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Wilderness: Enough is Enough 
1 
What 
is 
Wilderness? 
In 
common 
usage, 
“wilderness” 
is 
used 
to 
describe 
lands 
that 
represent 
some 
idyllic 
notion 
of 
preservation, 
calm, 
ecological 
balance, 
and 
psychological 
escape. 
In 
the 
public 
lands 
world, 
Wilderness 
is 
a 
formal 
land 
designation 
that 
can 
be 
accomplished 
only 
by 
Congress. 
The 
1964 
Wilderness 
Act 
was 
the 
product 
of 
8 
years 
of 
Congressional 
debate 
requiring 
60 
bill 
drafts 
to 
reach 
an 
agreement. 
The 
Act 
is 
considered 
a 
crowning 
achievement 
by 
some, 
but 
it 
represents 
perhaps 
the 
most 
restrictive 
language 
in 
the 
preservation 
world, 
defining 
Wilderness 
as 
a 
place 
“where 
the 
earth 
and 
its 
community 
of 
life 
are 
untrammeled 
by 
man, 
where 
man 
himself 
is 
a 
visitor 
who 
does 
not 
remain.” 
16 
U.S.C. 
1131. 
The 
1964 
Act 
prohibits 
commercial 
enterprises, 
roads, 
motorized 
vehicles 
or 
equipment, 
landing 
of 
aircraft, 
mechanical 
transport, 
or 
any 
structure 
or 
installation. 
16 
U.S.C. 
1133. 
You 
cannot 
ride 
a 
mountain 
bike 
in 
Wilderness. 
You 
cannot 
even 
pull 
a 
wheeled 
cart 
to 
remove 
elk 
quarters 
since 
that 
is 
considered 
“mechanical 
transport.” 
How 
much 
Wilderness 
Do 
We 
Have 
– 
Do 
We 
Need 
More? 
In 
Colorado, 
there 
are 
about 
3.7 
million 
acres 
of 
Congressionally 
designated 
Wilderness 
in 
our 
National 
Forests 
or 
approximately 
15% 
of 
all 
USFS 
lands. 
Another 
210,984 
acres 
of 
Wilderness 
are 
located 
within 
Colorado’s 
BLM 
boundaries 
and 
306,081 
acres 
are 
located 
in 
Colorado’s 
National 
Parks. 
In 
total, 
there 
are 
4.2 
million 
acres 
of 
designated 
Wilderness 
in 
Colorado. 
This 
is 
an 
area 
larger 
than 
the 
states 
of 
Rhode 
Island 
and 
Delaware 
combined! 
Across 
all 
agencies, 
there 
is 
over 
107 
million 
acres 
of 
designated 
Wilderness 
nationally! 
If 
we 
somehow 
wanted 
to 
“maximize” 
our 
Wilderness 
by 
putting 
all 
lands 
under 
Wilderness 
designation, 
we 
could 
not 
as 
the 
remaining 
undesignated 
lands 
do 
not 
meet 
the 
lofty 
standards 
of 
the 
1964 
Act. 
Through 
a 
web 
of 
statutes, 
regulations, 
and 
bureaucratic 
directives, 
the 
agencies 
have 
for 
decades 
studied 
lands 
with 
possible 
Wilderness 
characteristics. 
For 
instance, 
the 
San 
Juan 
Forest 
contains 
a 
total 
of 
1.867 
million 
acres 
of 
National 
Forest 
System 
lands, 
of 
which 
755,954 
acres 
are 
Wilderness 
created 
by 
Congress 
in 
1975, 
1980 
and 
1993. 
http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5435600.pdf. 
Many 
of 
the 
remaining 
lands 
were 
specifically 
“released” 
by 
Congress 
from 
future 
consideration 
as 
Wilderness, 
or 
have 
been 
studied 
by 
the 
agency 
and 
deemed 
unsuitable 
for 
Wilderness 
designation. 
Finally, 
visitor 
use 
statistics 
do 
not 
suggest 
that 
we 
need 
more 
Wilderness. 
