upcoming revised Forest Plan and concerns/issues including wilderness.
51) April 8, 2017, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Robert Potts, U.S. Forest Service, Natural Resources and Planning Team Leader/Staff Officer, about upcoming revised Forest Plan and concerns/issues including wilderness.
52) “Tell Me About the National Forests and Grasslands in Texas”, Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, March 6, 2017.
53) “New 2017 Forest Plan Effort Begins With Assessment”, Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, March 6, 2017.
54) “U.S. Forest Service Holds Public Meetings About Wilderness and Wild and Scenic Rivers for NFGT Forest Plan Assessment”, Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, updated, probably August or September 2017.
55) December 14, 2017, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Robert Potts, U.S. Forest Service, Natural Resources and Planning Team Leader/Staff Officer, comments about “Initial Draft Wilderness inventory for the NFGT Forest Plan Revision”.
56) January 4, 2018, Email from Robert Potts, U.S. Forest Service, Natural Resources and Planning Team Leader/Staff Officer, National Forests and Grasslands in Texas, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about December 17, 2017 comments on “Assessment Phase of the National Forests and Grasslands in Texas Forest Plan revision about Wilderness”.
57) June 15, 2018, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Robert Potts, U.S. Forest Service, Natural Resources and Planning Team Leader/Staff Officer, National Forests and Grasslands in Texas, comments on December 28, 2017 “Wilderness and Designated Area Assessment”.
58) “Forest Service Halts National Forest and Grasslands Forest Plan Revision”, Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, June 27, 2018.
59) December 21, 1994, Letter from Brandt Mannchen, to Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, about observations in Little Lake Creek Wilderness Area.
60) January 20, 1997, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, about observations in Little Lake Creek Wilderness Area.
61) April 26, 1997, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, about observations in Little Lake Creek Wilderness Area.
62) June 22, 1997, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, about April 22, 1997 Sierra Club visit to Little Lake Creek Wilderness Area and erosion found.
63) May 12, 1997, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, about trail maintenance on the Richards Loop of the LSHT and potential for cattle trespass in Little Lake Creek Wilderness Area.
64) December 22, 1997, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, about illegal trails and horse use on the Lone Star Hiking Trail in Little Lake Creek Wilderness Area.
65) January 7, 1998, Letter from Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, to Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, about two illegal trails in Little Lake Creek Wilderness Area.
66) January 26, 1998, Letter from Ronnie Raum, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, to Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, about information request on National Environmental Policy Act documentation for two illegal trails in Little Lake Creek Wilderness Area.
67) “Meeting With Forest Service Concerning Illegal Uses on Lone Star Hiking Trail and Other Issues”, Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, March 3, 1998.
68) March 3, 1998, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Ronnie Raum, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas and Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, about freedom of act information request about illegal trails in Little Lake Creek Wilderness Area and need to conduct National Environmental Policy Act analysis on those trails.
69) March 9, 1998, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Ronnie Raum, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas and Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, providing materials about the Lone Star Hiking Trail and illegal use and illegal trails.
70) April 10, 1998, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, about observations in Little Lake Creek Wilderness Area.
71) August 12, 1998, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Ronnie Raum, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas and Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, about meeting to discuss illegal use and trail issues in Little Lake Creek Wilderness Area.
72) “Meeting With Forest Supervisor About Lone Star Hiking Trail”, Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, September 27, 1998.
73) October 14, 1998, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, about trail maintenance meeting and to report illegal horse use on Lone Star Hiking Trail in Little Lake Creek Wilderness Area.
74) “Meeting about Lone Star Hiking Trail (LSHT) With Forest Supervisor and District Ranger, October 15, 1998”, Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, October 16, 1998.
75) October 18, 1998, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Ronnie Raum, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas and Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, about meeting to discuss illegal use and trail issues in Little Lake Creek Wilderness Area and copy of notes of that meeting.
76) October 22, 1998, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Keith Baker, U.S. Forest Service, Silviculturalist, Sam Houston National Forest, about trails in wilderness.
