u.s. department of agriculture forest service utah division of wildlife resources...

U.S. DEPARTMENT OF AGRICULTURE

FOREST SERVICE

UTAH DIVISION OF WILDLIFE RESOURCES (UDWR) PROPOSAL TO CAPTURE AND COLLAR MOUNTAIN

GOATS AND BIGHORN SHEEP

ENVIRONMENTAL ASSESSMENT

PUBLIC AND AGENCY SCOPING REPORT

USDA Forest Service

Supervisor’s Office

857 West South Jordan Parkway

South Jordan, Utah 84095

July 2017

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1.0 Introduction

1.1 Background Information In May of 2016, a 30-day scoping period took place for a proposal from the Utah Division of Wildlife Resources (UDWR) to the Uinta-Wasatch-Cache National Forest land helicopters in the Twin Peaks, Lone Peak, and Mount Timpanogos wilderness areas to capture and collar mountain goats. The scoping process is intended to gather comments on key issues that should be analyzed and any alternatives that should be considered.

In January of 2017, the UDWR met with Forest Service to discuss revising the project to add bighorn sheep to the proposal. The bighorn sheep population on the Wasatch Mountains has remained stagnant since the year 2000, and the mountain goat population in this area has significantly declined since 1999. The term "stagnant" as defined by UDWR describes a population that exhibits no clear growth trend and shows poor population performance relative to a population objective or what the surrounding habitat can sustain. UDWR has determined that in order to conserve and manage these protected species, the best course of action would be to take biological samples for disease testing from both species populations and to monitor their movements to better understand their interactions. It is believed that the information collected from these efforts would help UDWR understand what is causing species specific mortality and population decline.

1.2 Purpose of the Project The purpose of this project is determine if the Forest Service should authorize UDWR to land and to drop people and materials from helicopters in the Mount Timpanogos, Lone Peak and Twin Peaks Wilderness areas for the purpose of capturing, taking biological samples and GPS radio collaring mountain goats and Rocky Mountain bighorn sheep. This would allow UDWR to try to understand the decline in the mountain goat population and the lack of growth in Rocky Mountain bighorn sheep population. UDWR’s need is to understand the potential for disease spread between the two populations and to monitor and maintain meaningful data regarding current health status, survival, causes of mortality, year-round habitat use, migration/movements within and to and from the three wilderness areas. Based on the information gathered from this study, UDWR may be able to adjust management actions to conserve and protect these wildlife populations and maintain Wilderness Character.

1.3 Document Organization This document contains summary descriptions of the following:

• Description of public outreach and opportunities for comment • The scoping content analysis process, including how individual letters and comments were

reviewed and organized • Preliminary issues, concerns, and opportunities to be addressed in the analysis

As part of the NEPA process, all comments are given equal consideration, regardless of the method of their transmittal.

2.0 Description of Public Outreach and Opportunities for Comment Members of the public and representatives of agencies were afforded several methods for providing comments.

A public notice initiating a 30-day comment period was published in the Salt Lake Tribune, Deseret News, and Provo Daily Herald on May 25, 2016. A letter was also emailed to the project mailing list for

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the Salt Lake and Pleasant Grove Ranger Districts. During the May 2016, 30-day scoping period, email comments could be sent to the following dedicated email address: [email protected] and individual letters could be mailed to Salt Lake Ranger District, 6944 South 3000 East, Salt Lake City, UT 84121. The Forest Wildlife Program Manager was also listed with a telephone number.

A second public notice initiating a 30-day comment period was published in the Salt Lake Tribune, Deseret News, and Provo Daily Herald on February 9, 2017. A letter was also emailed to the project mailing list for the Salt Lake and Pleasant Grove Ranger Districts. During the February 2017 30-day scoping period, email comments could be sent to the following dedicated email address: [email protected] and individual letters could be mailed to Uinta-Wasatch-Cache National Forest, Supervisor’s Office, 857 W. South Jordan Parkway, South Jordan, UT 84095. The Forest Wildlife Program Manager was also listed with a telephone number.

3.0 Scoping Content Analysis During the May 2016 scoping comment period, the Uinta-Wasatch-Cache received 34 unique comments from individuals and organizations. These comments were compiled in a spreadsheet and were given a unique comment number from 001 to 034. Comments were assigned a category based on the content of the comment. Categories included; Alternatives, request for MRDG, Analysis and alternatives, Botany, General opposition, General opposition - wilderness character, General support, General support - request for info, Request for Info, Request for project detail, Timing of analysis, Wilderness Act, Wilderness character, Wildlife, and Wildlife - status of species.

During the February 2017 scoping comment period, approximately 2,395 comments were received including 1,710 form letters, 547 form letters with additional comments, and 138 unique comments. Each of these comments was reviewed by an interdisciplinary team of resource specialists and categorized based on the response. Categories included; Alternatives, Budget, Frequency of helicopter landings, General opposition, request for information, Hunting and viewing opportunities, Noise, Proposed Action and Purpose and Need, Safety, USFS Decision, Wilderness Act, Wilderness Act (Idaho Court Case), Wilderness character, Wildlife, Wildlife management for wilderness character.

