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The Forest Service has extended the comment period
until March 20, 2008 to submit comments on the proposed outfitter-guide rules. Please take this opportunity to protect Wilderness from increased
commercialization and harm. The alert below contains information that can help
in preparing your comments.
Thank much,
Proposed Administration Policy is a Giveaway to
Commercial Outfitters and Guides
Ten years ago Senator Larry Craig of
Idaho introduced legislation that constituted an incredible giveaway to the
commercial outfitting industry. The 56-page "Outfitter Policy Act," written by
industry lobbyists, would have granted private property rights for outfitter
permits and lowered resource protection and outfitter performance standards,
while making it virtually impossible for federal agencies to enforce even the
weakened rules. The bill went nowhere, nor did similar bills introduced by Sen.
Craig in subsequent Congresses, but the industry didn't give up. Instead, it
turned to the Administration and its toadies in the Forest Service to get what
it wanted. The result is a recently proposed rulemaking change by the Forest
Service that will give the outfitters much of what they sought at the expense of
Wilderness and self-guided visitors.
Your comments are needed to help
stop this destructive giveaway and protect Wilderness from exploitation. Now is
the time to stand up and protect your right to Wilderness that remains largely
free of commercial enterprise and that provides outstanding opportunities for
solitude and primitive and unconfined recreation.
Please ACT NOW! Your
comments must be received by March 20, 2008.
The myriad and
seemingly small changes spread over 32 pages of the propose rules will have the
cumulative effect of significantly favoring the interests of commercial
outfitters over resource protection and the publics' interest. The suggestions
below will restore key provisions of current rules and help to tip the scales
back in favor of protecting Wilderness and other public
lands.
SUGGESTED COMMENT POINTS:
The proposed regulations should be supplemented
to require that the issuance of permits must undergo analysis under the National
Environmental Policy Act (NEPA) prior to allowing and/or allocating
outfitter/guide use. The maximum permit term should be 5 years, as has
been customary on national forest lands. Reissuance of permits should be
reviewed under NEPA at least once every 10 years. Similarly, a new permit should
be required for any new commercial service or activity. For example, permitting
an existing commercial operator that provides pack stock service to provide new
services such as pack trips into a nearby Wilderness or cross-country skiing
must be disclosed and analyzed because the impacts may be very
different.
The wording regarding "Needs Assessments" for
commercial services in Wilderness should be changed to reflect that the
Wilderness Act limits the amount and type of commercial outfitting to only that
which has been shown to be both "necessary" and "proper." Market demand does
not determine the "need" for commercial services. Under no condition should
commercial services be allowed to impair wilderness character. No new
commercial permits should be issued where current use levels meet or exceed an
area's carrying capacity.
The proposed wording regarding development,
improvements, installations, and caches in Wilderness should be changed to
prohibit such things. Commercial outfitters must be held to the same "leave no
trace" standard as self-guided visitors. All outfitters should be setting an
example for others to follow. Conscientious outfitters, of which there are
many, already do this.
The proposed definition of "Assigned Site" that
allows commercial interests to monopolize prime campsites, launch ramps, or
hunting or fishing locations should be deleted. There should be no Assigned
Sites specifically set aside for outfitter, guide or non-profit use. All
visitors should have equal opportunity to use available
sites.
The rule should prohibit commercial groups from
exceeding the group size limits imposed on other visitors. Too many people,
boats, or stock, are too many, regardless of whether it is a self-guided group
or a commercial group.
The proposal to authorize outfitting and guiding
under the Federal Lands Recreation Enhancement Act ("RAT tax") should be
deleted. This language in the rule is an unlawful attempt by the Forest Service
to collect fees to use public lands, and it serves as a perverse incentive to
increase commercial use, even at the expense of the
resource.
When reductions in use are needed based on
changed resource, administrative or social conditions, the reductions should not
be voluntary, as proposed in section 41.53m. Commercial use of public lands is
a privilege, not a right.
Where demand exceeds capacity and quotas are in
place, the rule should promote Common Pool or Freedom of Choice permit systems,
whereby all citizens have an equal opportunity to obtain a permit. In
Wilderness, these systems must also be consistent with the limitations imposed
by the "needs assessment."
The provisions described above will go a long way
toward preserving the unique values of our Wilderness lands and the publics
ability to use and enjoy these lands. Your letters urging the Forest Service to
adopt these changes to the policy are essential to making that happen! Please write today! Remember, comments must be received by March 20, 2008. Keep in mind that comments written in your own words will carry the most
weight.
How to Submit Comments:
A. Electronically (they
don't make it simple, be patient and follow these instructions):
1. click
here: www.regulations.gov
2. click on the hyperlink in the How to Comment
section.
3. In the Comment or Submission box enter "Forest Service
outfitting and guiding". Click on "go"
4. click on "Send a comment or
submission."
5. enter, paste-in, or attach your comments.
B. For
a shortcut, some browsers will get you directly to the comment page with this
link.
C. U.S. Mail: (remember to allow sufficient time, deadline
is not a postmark date):
U.S. Forest Service
Attn: Carolyn
Holbrook, Recreation and Heritage Resources Staff (2720)
1400 Independence
Avenue, SW., Stop 1125
Washington, DC 20250-1125
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