Nationally, 
only 
about 
5 
percent 
of 
user 
visits 
to 
the 
Forest 
System 
are 
in 
Wilderness 
areas. 
The 
visitation 
figure 
for 
the 
Rocky 
Mountain 
region 
is 
even 
lower, 
about 
4 
percent, 
despite 
over 
15% 
of 
USFS 
lands 
in 
Colorado 
being 
Congressionally 
designated 
Wilderness. 
http://www.fs.fed.us/recreation/programs/nvum/2012%20National_Summary_Report_061413.pdf. 
Congress 
has 
amply 
addressed 
both 
need 
and 
demand 
for 
Wilderness 
in 
Colorado.
2 
Wilderness 
Economics: 
Wilderness 
advocates 
frequently 
claim 
new 
Congressional 
designations 
of 
Wilderness 
areas 
will 
drive 
economic 
growth, 
which 
claims 
are 
supported 
by 
generalized 
assertions 
by 
the 
Outdoor 
Industry 
Association 
(OIA) 
research 
findings 
that 
outdoor 
recreation 
is 
$646 
Billion 
dollar 
a 
year 
industry. 
The 
relationship 
of 
this 
research 
and 
Congressionally 
designated 
Wilderness 
is 
unclear 
at 
best, 
as 
the 
OIA 
research 
specifically 
includes 
valuations 
of 
activities 
such 
as 
motorized 
recreation, 
Bicycling, 
RV 
camping, 
and 
Snowmobiling. 
http://outdoorindustry.org/images/researchfiles/OIA_OutdoorRecEconomyReport2012.pdf 
The 
lack 
of 
clarity 
in 
this 
relationship 
is 
based 
on 
the 
fact 
these 
activities 
are 
illegal 
in 
Congressionally 
designated 
Wilderness 
areas. 
In 
reality, 
most 
Americans 
are, 
for 
various 
reasons, 
unable 
or 
unwilling 
to 
enlist 
in 
the 
rigorous 
adventures 
of 
Congressionally 
designated 
Wilderness 
areas. 
The 
hunting 
community 
has 
concluded 
that 
" 
access 
is 
the 
most 
important 
factor 
associated 
with 
hunting 
participation 
that 
is 
not 
a 
time-­‐related 
or 
demographic 
factor—in 
other 
words, 
the 
most 
important 
factor 
over 
which 
agencies 
and 
organizations 
can 
have 
an 
important 
influence." 
This 
research 
continues: 
" 
Data 
show 
that 
hunters 
use 
many 
different 
modes 
of 
transportation 
to 
access 
the 
land 
on 
which 
they 
hunt: 
70% 
use 
a 
car 
or 
truck 
(by 
far 
the 
top 
mode 
of 
transportation), 
followed 
by 
walking 
(51%) 
and 
ATV 
(16%)" 
http://www.nssf.org/PDF/research/HuntingAccessReport2011.pdf 
While 
Wilderness 
advocates 
have 
provided 
a 
wide 
range 
of 
their 
own 
research 
to 
support 
the 
position 
that 
recreational 
usage 
of 
Wilderness 
is 
an 
economic 
driver, 
USFS 
research 
does 
not 
support 
this 
position. 
USFS 
research 
and 
conclusions 
are 
based 
on 
over 
20 
years 
of 
user 
group 
research, 
and 
generally 
recognized 
as 
the 
best 
available 
science. 
These 
conclusions 
are 
clear 
and 
find 
users 
excluded 
by 
a 
Congressional 
Wilderness 
designation 
spend 
far 
more 
per 
day 
than 
those 
choosing 
to 
recreate 
in 
Wilderness 
areas. 
http://www.fsl.orst.edu/lulcd/Publicationsalpha_files/White_Stynes_NVUM2010b.pdf 
The 
lower 
per 
day 
per 
visitor 
spending 
profile 
of 
Wilderness 
users 
compounds 
concerns 
regarding 
the 
limited 
visitation 
of 
the 
public 
to 
Congressionally 
designated 
Wilderness 
areas 
for 
recreation. 