Many of the responses included similar issues and were summarized accordingly. Table A-1 includes the table of summarized responses, the categories used to sort the comments, and how the comments have been, or will be addressed as we move forward.

4.0 Preliminary Issues, Concerns, and Opportunities Based on the summary responses provided in Table A-1, the Forest Service did not identify any key issues that would drive the development of an additional action alternative. Wilderness was identified as they only key issue that would be carried forward for detailed analysis. A summary of detailed analyses associated with the issue are presented in Chapter 3 of the environmental assessment. Indicators are listed for use in comparing how the different alternatives affect that issue. Numerous concerns were raised during internal and external scoping processes and while these concerns were valuable, they did not raise unresolved conflicts.

Wilderness and Other Undeveloped Lands The key issue carried forward for wilderness resources is whether or not the proposed federal action activities connected with the proposed federal action could result in a downward trend in wilderness

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character qualities of Untrammeled, Undeveloped, Natural, Outstanding Opportunities – (Solitude and Primitive and Unconfined Recreation), and Other Features of Value.

Specific indicators include:

Untrammeled - Would the intentional proposed management actions directly control or manipulate the components or processes of ecological systems inside wilderness?

Undeveloped - Would motor vehicles, motorized equipment or mechanical transport Activities Adversely Affect the undeveloped quality of wilderness?

Natural - Would activities adversely affect the natural environment of plants, animals, air, water and ecological process?

Outstanding Opportunities - o Solitude - Would seeing or hearing the signs of modern civilization activities adversely

Affect opportunities to experience solitude? o Primitive - Would activities adversely affect recreationist self-reliance and skills in

wilderness travel? o Unconfined Recreation – Would activities adversely affect recreationist sense of

discovery, and mental challenge where one can travel and explore unique and unknown environments?

Other Features of Value - Would activities adversely affect unique features, and or iconic plant or animal species?

5.0 Opportunities for Future Comment The Uinta-Wasatch-Cache National Forest has determined that an environmental assessment (EA) will be prepared for this project. The draft EA will be released for a 30-day public comment period.

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Table A-1 Summary of scoping comments received and responses

Scoping Period

Number First Name

Last Name Organization Comment Resource Category

Response

2016 001 Adam Bronson Utah Foundation for North American Wild Sheep

Due to the nature of mountain goats and the rugged country they inhabit, helicopter captures are about the only way to get goats in hand across a random geographic range and collect good biological data. While we realize that during the few days of the captures there may be some low level flying in wilderness areas, there is simply no better way to capture goats and to find out why their numbers have declined. Wildlife management is an active profession, not a passive sit back and do nothing one, especially since 2 million people now live within an hour of the Wasatch mountain range, the landscape these goats live in is simply a different place faces with ever changing challenges. We urge the USFS to support the Utah DWR in the sound wildlife management practices of capturing goats by helicopter capture, despite the isolated short lived disturbances it may cause to some people who believe wilderness should be left alone. Our group funds nearly

General support Thank you for your comment. You have been added to the mailing list for the project.

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all bighorn sheep and mountain goat capture project proposal requests that come before us and are committed to promoting and enhancing sheep and goat populations throughout Utah. We feel that efforts to block the Utah DWR's efforts to study goats or other wildlife species by using wilderness designations are contrary to our mission and the basic principles of sound wildlife management. Please keep me on your mailing or notification email list for this project.

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Response

2016 002 Bill King Utah Native Plant Society

UNPS has been tracking rare plant species in the Wasatch Mountains for many years and recently have published Calochortiana Number 3, February, 2016, which details our findings.We believe that the following high priority rare species could fall into the helicopter goat capture project area and could be negatively impacted: Crepis runcinata ssp. Runcinata (Meadow hawksbeard), Erigeron goodrichii (Goodrich's fleabane), Boechera harrsonii (Harrison's rockcress), Boechera lasiocarpa (Wasatch rockcress), Lepidium montanum var. alpinum (Wasatch pepperwort), Corydalis caseana var brachycarpa (Case's corydalis), Jamesia americana var. macrocalyx (Wasatch jamesia), Eriogonum brevicaule var. cottamii (Cottam's wild buckwheat), Dodecatheon dentatum var. utahense (Hooker's shooting star). Additionally, there are 79 rare species listed on the UNPS Watch List for Utah and Salt Lake Counties, of which close to half could be in the helicopter

Botany We appreciate the concern over narrow endemic plants and the potential of landing a helicopter in the general proximity of one or more of these plants. An environmental assessment has been prepared to address potential impacts. We have had our botanist review your concerns in regards to this project. They have analyzed the potential impacts to vegetation and these have been address in the environmental assessment which includes mitigation measures.

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project area. It has long been a standing Forest Service Policy to not make any decision which could cause species to become threatened or endangered under the National Environmental Protection Act. Any of these species mentioned above could become threatened or endangered by the landing of helicopters onto this very fragile environment. The three Wasatch Wilderness areas that would be affected by the helicopter project contain many rare and fragile plants and habitats. Before any action is taken to decide on the helicopter project, we think that a full Environmental Impact Statement under NEPA should be carried out.

2016 003 Steve Sorensen When I heard that the mountain goat population was declining in this unit and the DWR was going to conduct a study I was excited. I've taken multiple scout groups into Utah's wilderness and the high light of every trip was seeing goats hanging on to the cliff faces. I

General support Thank you for your comment.