77) October 27, 1998, Letter from Elizabeth Estill, U.S. Forest Service, Region 8 Regional Forester, to Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, about Freedom of Information Act request for illegal trails in Little Lake Creek Wilderness Area.
78) January 17, 2000, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, about observations that the Sierra Club made on a hike in Little Lake Creek Wilderness Area.
79) February 7, 2000, Letter from Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, to Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, about Sierra Club hike in Little Lake Creek Wilderness Area.
80) February 8, 2000, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, about Lone Star Hiking Trail in Little Lake Creek Wilderness Area.
81) June 13, 2001, Letter from Sue Gregory, to Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, about hikes in Little Lake Creek Wilderness Area and low water.
82) June 21, 2001, Letter from Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, to Sue Gregory, about low water in Little Lake Creek Wilderness Area.
83) June 27, 2001, Letter from Sue Gregory, to Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, about keeping in touch about Little Lake Creek Wilderness Area.
84) July 10, 2001, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Sue Gregory, about “Adopt-a-Wilderness” for Little Lake Creek Wilderness Area.
85) August 13, 2001, Letter from Sue Gregory, to Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Sue Gregory, about “Adopt-a-Wilderness” for the Houston Regional Group of the Sierra Club.
86) August 16, 2001, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Sue Gregory, about “Adopt-a-Wilderness” for Little Lake Creek Wilderness Area.
87) August 20, 2001, Letter from Sue Gregory, to Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, about “Adopt-a-Wilderness” for the Houston Regional Group of the Sierra Club.
88) September 3, 2001, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Sue Gregory, about “Adopt-a-Wilderness” for Little Lake Creek Wilderness Area.
89) September 25, 2001, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, reporting observations about Lone Star Hiking Trail in Little Lake Creek Wilderness Area.
90) November 12, 2001, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, about observations for the Lone Star Hiking Trail and illegal uses.
91) November 14, 2001, Letter from Sue Gregory, to Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, about the need for better recreational use information at kiosks at Lone Star Hiking Trail trailheads.
92) November 2, 2004, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Fred Salinas, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, about illegal trail in Little Lake Creek Wilderness Area.
93) November 9, 2004, Letter from Fred Salinas, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, to Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, about illegal trail in Little Lake Creek Wilderness Area.
94) November 19, 2004, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Fred Salinas, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, about illegal trail in Little Lake Creek Wilderness Area.
95) December 10, 2004, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, about illegal trail in Little Lake Creek Wilderness Area.
96) January 3, 2005, Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, to Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, about illegal trail in Little Lake Creek Wilderness Area.
97) April 23, 2023, Email from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Jason Roesner, U.S. Forest Service, District Ranger, Sam Houston National Forest, about observations in Little Lake creek Wilderness Area and the Lone Star Hiking Trail.
98) “Little Lake Creek Wilderness Area, April 19, 2023, Visit Report”, Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, April 23, 2023.
99) September 9, 1997, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, about U.S. Forest Service letter about upgrading and maintaining the Lone Star Hiking Trail for its entire length.
100) September 11, 1997, Letter from Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, to Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, about U.S. Forest Service letter about upgrading and maintaining the Lone Star Hiking Trail for its entire length.
101) June 8, 1999, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, about trail maintenance in Little Lake Creek Wilderness Area.
102) “Forest Walk in Wilderness Celebrates 35th Anniversary of Wilderness Act and New Millennium”, Brandt Mannchen, Chair, Forestry Subcommittee, Houston Reginal Group of the Sierra Club flyer, undated but probably from December 1999.
103) March 14, 2000, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, about meeting for trial maintenance on the Lone Star Hiking Trail.
104) March 19, 2001, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, observations about trail maintenance on the Lone Star Hiking Trail in Little Lake Creek Wilderness Area.
105) May 15, 2002, Letter from Brandt Mannchen, Chair, Forestry Subcommittee, Houston Regional Group of the Sierra Club, to Tim Bigler, U.S. Forest Service, District Ranger, Sam Houston National Forest, about illegal horse use on the LSHT in Little Lake Creek Wilderness Area.
