Hells Canyon 1993 - 2003

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How NEPA Changed Minds and Management

The Imhana River

It took ten years, but on July 22, 2003, the managers of the Wallowa-Whitman National Forest (W-WNF) showed they hold a deeper appreciation and understanding of Hells Canyon than they did in September 1993.

You wouldn’t think it would take a decade to finally express protectiveness toward what may be the deepest river-cut canyon in North America (Kings Canyon in California may be just as deep). Or to commit to preservation of the spectacular native bunchgrass lands that survive on the canyon’s plunging walls, when nearly all native grasslands in the West have been destroyed. You wouldn’t think it would take a decade to acknowledge that vehicles and livestock running willy-nilly on slopes, in meadows, and across streams might not be compatible with the canyon’s salmon streams and rare plants. But it did, and the steps it took to bring about this change are worth repeating on public lands throughout the world.

Hells Canyon

A bit of background
Hells Canyon National Recreation Area (HCNRA) sprawls its 652,000 acres across three national forests in northeastern Oregon and western Idaho. Administered by the W-WNF in Oregon, the HCNRA surrounds and includes 67 miles of Wild and Scenic-status Snake River and the 214,000-acre Hells Canyon Wilderness. It starts low with desert-like conditions at the Snake River, climbs up through grassy slopes and forested crevices, levels out on benches and plateaus of forest and meadow, and finally rises into the rarified alpine ecosystems of Idaho’s Seven Devils Mountains. When, in September 1993, W-WNF Supervisor Bob Richmond grudgingly agreed to revise the original (1982) HCNRA Comprehensive Management Plan (CMP), he clearly intended to uphold "Good Old Boy Business As Usual:" Road and motorized developments, off-road travel, logging, and cattle and sheep grazing. But ten years later, W-WNF Supervisor Karyn Wood’s Record of Decision for the new CMP included eliminating one-third of the roads; closing three key canyon-edge and ridge-top roads throughout the fall hunting season, winter and spring; designating all other roads closed unless posted open; withdrawing the historic permission to drive stock trucks, RVs, pickups and ATVs 300 feet out from either side of every open road; and limiting the canyon’s 55 roaded subwatersheds to no more than 1.35 road miles per square mile of land (many have less). In addition, her decision abolished one-quarter million acres of livestock allotments, transforming them into protected native grasslands. (These livestock allotments did not have current permitees, but earlier plans had been to expand adjacent allotments to include parts of these so-called "vacant" allotments.)

Roadless country

What led to this Record of Decision?

1. Legislation that requires human activities to be compatible with the long-term health of HCNRA ecosystems.

The 1975 HCNRA Act states that human activities such as logging, grazing, mining, and recreation are allowed in Hells Canyon to the degree they are compatible with wildlife habitat, rare and endemic plants, free-flowing rivers, cultural artifacts, and outstanding ecosystems and parts of ecosystems. Anything less than this commitment allows degradation and destruction of public ecosystems.

2. The National Environmental Policy Act’s (NEPA’s) requirement that "a full range of reasonable alternatives" be "rigorously explore[d] and objectively evaluate[d]" in environmental impact statements (EISs) for any federal decisions that may significantly affect the environment.

There is no wiser law than one that requires consideration of a full range of alternatives. The NEPA regulations state that consideration of alternatives is "the heart of the environmental impact statement." After all, the only way we’ll stop destroying the earth is to consider (and implement) alternatives to the way we’re behaving, e.g., our proliferation of roads and off-road vehicles.

3. Drafting by citizens and scientists of a reasonable alternative.

In January 1994, ten people representing two tribes; eight national, regional, state, and local conservation organizations (including Wildlands CPR); a state hunting organization; and two individual experts, joined together as the Hells Canyon CMP Tracking Group. We notified the Wallowa-Whitman NF that we were going to write an ecosystem-based alternative to be considered in the upcoming Draft EIS for the HCNRA CMP. The Tracking Group met for a threeday marathon to begin drafting our alternative, and I agreed to facilitate pulling together the disparate pieces into one comprehensive alternative. We named our alternative what it is: the Native Ecosystem Alternative. (We figured that calling it a "Citizens’ Alternative" (1) would marginalize the alternative; and (2) didn’t describe the alternative.)

Canyon slopes

4. Backing the alternative with scientific evidence.

When we submitted the Native Ecosystem Alternative to the WWNF, we also submitted hard copies of 116 scientific documents that provided evidence we believed the W-WNF needed to use when analyzing all alternatives in the Draft EIS. In addition, we supplied a 60-page bibliography summarizing the main findings, relevance, and significance of each of the documents. We did this because NEPA requires agencies to insure the "scientific integrity" of their EIS discussions and analyses. NEPA regulation 1502.24 requires agencies to "identify any methodologies used and...make explicit reference by footnote to the scientific and other sources relied upon for conclusions in the [EIS]."