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hope the FS will allow this study to take place to insure that this awesome animal is around for years to come for all to enjoy. Thanks Steve Sorensen P.S. Please respond to this email so I know my voice and opinion is being heard.

2016 004 Clay Northrup I'd like to record my opposition to the proposal from the Utah DWR to land helicopters in Wilderness areas for the purpose of studying mountain goat populations. The goats are not a native species, and the DWR's ultimate purpose is to increase the number of goats available to be shot by hunters. This is not a sufficient reason to violate the Wilderness Act, which the Forest Service is legally obligated to uphold.

General opposition Thank you for your comment. All alternatives being analyzed will meet the Forest Service legal requirements. The analysis provides a review of what is known of the mountain goat population on the Wasatch Front. The native status of mountain goats in Utah has been a subject of controversy. UDWR’s position is that mountain goat habitat exists in Utah and they require proactive management. Mountain goats have been listed as a protected wildlife

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species in Utah since 1919, shortly after they were first observed in the Wasatch National Forest during a 1918 wildlife census conducted by the Forest Service. Additional information can be found in the environmental assessment as well as the wildlife specialist report included in the project record. Hunting issues are outside the scope of this analysis.

2016 005 Clay Northrup I'm writing to register my opposition to the Utah DWR request to land helicopters in Wilderness areas along the Wasatch Front. Suspending provisions of the Wilderness Act for the purpose of increasing the quantity of non-native mountain goats that are available to be shot by Utah hunters would violate the Forest Service's legal obligations - regardless of whether or not there are other

General opposition See response to 004.

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means of studying the mountain goat population.

2016 006 Clay Northrup Duplicate of 005 See response to 004. 2016 007 Gary Nichols Just want to let you know I'm

opposed to using helicopters in designated wilderness areas for collaring mountain goats. I think this is very inappropriate. The goats don't belong there in the first place.

Wildlife - status of species

Thank you for your comment.

2016 008 Paul Diegel I am writing to express my strong opposition to the proposal to grant special permission to use helicopters in the Wasatch Wilderness Areas for purposes of studying Mountain Goats. The State and the Forest Service have not provided compelling reasons for a) studying goat behavior or b) the need to maintain an invasive species in the Wasatch. The Wilderness Act of 1964 is intended to maintain the integrity of wild places and the Forest Service is obliged to act in good faith to uphold that principle. If you allow one special interest group to violate the Wilderness rules, you open the door to other

Wilderness Act Both bighorn sheep and mountain goat are be studied as part of the proposed action. See the purpose and need for the project and response to 004.

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special interests to request special permission to violate Wilderness rules to further their unique interest. Flying in the Wilderness in this case serves no compelling public interest and to allow it would be an irresponsible use of Forest Service authority.

2016 009 David Smith Mountain Goats are not native to the Wasatch Mountains! Almost without exception, whenever man has introduced exotic species into an ecosystem, the results have been problematic--think lake trout in the Yellowstone drainage, tamarisk is the Colorado drainage, etc. Mountain Goats is the Wasatch may be another example of a failed introduction of an exotic species in to our local ecosystem. The possible failure of this poorly thought-out introduction is not a reason to violate the Wilderness Act and allow illegal helicopter landings within designated Wilderness Areas. Such landings (if allowed) will adversely impact the wilderness experience of wilderness users. The potential benefit to an invasive species is

Wilderness Act See response to 004 and 008.

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not worth the certain negative impact of violating the law. Stand up for the integrity of our wilderness areas--do not allow illegal landings for the possible benefit of a species that shouldn't be in those areas to begin with!

2016 010 Jason Lundahl I would fully support the UDWR in these studies and I would hope they would be granted permission to perform necessary capture & testing to help fix any issues that are occurring. I have been into wilderness areas a lot and there is nothing better than to see these unique animals and the places that they are able to survive. It would be tragic to let the mountain goat population continue to decline when there could possibly be an easy fix. I have been involved in many projects with the UDWR and always support these types of projects. Please don't let something bad happen to these animals because of a rule that I don't think was designed for this purpose.

General support - request for info


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Please confirm receipt of this email.

2016 011 Kristen Shelley I would like to object to the proposal for helicopters going into the 3 Wilderness areas to tag mountain goats. I know the goat population has diminished but there is no reason for the government to have an exception to the law against motorized vehicles. Just hike or horseback ride in like everyone else has to do. If someone is hurt up there, a helicopter is not allowed in, correct? Nothing supersedes human life, so this study certainly should not. Do NOT allow the helicopters into those 3 areas. The negative impact far outweighs the positive results.

Wilderness Act Helicopters have been used to assist in human rescue efforts in the wilderness. Thank you for your comment.

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2016 012 Kristen Shelley The Mountain Goat study into Wilderness areas via helicopter is a ridiculous idea. We agree that the goats are disappearing, but they have most likely moved South into the Nebo areas. What will you do once you find out that they are gone, just as you thought? The Wilderness designation is not just there to be turned over when a government employee is too lazy to hike or ride a horse up to where you need to be to study the goats. Just get up there like the rest of us do. Hike or ride a horse. Bringing helicopters into this area is against the law. If I rode my motorcycle 10 yards into the Wilderness Area, I would get a ticket and a fine without question. Why is it ok for a government agency to just decide that they want to bypass the law for their convenience? Do NOT let the helicopters into the 2 designated wilderness areas. Access those areas like the rest of us. There is no good reason and only negative consequences to wildlife and plant life.