106) June 12, 2023, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Jason Roesner, U.S. Forest Service, District Ranger, Sam Houston National Forest, observations and photos about the degraded Lone Star Hiking Trail in Little Lake Creek Wilderness Area.
107) January 4, 2015, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Mark Van Every, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, about Wilderness Areas Managed to Minimum Stewardship Level for the five East Texas Wilderness Areas.
108) “Supplemental Information for Determining Accomplishments of Wilderness Areas managed to Minimum Stewardship Level for FR 2014 Reporting”, U.S. Forest Service, Version July 22, 2014.
109) “National Visitor Use Monitoring, Wilderness”, U.S. Forest Service, National Forests and Grasslands in Texas, 2008.
110) “Wilderness Education Plan for: Turkey Hill and Upland Island Wilderness, Angelina National Forest, Big Slough Wilderness, Davy Crockett National Forest, Indian Mounds Wilderness, Sabine National Forest, Little Lake Creek Wilderness, Sam Houston National Forest”, U.S. Forest Service, National Forests and Grasslands in Texas, December 5, 2007.
111) “National Forests in Texas Wilderness Campsite Inventory”, U.S. Forest Service, National Forests and Grasslands in Texas, 2010.
112) “NF’s of Texas Wildernesses – Notes on Matrix”, U.S. Forest Service, National Forests and Grasslands in Texas, 2010.
113) “Recreation Site Monitoring – Field Techniques and Forms for Element 6 of the 10 Year Wilderness Stewardship Challenge” (Campsite Inventory Protocol), U.S. Forest Service, from the Recreation Site Monitoring Toolbox on Wilderness.net, 2010.
114) “Minimum Protocol Campsite Inventory of East Texas Wilderness Areas”, Ryan Grisham and Pat Stephens Williams, September 8, 2014.
115) “Supplemental Documentation to Support the FY 2014 Accomplishment Reporting of Wildernesses Managed to a Minimum Stewardship Level, Turkey Hill and Upland Island Wilderness, Angelina National Forest, Big Slough Wilderness, Davy Crockett National Forest, Indian Mounds Wilderness, Sabine National Forest, Little Lake Creek Wilderness, Sam Houston National Forest”, U.S. Forest Service, National Forests and Grasslands in Texas, Final Version, August 30, 2009.
116) “Wilderness Performance Measure Accomplishment Reports, Big Slough Wilderness, Indian Mounds Wilderness, Little Lake Creek Wilderness, Turkey Hill Wilderness, and Upland Island Wilderness”, U.S. Forest Service, National Forests in Texas, December 16, 2014.
117) “Crosswalk from 10YWSC to Wilderness Stewardship Performance”, U.S. Forest Service, Version 1, February 12, 2015.
118) “Air Quality Values Monitoring Plan, Wilderness Stewardship Challenge,” U.S. Forest Service, National Forests and Grasslands in Texas, undated.
119) December 12, 2014, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Mary Frye, U.S. Forest Service, National Forests and Grasslands in Texas, about documents for U.S. Forest Service Wilderness Challenge monitoring survey.
120) December 17, 2014, Email from Nancy Snoberger, U.S. Forest Service, National Forests and Grasslands in Texas, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about documents for U.S. Forest Service Wilderness Challenge monitoring survey.
121) December 17, 2014, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Nancy Snoberger, U.S. Forest Service, National Forests and Grasslands in Texas, about documents for U.S. Forest Service Wilderness Challenge monitoring survey.
122) December 22, 2014, Email from Nancy Snoberger, U.S. Forest Service, National Forests and Grasslands in Texas, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about documents for U.S. Forest Service Wilderness Challenge monitoring survey.
123) December 22, 2014, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Nancy Snoberger, U.S. Forest Service, National Forests and Grasslands in Texas, about documents for U.S. Forest Service Wilderness Challenge monitoring survey.
124) February 24, 2016, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Mark Van Every, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, about questions and documents that needed to be answered or sent from the January 4, 2015 letter about the U.S. Forest Service Wilderness Challenge monitoring survey.
