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."

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