Wilderness Act Please see the purpose and need for the project for a description of the issues being addressed. See response to comment 004. A ground only alternative is discussed in the "Alternatives Considered but Eliminated" section of the EA.

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2016 013 Bob Brister I am writing to comment on the proposal to land helicopters in the Twin Peaks, Lone Peak, and Mount Timpanogos wilderness areas to capture and collar mountain goats. Isn't the use of mechanical objects in designated wilderness against the law?

Wilderness Act The use of mechanized equipment in a designated Forest Service managed wilderness area can occur but should be analyzed and approved by the Forest Service.

2016 014 Richard Steiner Do not allow helicopters in the wilderness. This is against regulations and opens a slippery slope for other special use permits. Fast personnel cannot use chain saws so UDW cannot use helicopters. This is almost a no brainier in terms of a decision.

Wilderness Act See response to comments 004 and 013.

2016 015 Jay Griffith It has come to my attention that the Utah DWR is requesting permission to fly and land helicopters into wilderness area to study mountain goat populations. That is unlawful and inappropriate for wilderness area. We go to these quiet and beautiful places because they are quiet and beautiful. Please find a different method (like horseback if necessary) to reach the locals.


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2016 016 Richard Middleton I believe that you should deny UDWR's application to land helicopters in the Twin Peaks, Lone Peak and Timpanogos Wilderness areas to study mountain goats. First, it is debatable whether mountain goats belong in these areas at all, since they were introduced by UDWR. Second, if there has been a decline in the herd from previous peak levels, this may be natural fluctuation (or a natural corrective response to being introduced to the wrong place). Third, there are plenty of stressors in this environment which could account for the drop in numbers, for example: much greater human intrusion into the back country (both on foot and using snowmobiles and ATVs, and heli-skiing), changes in vegetation patterns due to resort and other developments, and of course hunting, which selectively culls the prime trophy animals who are most knowledgeable about food supplies and safe paths in the mountains. None of these factors will be adequately evaluated using the UDWR's approach, to take


Thank you for your comment. The evaluation of other potentially detrimental impacts to mountain goat populations is outside of the scope of this analysis. A ground only alternative is discussed in the "Alternatives Considered but Eliminated" section of the EA. See response to comments 004 and 013.

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samples from a few animals. I believe that, if it is decided that mountain goats do indeed have a place in the Wasatch, then UDWR should be asked to design a less intrusive holistic study that could identify and quantify the factors at play, and devise suitable mitigation. Allowing helicopters into the wilderness does not seem an appropriate technique, and sets an appalling precedent for future intrusions.

2016 017 Michael Kelsey Regarding landing choppers inside the 3 wilderness areas to take a survey of Mtn. Goats, I have no objections. Only the most radical of environmentalists might believe otherwise. Good luck in your survey. Also, I would like to know the results of your study-I may be doing an updated edition of my Timp Guide in the next 3-4 years.

General support Thank you for your comment. Please contact UDWR to request the results of their work.

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2016 018 Nate Jones I have to say that I love Mountain Goats and love seeing them in the wilderness when I go hiking. I think it is great they are being studied, but helicopters should not be used. Wilderness is a place where humans and animals alike can find solitude and quiet solace. Allowing helicopters to land in the wilderness ruins the purpose of the wilderness designation. I worry it will lead to helicopters being used for additional activities and studies or other mechanical vehicles being used (e.g. for trail work etc.). Let's keep the wilderness protected and find another means of studying the Mountain Goats.

General opposition Thank you for your comment.

2016 019 Eric Sadler Wasatch Mountain Club

Will McCarvill was kind enough to forward this to me. I am the Conservation Director for the Wasatch Mountain Club. Please add me to the distribution list for this correspondence.

Request for Info You have been added to the mailing list for this project.

2016 020 Kathleen Rice I have learned that the Utah Division of Wildlife Resources is proposing to conduct a survey using motorized vehicles - helicopters - to see why populations of mountain goats are diminishing. The wild animals do not understand such

Wildlife Thank you for your comment.

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invasions to their habitat and to their daily living patterns, and, despite the remarks (today's Salt Lake Tribune) by Mr. Robinson, it could be extremely frightening and invasive. In fact, the count, by air, could have contributed to the diminished numbers with the disruption of the homes and activities of the animals.