125) February 24, 2016, Email from Mark Van Every, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about questions and documents that needed to be answered or sent from the January 4, 2015 letter about the U.S. Forest Service Wilderness Challenge monitoring survey.
126) April 9, 2016, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Mark Van Every, U.S. Forest Service, Forest Supervisor, National Forests and Grasslands in Texas, about questions and documents that needed to be answered or sent from the January 4, 2015 letter about the U.S. Forest Service Wilderness Challenge monitoring survey.
127) April 18, 2016, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Robert Potts and April Heesacker, U.S. Forest Service, National Forests and Grasslands in Texas, about questions and documents that needed to be answered or sent from the January 4, 2015 letter about the U.S. Forest Service Wilderness Challenge monitoring survey.
128) April 18, 2016, Email from April Heesacker, U.S. Forest Service, National Forests and Grasslands in Texas, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about questions and documents that needed to be answered or sent from the January 4, 2015 letter about the U.S. Forest Service Wilderness Challenge monitoring survey.
129) April 20, 2016, Email from April Heesacker, U.S. Forest Service, National Forests and Grasslands in Texas, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about questions and documents that needed to be answered or sent from the January 4, 2015 letter about the U.S. Forest Service Wilderness Challenge monitoring survey.
130) April 25, 2016, Email from April Heesacker, U.S. Forest Service, National Forests and Grasslands in Texas, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about questions and documents that needed to be answered or sent from the January 4, 2015 letter about the U.S. Forest Service Wilderness Challenge monitoring survey.
131) April 27, 2016, Email from April Heesacker, U.S. Forest Service, National Forests and Grasslands in Texas, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about questions and documents that needed to be answered or sent from the January 4, 2015 letter about the U.S. Forest Service Wilderness Challenge monitoring survey.
132) April 29, 2016, Email from April Heesacker, U.S. Forest Service, National Forests and Grasslands in Texas, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about questions and documents that needed to be answered or sent from the January 4, 2015 letter about the U.S. Forest Service Wilderness Challenge monitoring survey.
133) “Keep It Wild2: An Updated Interagency Strategy to Monitor Trends in Wilderness Character Across the National Wilderness Preservation System”, Peter Landres, et. al., U.S. Department of Agriculture, Forest Service, General Technical Report RMRS-GTR-340, 2015.
134) “The Definition of Wilderness Character in “Keeping It Wild” Jeopardizes the Wildness of Wilderness”, David Cole, Ed Zahnizer, Doug Scott, Roger Kaye, Kevin Proescholdt, and George Nickas, September 2015.
135) March 16, 2016, Letter from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Dr. Peter Landres, Research ecologist, Aldo Leopold Wilderness Research Institute, comments about “Keeping It Wild 2” document.
136) “Sierra Club Wildland and Wilderness Team’s Preliminary Comments on the Forest Service’s Wilderness Character Monitoring Technical Guide”, comments from Clayton Daughenbaugh, Anne Henny, David Sublette, Gary Macfarlane, Norm Sharp, and Jim Margadant, Sierra Club Wildland and Wilderness Team, September 29, 2016.
137) “Wilderness Character Monitoring Technical Guide”, Peter Landres, Steve Boutcher, Elizabeth Mejicano, and Eric Sandeno, U.S. Department of Agriculture, Forest Service, General Technical Report RMMR-GTR-400, December 2020.
138) June 4, 2021, Email from Larry Shelton, Texas Conservation Alliance, to Kimpton Cooper, U.S. Forest Service, District Ranger, Angelina/Sabine National Forests, about runoff erosion from Forest Road 314 into Upland Island Wilderness Area.
139) June 4, 2021, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Kimpton Cooper, U.S. Forest Service, District Ranger, Angelina/Sabine National Forests, about runoff erosion from Forest Road 314 into Upland Island Wilderness Area.
140) June 8, 2021, Email from Kimpton Cooper, U.S. Forest Service, District Ranger, Angelina/Sabine National Forests, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about runoff erosion from Forest Road 314 into Upland Island Wilderness Area.
