Visit the Central Cascades while you still can...

[jessbee]

I specifically asked them how they expect to enforce additional regulations if they don't have the budget to enforce the current ones, and their answer was that the revenue will come from the new user fees. It seems like they have all their eggs in that basket, which presumably makes the outcome of this process a foregone conclusion. They said they have data showing high compliance with permits/limited entry, so it appears they expect this will work. If only their proposal had been to drum up stakeholder support to push Congress to give the FS more funding!

This is hilarious because it is easy to enforce regulations when you're only limiting entry on two trails: you post two rangers there.

So how are they planning to enforce limited entry at 80 trailheads? The revenue earned from this permit system will not cover the cost of 78 new rangers. Oh wait, we haven't come up with cost yet... So if they do the math those are going to be some damned expensive permits.

[Aimless]

If only their proposal had been to drum up stakeholder support to push Congress to give the FS more funding!

I may be mistaken, but I believe the Hatch Act forbids federal employees in civil service jobs from undertaking any overt political activity in their capacity as public employees. So even though this may sound like a sensible thought that they should have pursued, it would have brought the wrath of Congress down on their heads. Basically, they can directly ask Congress for a bigger budget as part of the budget process, but they can't lobby the public to push Congress into giving it to them, unless it is on their own time and in no way trying to leverage their position in the government for greater advantage. That's why you'll often see people writing letters to the editor identifying themselves as retired public employees, but not as current ones, unless they hold a position that is filled by political appointment instead of civil service.

[retired jerry]

email - phone scheduled for 21st or 22nd

[cunningkeith]

So I attended my meeting today. There were only 44 objections filed.

According to this article, the FS says 96 objections were filed

https://www.ktvz.com/news/nearly-100-fi ... 1021711970

Of course, the article gets other things wrong, so who knows?

[jessbee]

So I attended my meeting today. There were only 44 objections filed.

According to this article, the FS says 96 objections were filed

https://www.ktvz.com/news/nearly-100-fi ... 1021711970

Of course, the article gets other things wrong, so who knows?

Yeah I was confused about that because in the meeting, Beth Peer cited only 44 objections. I saw more than that were posted on their website though. The whole process is utterly screwy.

[Aimless]

It's my understanding that at the second stage of the public comment process, further objections must specifically cite ways in which the proposed permit/fee system are in conflict with existing law, or with Forest Service policies, or other public interests the FS is required to consider, or else they are not considered as having any bearing on the adoption of the final plan. I'm guessing here, but maybe there were 96 objections filed, while only 44 were considered as having substance or bearing on the final process.

[retired jerry]

according to the wilderness act

https://www.govinfo.gov/content/pkg/STA ... -Pg890.pdf

"wilderness areas shall be devoted to the public purposes of recreational, scenic, scientific, educational, conservation, and historical use"

if they don't let us use the wilderness because all the permits are issued, then they're not providing recreational use

kind of a stretch, but...

I wonder if there are any court cases that would be relevant. Like what is it, the Adams case talks about charging people to use the national forest? Maybe there are cases about people being restricted from use. There's a case where they wanted to build a water tank in the wilderness to keep a sustainable wildlife population, normally they can't build things in the wilderness but I think this was a valid exception.

[retired jerry]

https://www.wilderness.net/NWPS/documen ... se_Law.pdf

In "American Whitewater v. Tidwell, 959 F.Supp.2d 839 (D.S.C. 2013)" Forest Service restricted whitewater rafting to Chattooga headwaters. "Holding: The USFS did not violate the Wilderness Act by proposing a plan that established limitations that do not allow whitewater rafting in the Headwaters. The USFS has not banned whitewater floating
altogether, but rather established certain limitations that allow for whitewater floating in other areas of the river while addressing other environmental and recreational concerns and interests. The USFS presented evidence to demonstrate that it considered and balanced, among others, the recreational and solitary goals of the Act"

So, in restricting access to Three Sisters, are they allowing access elsewhere? It sounds like they're restricting access to the entire Wilderness and adjoining Wildernesses. Maybe the Forest Service should only be restricting access to crowded areas?

I think this addresses Aimless "It's my understanding that at the second stage of the public comment process, further objections must specifically cite ways in which the proposed permit/fee system are in conflict with existing law"

Although interpreting cases like this is tricky, and whether it would be applicable to our case

[oldandslow]

I assume that someone who knows how to do legal research has determined that the Forest has the legal authority to charge the fees that they are proposing to enforce the restrictions on access.

[retired jerry]

I just talked to John and Beth on the phone

They said there'd be a plan announced in a few months, then one year for public outreach, so effective for 2020 summer

Limited number of day use permits for about half the trailheads in Three Sisters Wilderness

Limited number of overnight permits for all trailheads in Three Sisters

Estimated that there should be permits available for at least some trailheads at all times except holiday weekends

I assume permit is from recreation.gov, a fee like $5 or $10 a night

I disagreed that they should have limited number of overnight permits, they should make parking areas bigger and trails wider to accommodate the number of people. Better to concentrate the usage to high use areas like Green Lakes to preserve the rest of the wilderness.

I assume my commenting is futile. This is basically a done deal. Maybe when they release their plan, if there's enough protest, they might reconsider.

They also said they were considering building some new trails that go to alpine viewpoints that are outside a wilderness with no restrictions