2016 021 Tyson Bradley I have been seeing goats each of the 4 times I've guided on Mt. Olympus this month. I think they have moved off of Mt. Superior (where I counted 60 one day in the late '90s) and are thriving in the Olympus Wilderness. I don't know why. I know they are non-indigenous to the Wasatch, but I also have been sad to notice their decline. Good Luck with your research, and let us know if we can help. Our guides will be aware that helicopters may be in the wilderness for this reason this summer. [PHOTOS INCLUDED IN EMAIL]


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2016 022 Troy Justensen Sportsmen for Fish and Wildlife

I am writing this letter on behalf of 7,200 members of our organization in favor of the proposed use of a helicopter by the Utah Division of Wildlife Resource (UDWR) in the wilderness areas of Twin Peaks, Lone Peak and Mount Timpanogas for the purpose of collaring and collecting blood for a disease profile on Mountain Goats. According to the UDWR latest flight surveys, Mountain Goat populations continue to decrease in these areas. The information that would be obtained from the proposed collaring/blood work is absolutely critical in determining what the cause of the population decrease is. The impact to wilderness will be minimal at best; other than the noise of the aircraft during the captures, there will be no permanent disturbance to habitat or terrain. Having a healthy and robust population of Mountain Goats in these areas is beneficial to both consumptive and non-consumptive parties alike. There are very few animals as majestic as the Mountain Goat that can


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be so easily viewed by the general public. Multiple Conservation Groups in the state of Utah have spent thousands of dollars to insure the well being of this species. It would be criminal not to use every possible resource available to ensure these animals are here and abundant for future generations to enjoy.

2016 023.1 Kirk Robinson (multiple)

Western Wildlife Conservancy

This letter is to inform you that the not-for-profit conservation organizations listed at the end of this letter are opposed to the Utah Division of Wildlife Resources' proposal that the Forest Service allow the agency (UDWR) to employ helicopter landings in Wasatch Mountain wilderness areas in order to capture and collar Rocky Mountain goats. We will remain opposed to this project until our questions and concerns, listed below, are satisfactorily addressed. As the agency charged with managing the

General opposition, wilderness character

The Wilderness values, with regards to the various alternatives, were evaluated in the Minimum Requirements Analysis (MRA) and are reflected in the NEPA analysis.

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Wasatch wilderness areas, the Forest Service has an enforceable statutory duty to preserve the areas' wilderness character including natural and experiential values (16 U.S.C. § 1133(b)). Where a choice must be made between wilderness values and visitor or any other activity, preserving the wilderness resource [character] is the overriding value. Economy, convenience, commercial value, and comfort are not standards of management or use of wilderness (FSH 2320.6). The following questions and comments are meant to assist the FS in this matter.



1) The pending case from Idaho, Wilderness Watch y. Vilsack. addresses nearly the same issue as raised by UDWR's proposal to use helicopter landings to collar mountain goats in Wasatch Mountain wildernesses, albeit in that case the species to be studied is the Rocky Mountain elk (Cervus elaphus) which is indisputably a species native to the Frank Church-River of No Return Wilderness, while the Rocky Mountain goat

Timing of analysis A decision has been issued on the case. Thank you for your comment. See response to comment 004.

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(Oreamnos americanus) is not, by any reasonable standard, native to the Wasatch Mountains. Since Wilderness Watch v. Vilsack has not yet been decided, we believe it would be prudent to wait and see what the decision in that case is before considering UDWR's proposal.



2) The Wilderness Act expressly prohibits any "landing of aircraft" and any "installation" within designated wilderness "except as necessary to meet minimum requirements for the administration of the area" as wilderness. 16 U.S.C. § 1133(c). Radio telemetry collars on wildlife constitute "installations" that are generally prohibited by the Wilderness Act. Thus, in order to avoid violating the Wilderness Act, the FS must determine that the proposed project is necessary to meet minimum requirements for the administration of each of the three affected wilderness areas as wilderness. How will collaring and monitoring the activities of the mountain goats assist the FS in meeting the minimum requirements for

Wilderness Act The Wilderness values, with regards to the various alternatives, were evaluated in the Minimum Requirements Analysis (MRA) and are reflected in the NEPA analysis. See the purpose and need description in the EA.

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administering the Twin Peaks, Lone Peak, and the Mount Timpanogos wildernesses so as to preserve or enhance their wilderness character?



3) Why is this specific project, which will involve helicopter landings in wilderness and collaring of mountain goats, necessary for obtaining the desired information about the mountain goats? Are there alternative ways in which UDWR can acquire the information it seeks that isn't a prima facie violation of the Wilderness Act triggering the "minimum requirements" exception? To meet minimum needs for protection and administration of the area as wilderness, the use of motorized equipment or mechanical transport may be allowed only if: 1) a delivery or application problem necessary to meet wilderness objectives cannot be resolved within reason through the use of nonmotorized

Alternatives, request for MRDG

A Minimum Requirements Analysis (MRA) has been developed for this project. A ground only alternative is discussed in the "Alternatives Considered but Eliminated" section of the EA. An evaluation of hunting is outside the scope of this analysis.

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methods, or 2) an essential activity is impossible to accomplish by nonmotorized means because of such factors as time or season limitations, safety, or other material restrictions (FSH 2326.1; emphasis added). While wildlife and fish research is an appropriate activity in wilderness, in all cases research shall be conducted in such a way as to minimize any adverse impacts on the wilderness resource or its users (FSH 2323.37; See FSH 2309.19 for specific direction and guidelines for approving these activities). Did the Forest Service conduct a documented minimum requirement analysis? Have any alternatives been identified, discussed or investigated? For example, temporarily suspending hunting is a viable alternative for increasing the goat population. Overhunting is implicated in the decline of mountain goats in their native range in the Cascade Mountains of Washington. If so, what are they and why have they been rejected? Please provide us with

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a copy of the MRA or MRDG document.