Other 
researchers 
have 
stated 
this 
relationship 
as 
follows: 
“The 
argument 
often 
stated 
by 
the 
environmental 
community 
that 
Wilderness 
is 
good 
for 
local 
economies 
is 
simply 
not 
supported 
by 
the 
data. 
When 
comparing 
Wilderness 
and 
Non-­‐Wilderness 
Counties, 
Wilderness 
Counties 
are 
at 
an 
economic 
disadvantage 
to 
their 
Non-­‐Wilderness 
counterparts.” 
http://www.environmentaltrends.org/single/article/the-­‐economic-­‐costs-­‐of-­‐wilderness.html. 
Wilderness 
and 
Forest 
Health 
Well, 
if 
Wilderness 
does 
not 
create 
economic 
growth, 
is 
that 
an 
acceptable 
tradeoff 
for 
the 
extreme 
protection 
of 
Mother 
Earth 
and 
the 
ecological 
sanctity 
we 
create 
through 
Wilderness? 
Absolutely 
not. 
Hundreds 
of 
millions 
of 
humans 
have 
tipped 
the 
ecological 
balance, 
and 
our 
impacts 
must 
be 
managed. 
There 
is 
a 
tension 
inherent 
in 
the 
concept 
of 
Wilderness, 
that 
areas 
will 
be 
“healthy” 
if 
they 
are 
left 
alone. 
However, 
our 
forests 
face 
broad-­‐scale 
ecological 
threats 
that 
require 
well 
designed 
management 
responses 
that 
do 
not 
stop 
at 
the 
Wilderness 
boundary. 
In 
Colorado, 
we 
only 
need 
to 
look 
outside 
to 
see 
the 
devastation 
tied 
to 
catastrophic 
wildfires 
and 
the 
pine 
and 
spruce 
beetle 
outbreaks. 
An 
ecological 
imbalance 
developed 
over 
time 
because 
“widespread 
treatments 
in 
lodgepole 
pine 
stands 
that 
would 
have 
created 
age 
class 
diversity, 
enhanced 
the 
vigor 
of 
remaining 
trees, 
and 
improved 
stand 
resiliency 
to 
drought 
or 
insect 
attack—such 
as 
timber 
harvest 
and 
thinning 
— 
lacked 
public 
acceptance. 
Proposals 
for 
such 
practices 
were 
routinely 
appealed 
and 
litigated, 
constraining 
the 
ability 
of 
the 
Forest 
Service 
to 
manage
what 
had 
become 
large 
expanses 
of 
even-­‐aged 
stands 
susceptible 
to 
a 
bark 
beetle 
outbreak.” 
http://www.frontrangeroundtable.org/uploads/Udall_Bark_Beetle_Report_2011.pdf. 
Factors 
leading 
to 
this 
perfect 
ecological 
storm 
included 
“[l]imited 
accessibility 
of 
terrain 
(only 
25% 
of 
the 
outbreak 
area 
was 
accessible 
due 
to 
steep 
slopes, 
lack 
of 
existing 
roads, 
and 
land 
use 
designations 
such 
as 
Wilderness 
that 
precluded 
treatments 
needed 
to 
reduce 
susceptibility 
to 
insects 
and 
disease).” 
The 
Wilderness 
Lobby 
Today’s 
“environmentalists” 
are 
not 
counter 
culture 
heroes 
fighting 
the 
establishment 
from 
the 
back 
of 
a 
rainbow 
hued 
microbus. 
They 
are 
sophisticated, 
well-­‐funded 
organizations 
who 
pay 
their 
talent 
as 
much 
or 
more 
as 
their 
counterparts 
in 
corporate 
America, 
with 
the 
blessing 
of 
“our” 
government. 
The 
Wilderness 
Society 
is 
a 
tax-­‐exempt 
nonprofit 
leader 
in 
the 
Wilderness 
advocacy 
movement. 
Its 
2011 
IRS 
filings 
list 
annual 
revenue 
of 
about 
25 
million, 
with 
listed 
employees’ 
annual 
compensation 
ranging 
from 
$200,000 
to 
$421,664! 
http://wilderness.org/sites/default/files/TWS%202011%20Form%20990.pdf. 