5. Having a responsive U.S. Forest Service and a responsive public.

In February 1996 the first Draft EIS (DEIS) was released, but with no Native Ecosystem Alternative. The W-WNF gave bogus reasons for not including it; but an appeal to the Regional Forester brought no help. Karyn Wood became W-WNF’s Supervisor in 1997, but she didn’t want to dump two years’ DEIS work. Six days before the Final EIS was to go to the printer, I met with a number of then-Chief Mike Dombeck’s Forest Service staff in Washington DC and a member of the Council on Environmental Quality, the executive branch office that oversees compliance with NEPA. That afternoon the Forest Service notified Karyn Wood that the DEIS should have included the Native Ecosystem Alternative because it was both reasonable and different from W-WNF alternatives. Supervisor Wood agreed to start all over with a new DEIS.

In December 1999, the second DEIS was released. It included our alternative and a new one by the Wallowa County Commissioners, but WWNF’s preferred alternative remained largely unprotective of Hells Canyon. Citizens sent in over 2,000 public comments, with most written comments expressing preference for the Native Ecosystem Alternative. The Nez Perce Tribe prepared and submitted a science-based paper on the importance of roadless ridges for elk, mule deer and bighorn sheep. The W-WNF undertook further analysis of Hells Canyon conditions in light of substantive comments.

Bighorn sheep

On July 22, 2003, Supervisor Wood and her interdisciplinary team released the Final EIS and her surprising Record of Decision. Roads and off-road travel and livestock were all finally recognized as entities to be circumscribed and limited, not simply defended, so that Hells Canyon could be afforded a fighting chance to survive motorized recreation, commodity extraction, and the invasive species they bring in their wake.

This account doesn’t begin to describe the countless Tracking Group drafts, meetings, and ongoing communication with the W-WNF that were required over the years, but anyone who has organized for change can imagine. Some might say that a ten-year process shows that NEPA "doesn’t work." I believe this account shows precisely the opposite: that NEPA does work. NEPA sets the stage through its alternatives assessment process for the possibility of long-term, fundamental changes. Such change doesn’t happen in a year, but it’s what brings real wins for the earth.

Closing roads

Some Positive Provisions of the New Hells Canyon CMP

• The HCNRA will be managed as a "healthy ecosystem that is an integral component of a larger biological region... an area of high biological diversity and endemism." Management will "...ensure that maintenance and/or restoration of ecological function and sustainability of species, habitats, and ecosystems ... contribute to its biological uniqueness."

• Over 245,000 acres of currently vacant livestock allotments will be closed to future livestock grazing and instead managed for biodiversity and native plant values, bringing the total livestock-free area within the HCNRA to around 365,000 acres.

• Road density will be reduced to 1.35 miles per square mile, resulting in the closure of approximately one third of existing HCNRA roads (about 200 miles). ATVs will be limited to "designated open roads and trails," with no cross-country use permitted.

• Forests will be allowed "to function in a nearly natural manner" through the use of natural fire, prescribed fire, and vegetation projects aimed at restoring "viable and healthy ecosystems." Wildfire will "resume a more natural role" and is recognized as an essential part of the health of Hells Canyon.

• The CMP emphasizes "maintenance of the rustic and primitive character of the HCNRA," and "favors primitive and semi-primitive experiences over roaded natural and rural experiences."

• Prevention is recognized as a critical part of invasive species (weed) management, including "closure or restrictions on use where appropriate."

Mary O’Brien (Ph.D., Botany), is a member of Wildlands CPR’s Board of Directors. She is currently working with a Utah coalition to write a Sustainable Multiple Use Alternative for the upcoming Fishlake, Dixie, and Manti-LaSal Forest Plans.

Article first published in The Road RIPorter, the quarterly newsletter of Wildlands CPR, volume 8 #4, winter solstice 2003 (link provided below)

FOOTNOTES 1. Public Law 94-199, December 31, 1975. 2. Section 7, HCNRA Act. 3. Section 1502.14 of NEPA Regulations, 40 Code of Federal Regulations Parts 1500-1508 (1992). If you’ve never read the crystal-clear, plain-language NEPA regulations, do so. And defend them, because they’re under attack by the Bush Administration.


N Chappaz (OEP auth. reprod.)  

Creation/last update: 18 January 2005

Recommended websites or webpages :

The Road-RIPorter - Click to read issues online

Wildlands Center for Preventing Roads - Click to visit website


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