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4) UDWR states in its management plan for Rocky Mountain goats, "This will allow the Division to expand both hunting and viewing opportunities for mountain goats while ensuring their long-term viability in Utah." How will management of mountain goats for the purposes of hunting and viewing help the Forest Service administer the Twin Peaks Lone Peak and Mount Timpanogos wildernesses so as to preserve or enhance their wilderness character? The Forest Service's statutory duty to protect wilderness character applies regardless of the states' traditional role in managing wildlife on federal public lands within their borders (See ER 63-64 (Fed. Br.). It is well established that "the 'complete power' that Congress has over public lands necessarily includes the power to regulate and protect the wildlife living there," (Kleppe v. New Mexico, 426 U.S. 529, 540-41(1976)), and state wildlife management that conflicts with federal objectives for federal public lands is preempted, (see Nat'l Audubon

Wilderness character

See the purpose and need and response to comment 004.

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Soc'y,Inc. v. Davis, 307 F.3d 835,854 (9th Cir. 2002) (affirming that "Congress has the authority under the Property Clause to preempt state action" affecting management of federal public lands); (see also 43 U.S.C. § 1732(b) (authorizing Secretary of Agriculture to prohibit hunting and fishing in designated areas of national forest lands when necessary to effectively administer such lands or comply "with provisions of applicable law").



5) What type of collars will be used - radio collars or satellite collars? 6) Will UDWR request future helicopter landings to replace collars? In other words, is this likely part of an ongoing project? 7) Will there be ongoing flyovers to gather information from the collars once the goats have been collared?

Request for project detail

The collars being used are satellite collars that are tracked with satellite signals tranferred through the internet. This may reduce the number of overflights required to manage these populations. Hike in crews would be used to retrieve these collars is an animal dies or when the collar drops off.

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8) The reintroduction of wildlife species is permitted only if the species was once indigenous to an area and was extirpated by human-induced events. Reintroductions shall be made in a manner compatible with the wilderness environment. Motorized or mechanical transport may be permitted if it is impossible to do the approved reintroduction by nonmotorized methods (FSH 2323.6) What positive evidence is there that Oreamnos americanus was indigenous to the Wasatch Mountains within, say, the last 10,000 years? (By 'positive evidence' we mean fossils, any sort of physical remains, DNA, verified sightings by trained zoologists, including locations or photographs (not just reports of estimates or statements of their presence.)


See the discussion in existing condition for wildlife and response to comment 004.



9) The Forest Service must also complete an appropriate National Environmental Policy Act ("NEPA") analysis for the project addressing the above concerns, fully analyzing direct, indirect and cumulative impacts as well as a reasonable range of alternatives that may avoid or

Analysis and alternatives

An environmental assessment has been prepared to address potential impacts and will be made available for public review and comment. A range of alternatives was

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lessen adverse impacts. The Environmental Impact Statement is NEPA's core requirement. Does the Forest Service intend to do an EIS on this project with further public input? If not, will there be an opportunity to comment on the EA? Will the Forest Service consider options such as no hunting of the goats, taking samples of dead goats (hunted and natural mortality) to determine general health, and using field workers, including volunteers, to monitor goat populations on foot to comply with the Wilderness Act?

analyzed in the EA including "Alternatives Considered but Eliminated from Detailed Analysis." Regulating harvest is outside the authority of the Forest Service.

2016 024 Andy White I have, for years enjoyed the sightings and occasional companionship of our local mountain goats on my forays into the wasatch and though the health of that environment due to their presence has, for some time, been a top of discussion I am a supporter of their health. I am not, however, a supporter of wilderness guideline exceptions for an introduced species. Aerial monitoring from prescribed vantage are fine, but "boots on the ground" should remain the standard in this case. What's the

General opposition A ground only alternative is discussed in the "Alternatives Considered but Eliminated" section of the EA.

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cost for the operation with a chopper compared to a number of young bucks anxious to do field research. I've got "boots" if you need my help.

2016 025 Steve Sorensen When I heard that the mountain goat population was declining in this unit and the DWR was going to conduct a study I was excited. I've taken multiple scout groups into Utah's wilderness and the high light of every trip was seeing goats hanging on to the cliff faces. I hope the FS will allow this study to take place to insure that this awesome animal is around for years to come for all to enjoy. Thanks Steve Sorensen P.S. Please respond to this email so I know my voice and opinion is being heard.

General support - request for info


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2016 026 Erme Catino I'm opposed to the following proposal given the following. As defined by the Wilderness Act of 1964, wilderness areas do not allow motorized equipment and provide opportunities for solitude. The Utah Division of Wildlife Resources (UDWR) has released a proposal to land helicopters in the Twin Peaks, Lone Peak, and Timpanogos Wilderness areas for the purpose of studying what they say is a significant decline in mountain goat populations since 1999. The proposal obviously does not comply with the rules of a wilderness area and has raised some questions about the importance, the purpose, and the methods the UDWR claims are best for capturing and studying mountain goats. Furthermore, the USFS specifically in the Wasatch National Forest has failed to regulate motorized access via private land and onto vast tracks of public land by way of snowmobiles and poachers in Cardiff Fork.