This 
doesn’t 
include 
their 
lawyers, 
who 
work 
for 
separate 
nonprofit 
organizations, 
such 
as 
Earthjustice, 
which 
the 
IRS 
considers 
“public 
interest” 
law 
firms, 
whose 
top 
employees 
in 
2012 
received 
from 
$156,000 
to 
$395,114. 
http://earthjustice.org/sites/default/files/Earthjustice-­‐Form-­‐990-­‐FY13_0.pdf. 
Their 
mission 
is 
to 
create 
more 
Wilderness. 
They 
aren’t 
ever 
going 
to 
be 
“finished.” 
Please 
join 
us 
in 
maintaining 
diverse 
recreation 
and 
calling 
ENOUGH 
on 
Wilderness 
in 
Colorado. 
3

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Wilderness: Enough is Enough

  • 1. Wilderness: Enough is Enough 1 What is Wilderness? In common usage, “wilderness” is used to describe lands that represent some idyllic notion of preservation, calm, ecological balance, and psychological escape. In the public lands world, Wilderness is a formal land designation that can be accomplished only by Congress. The 1964 Wilderness Act was the product of 8 years of Congressional debate requiring 60 bill drafts to reach an agreement. The Act is considered a crowning achievement by some, but it represents perhaps the most restrictive language in the preservation world, defining Wilderness as a place “where the earth and its community of life are untrammeled by man, where man himself is a visitor who does not remain.” 16 U.S.C. 1131. The 1964 Act prohibits commercial enterprises, roads, motorized vehicles or equipment, landing of aircraft, mechanical transport, or any structure or installation. 16 U.S.C. 1133. You cannot ride a mountain bike in Wilderness. You cannot even pull a wheeled cart to remove elk quarters since that is considered “mechanical transport.” How much Wilderness Do We Have – Do We Need More? In Colorado, there are about 3.7 million acres of Congressionally designated Wilderness in our National Forests or approximately 15% of all USFS lands. Another 210,984 acres of Wilderness are located within Colorado’s BLM boundaries and 306,081 acres are located in Colorado’s National Parks. In total, there are 4.2 million acres of designated Wilderness in Colorado. This is an area larger than the states of Rhode Island and Delaware combined! Across all agencies, there is over 107 million acres of designated Wilderness nationally! If we somehow wanted to “maximize” our Wilderness by putting all lands under Wilderness designation, we could not as the remaining undesignated lands do not meet the lofty standards of the 1964 Act. Through a web of statutes, regulations, and bureaucratic directives, the agencies have for decades studied lands with possible Wilderness characteristics. For instance, the San Juan Forest contains a total of 1.867 million acres of National Forest System lands, of which 755,954 acres are Wilderness created by Congress in 1975, 1980 and 1993. http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5435600.pdf. Many of the remaining lands were specifically “released” by Congress from future consideration as Wilderness, or have been studied by the agency and deemed unsuitable for Wilderness designation. Finally, visitor use statistics do not suggest that we need more Wilderness. Nationally, only about 5 percent of user visits to the Forest System are in Wilderness areas. The visitation figure for the Rocky Mountain region is even lower, about 4 percent, despite over 15% of USFS lands in Colorado being Congressionally designated Wilderness. http://www.fs.fed.us/recreation/programs/nvum/2012%20National_Summary_Report_061413.pdf. Congress has amply addressed both need and demand for Wilderness in Colorado.