141) June 22 2021, Email from Kimpton Cooper, U.S. Forest Service, District Ranger, Angelina/Sabine National Forests, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about runoff erosion from Forest Road 314 into Upland Island Wilderness Area.
142) June 22, 2021, Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Kimpton Cooper, U.S. Forest Service, District Ranger, Angelina/Sabine National Forests, about runoff erosion from Forest Road 314 into Upland Island Wilderness Area.
143) June 23, 2021, Email from Larry Shelton, Texas Conservation Alliance, to Kimpton Cooper, U.S. Forest Service, District Ranger, Angelina/Sabine National Forests, about runoff erosion from Forest Road 314 into Upland Island Wilderness Area.
145) October 8, 2021, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Kimpton Cooper, U.S. Forest Service, District Ranger, Angelina/Sabine National Forests, about runoff erosion from Forest Road 314 into Upland Island Wilderness Area.
146) “Forest Visit Brings Interest and Surprises in December”, Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, December 17, 2021.
147) December 17, 2021, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Kimpton Cooper, U.S. Forest Service, District Ranger, Angelina/Sabine National Forests, about runoff erosion from Forest Road 314 into Upland Island Wilderness Area.
148) December 17, 2021, Email from Logan Gallant, U.S. Forest Service, District Ranger, Angelina/Sabine National Forests, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about runoff erosion from Forest Road 314 into Upland Island Wilderness Area.
149) December 23, 2001, Email from Robert Potts, U.S. Forest Service, Natural Resources and Planning/Staff Officer, National Forests and Grasslands in Texas, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about runoff erosion from Forest Road 314 into Upland Island Wilderness Area.
150) December 26, 2021, Email from Logan Gallant, U.S. Forest Service, District Ranger, Angelia/Sabine National Forests, National Forests and Grasslands in Texas, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about runoff erosion from Forest Road 314 into Upland Island Wilderness Area.
151) January 27, 2022, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Logan Gallant, U.S. Forest Service, District Ranger, Angelina/Sabine National Forests, about runoff erosion from Forest Road 314 into Upland Island Wilderness Area.
152) January 27, 2022, Email from Robert Potts, FS, Natural Resource and Planning Staff, National Forests and Grasslands in Texas, to Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about runoff erosion from Forest Road 314 into Upland Island Wilderness Area.
153) January 27, 2022, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Logan Gallant, U.S. Forest Service, District Ranger, Angelina/Sabine National Forests, about photos of runoff erosion from Forest Road 314 into Upland Island Wilderness Area.
154) “Road Erosion Addressed in Upland Island Wilderness Area”, Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, January 28, 2022.
155) January 31, 2022, Email from Logan Gallant, U.S. Forest Service, District Ranger, Angelia/Sabine National Forests, National Forests and Grasslands in Texas, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about runoff erosion from Forest Road 314 into Upland Island Wilderness Area.
156) October 12, 2022, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Logan Gallant, U.S. Forest Service, District Ranger, Angelina/Sabine National Forests, about runoff erosion from Forest Road 314 into Upland Island Wilderness Area.
157) October 12, 2022, Email from Logan Gallant, U.S. Forest Service, District Ranger, Angelia/Sabine National Forests, National Forests and Grasslands in Texas, to Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, about runoff erosion from Forest Road 314 into Upland Island Wilderness Area.
158) October 12, 2022, Email from Brandt Mannchen, Forest Management Issue Chair, Lone Star Chapter of the Sierra Club, to Logan Gallant, U.S. Forest Service, District Ranger, Angelina/Sabine National Forests, about of runoff erosion from Forest Road 314 into Upland Island Wilderness Area.
159) October 19, 2022, Email from Larry Shelton, Texas Conservation Alliance, to
Logan Gallant, U.S. Forest Service, District Ranger, Angelina/Sabine National Forests, about runoff erosion from Forest Road 314 into Upland Island Wilderness Area.
160) February 1, 2023, Letter from Larry Shelton, Texas Conservation Alliance, to
Logan Gallant, U.S. Forest Service, District Ranger, Angelina/Sabine National Forests, about prescribed burning as a source of increased erosion in Upland Island Wilderness Area.