Wilderness Act Thank you for your comment. All alternatives being analyzed will meet the Forest Service legal requirements. The analysis provides a review of what is know of the mountain goat population on the Wasatch Front. Hunting issues are outside the scope of this project.

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2016 027 Carlton DeTar and Laurel Casjens

We are writing to urge you to deny the request by Utah Division of Wildlife Resources to land helicopters in designated wilderness areas to capture and collar mountain goats. A wilderness designation forbids introducing motorized equipment as a matter of convenience. As an alternative we would suggest the UDWR organize a citizen-science project or recruit a biology student to conduct censuses and observe goat movements on foot. We are not enthusiastic about the introduction of mountain goats in an area where they have not been native, at least for millenia, so we do not feel a strong sense of urgency in trying to preserve the population.

Wilderness Act See responses to comments 004 and comment 013.

2016 028 Brad Clinch I write in support of the letter from Save Our Canyons and other organizations that opposes the helicopter landing proposal in the three wilderness areas of the Wasatch mountains until further questions can be answered. As a wildlife photographer I have noticed the significant decline in the mountain goat population in the

Wilderness Act Thank you for your comment.

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Wasatch. The situation does need investigation, though it seems there are other ways to do so that respect the Wilderness Act regulations.

2016 029 Hunter I would disagree with flying and landing helicopters in the Wilderness. Im all about doing studies and research but the helicopter is unnecessary. SO i say no go.

General opposition Thank you for your comment.

2016 030 Creighton Hart No comments included or attached to email.

2016 031 Suzie Ellison UDRW should adhere to the rules of wilderness areas! Send researchers in on foot. Please Do not disturb our precious few areas in the wasatch wilderness with helicopters.


2016 032 Mark Lusch If someone wants to study mountain goats, fine. Let them walk up the mountain or ride a horse and they can study all they want. No helicopters. That's cheating. It's a wilderness.


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2016 033 Earle Bevins The request by the UDWR to helicopter into the Widerness areas of the Wasatch range should be denied. The Wilderness Act of 1964 clearly prohibits motorized equipment in areas designated as Wilderness. For the UDWR to request a waiver to study what is happening to what may be a non native mammal the introduction of which has harmed rare and sensitive vegetation is simply wrong. UDWR should have developed a plan to monitor the goats consistent with the limitation of the Wilderness Act when they were first introduced. Denial of this request is further enhanced by the “trophy” status of the goats by an affluent yet insignificant portion of the population. To waive the protections afforded by the Wilderness Act to meet the desire of these hunters to clear an item on their life list of trophy animals killed is unwarranted. These folks have the economic means to harvest these goats in areas not designated Wilderness.

Wilderness Act Thank you for your comment. See response to comment 013. All alternatives being analyzed will meet the Forest Service legal requirements. The analysis provides a review of what is know of the mountain goat population on the Wasatch Front. Hunting issues are outside the scope of this analysis.

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It is unfortunate that the UDWR has wasted the public's time and money to even consider a request that in clearly not permitted by the Wilderness Act of 1964 nor in the general public’s interest.

2016 034 Steven Pritchett There is no reason to allow an exception to the wilderness rules, when the task could be completed while complying to those rules. The study proposed by the UDWR could be accomplished without the use of helicopters. Hikers frequently travel on foot to those locations. If UDWR personnel cannot perform the study within the wilderness rules, then they need to enlist personnel that are capable of working within the wilderness rules.

Wilderness Act See response to comment 013.

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It also raises a typical scientific dilemma in trying to perform a measurement or study without the intrusion of the measurement actually altering the measured result. It would seem that inserting a helicopter into the wilderness may be short duration but a huge alteration to the relatively quite wilderness environment. If this request is granted approval, it sets a precedent for future exceptions. Some of which may also be desired but not required as in this current case.

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2017 035 Kirk Robinson (multiple)

Western Wildlife Conservancy (Wildlands Network, Wild Utah Project, Save our Canyons, Sierra Club, Yellowstone to Uintas connection, Voices of Wildlife, Wilderness Watch)

The proposed action is for the Utah Division of Wildlife Resources (UDWR) to make up to 60 helicopter landings in three Wasatch Mountain wilderness areas in the fall of 2017 in order to capture and collar approximately 20 Rocky Mountain goats (Oreamnos americanus) and approximately 10 Rocky Mountain bighorn sheep (Ovis Canadensis), and to take tissue samples from them. The wilderness areas where helicopter landings would take place are the Twin Peaks Wilderness, Lone Peak Wilderness, and Mount Timpanogos Wilderness - roughly the high mountainous area stretching between Provo Canyon on the south and Big Cottonwood Canyon on the north. The stated "purpose and need" of the project is for UDWR to be able to monitor the movements of the sheep and goats from data transmitted by the collars, as well as learn what diseases they may have from the tissue samples. UDWR personnel believe that the information the project will allow them to


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acquire will better enable them to manage both species in the wildernesses and surrounding habitats of the Wasatch Mountains.