  • 2. 2 Wilderness Economics: Wilderness advocates frequently claim new Congressional designations of Wilderness areas will drive economic growth, which claims are supported by generalized assertions by the Outdoor Industry Association (OIA) research findings that outdoor recreation is $646 Billion dollar a year industry. The relationship of this research and Congressionally designated Wilderness is unclear at best, as the OIA research specifically includes valuations of activities such as motorized recreation, Bicycling, RV camping, and Snowmobiling. http://outdoorindustry.org/images/researchfiles/OIA_OutdoorRecEconomyReport2012.pdf The lack of clarity in this relationship is based on the fact these activities are illegal in Congressionally designated Wilderness areas. In reality, most Americans are, for various reasons, unable or unwilling to enlist in the rigorous adventures of Congressionally designated Wilderness areas. The hunting community has concluded that " access is the most important factor associated with hunting participation that is not a time-­‐related or demographic factor—in other words, the most important factor over which agencies and organizations can have an important influence." This research continues: " Data show that hunters use many different modes of transportation to access the land on which they hunt: 70% use a car or truck (by far the top mode of transportation), followed by walking (51%) and ATV (16%)" http://www.nssf.org/PDF/research/HuntingAccessReport2011.pdf While Wilderness advocates have provided a wide range of their own research to support the position that recreational usage of Wilderness is an economic driver, USFS research does not support this position. USFS research and conclusions are based on over 20 years of user group research, and generally recognized as the best available science. These conclusions are clear and find users excluded by a Congressional Wilderness designation spend far more per day than those choosing to recreate in Wilderness areas. http://www.fsl.orst.edu/lulcd/Publicationsalpha_files/White_Stynes_NVUM2010b.pdf The lower per day per visitor spending profile of Wilderness users compounds concerns regarding the limited visitation of the public to Congressionally designated Wilderness areas for recreation. Other researchers have stated this relationship as follows: “The argument often stated by the environmental community that Wilderness is good for local economies is simply not supported by the data. When comparing Wilderness and Non-­‐Wilderness Counties, Wilderness Counties are at an economic disadvantage to their Non-­‐Wilderness counterparts.” http://www.environmentaltrends.org/single/article/the-­‐economic-­‐costs-­‐of-­‐wilderness.html. Wilderness and Forest Health Well, if Wilderness does not create economic growth, is that an acceptable tradeoff for the extreme protection of Mother Earth and the ecological sanctity we create through Wilderness? Absolutely not. Hundreds of millions of humans have tipped the ecological balance, and our impacts must be managed. There is a tension inherent in the concept of Wilderness, that areas will be “healthy” if they are left alone. However, our forests face broad-­‐scale ecological threats that require well designed management responses that do not stop at the Wilderness boundary. In Colorado, we only need to look outside to see the devastation tied to catastrophic wildfires and the pine and spruce beetle outbreaks. An ecological imbalance developed over time because “widespread treatments in lodgepole pine stands that would have created age class diversity, enhanced the vigor of remaining trees, and improved stand resiliency to drought or insect attack—such as timber harvest and thinning — lacked public acceptance. Proposals for such practices were routinely appealed and litigated, constraining the ability of the Forest Service to manage
  • 3. what had become large expanses of even-­‐aged stands susceptible to a bark beetle outbreak.” http://www.frontrangeroundtable.org/uploads/Udall_Bark_Beetle_Report_2011.pdf. Factors leading to this perfect ecological storm included “[l]imited accessibility of terrain (only 25% of the outbreak area was accessible due to steep slopes, lack of existing roads, and land use designations such as Wilderness that precluded treatments needed to reduce susceptibility to insects and disease).” The Wilderness Lobby Today’s “environmentalists” are not counter culture heroes fighting the establishment from the back of a rainbow hued microbus. They are sophisticated, well-­‐funded organizations who pay their talent as much or more as their counterparts in corporate America, with the blessing of “our” government. The Wilderness Society is a tax-­‐exempt nonprofit leader in the Wilderness advocacy movement. Its 2011 IRS filings list annual revenue of about 25 million, with listed employees’ annual compensation ranging from $200,000 to $421,664! http://wilderness.org/sites/default/files/TWS%202011%20Form%20990.pdf. This doesn’t include their lawyers, who work for separate nonprofit organizations, such as Earthjustice, which the IRS considers “public interest” law firms, whose top employees in 2012 received from $156,000 to $395,114. http://earthjustice.org/sites/default/files/Earthjustice-­‐Form-­‐990-­‐FY13_0.pdf. Their mission is to create more Wilderness. They aren’t ever going to be “finished.” Please join us in maintaining diverse recreation and calling ENOUGH on Wilderness in Colorado. 3