Western Wildlife Conservancy (Multiple)

The Wilderness Act of 1964, as amended, is the governing document pertaining to wilderness management. It expressly prohibits aircraft landings and installations inside wilderness areas "except as necessary to meet minimum requirements for the administration of the area." See 16 U.S.C. § 1133(c). The proposed helicopter landings would violate this prohibition unless they fall under the exception. Collars installed on goats and sheep in the

Wilderness Act See response to comment 013.

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wilderness would also violate the prohibition because they are considered installations.



The U.S. Forest Service is the managing agency in this case. Thus, the Forest Service (FS) must determine whether the proposed action is "necessary to meet minimum requirements" for the administration of the three wilderness areas for wilderness character, i.e., in order to preserve or enhance their wilderness character. The comments below from eight concerned conservation organizations are intended to help the Forest Service answer this question.

USFS Decision Thank you for you comment. A Minimum Requirements Analysis (MRA) has been developed for this project.

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The following passage is from Wolf Recovery Foundation v. United States Forest Service, (692 F.Supp.2d 1264 (2010) is helpful for evaluating the UDWR proposal. 'The plaintiffs allege that this special use permit violates the Wilderness Act because it is not "necessary to meet minimum requirements for the administration of the area." See 16 U.S.C. § 1133(c). Courts have construed this phrase "narrowly." See High Sierra Hikers Ass'n v. U.S. Forest Service, 436 F.Supp.2d 1117 (E.D.Cal. 2006). Under this language, the court in High Sierra banned the construction of small dams that would restore fishing in a wilderness area. Id. The court reasoned that recreational fishing was "not an integral part of the wilderness nature of the area" and thus the building of small dams to enhance fishing was not "necessary" for administration of the area, i.e., necessary for maintaining the area as a wilderness. Id. at 1137. Similarly, the "acquisition and use of a large passenger van for transporting tourists cannot

Wilderness Act (Idaho Court Case)

Thank you for you comment.

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reasonably be squeezed 1268*1268 into the phrase `necessary to meet minimum requirements of administration.'" See Wilderness Watch v. Mainella, 375 F.3d 1085, 1093 (11th Cir.2004). To constitute "administration of the area," the activity must further the wilderness character of the area: "A wilderness, in contrast with those areas where man and his own works dominate the landscape, is hereby recognized as an area where the earth and its community of life are untrammeled by man." See 16 U.S.C. § 1131(c).'



In Wolf Recovery Foundation v. U.S. Forest Service, from which the above passage is excerpted, the presiding federal judge ruled in favor of the FS for permitting Idaho Fish and Game to land helicopters in a wilderness area in order to collar wolves. While acknowledging that proposed helicopter flights into on the Frank Church River of No Return Wilderness of central Idaho were inconsistent with wilderness values, the judge nevertheless ruled that their purpose, which was to capture



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and collar gray wolves (Canis lupus) in order to better understand the animal in that habitat, furthered wilderness values: "Ultimately, the Court was persuaded that the unique value of that particular study, coupled with the relatively small number of landings and short duration of the project, outweighed concerns over the disruption to wilderness values." (692 F.Supp.2d 1264)



So, the question in this case is whether the value of the research that UDWR proposes to undertake in the three Wasatch Mountain wilderness areas is of sufficiently unique value for enabling the FS to better manage those wilderness areas for wilderness character, that, coupled with the relatively small number of proposed landings and short duration of the project, the project is legally permissible.



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In this connection, we must be careful to distinguish the wolf collaring project from other types of intrusion into wilderness that have been ruled incompatible with wilderness values: In 'High Sierra Hikers Ass'n v. U.S. Forest Service, (cited in the excerpt from Wolf Recovery Foundation v. U.S. Forest Service), the court banned the construction and maintenance of small dams that would restore fishing in a wilderness area, reasoning that recreational fishing was '"not an integral part of the wilderness nature of the area" and thus the building of small dams to enhance fishing was not "necessary" for administration of the area, i.e., necessary for maintaining the area as a wilderness.'





We have concerns regarding the proposition that the proposed project would be of unique value for enabling the FS to better manage the wilderness areas in question for their wilderness character. We do not see how this might be so. We do not see how the proposal is more like wolf collaring than like dam


Thank you for your comment. Please see the purpose and need for the project for a description of the issues being addressed. An environmental assessment has been prepared to address

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building for the purpose of enhancing recreational fishing. Indeed, it seems to us that the opposite is true. Therefore, we believe the challenge for the FS, before permitting the proposed project, is to make a sufficiently strong case that the reverse of what we believe is actually true.

potential impacts and will be made available for public review and comment. A range of alternatives was analyzed in the EA including "Alternatives Considered but Eliminated from Detailed Analysis."



In this connection, we note that the missions of the two agencies (FS and UDWR respectively) are quite different. The mission of UDWR is to manage the two species of ungulates that it wishes to study (Rocky Mountain goats and sheep), while the mission of the FS is to manage the wilderness areas where these species reside to preserve or enhance their wilderness character. Thus, the FS must articulate a plausible explanation for how data or information that can be expected to be obtained from the project, concerning animal movements and diseases, will enable it to better manage the three wilderness areas to preserve or


Thank you for your comment. An environmental assessment has been prepared to address potential impacts and will be made available for public review and comment. A range of alternatives was analyzed in the EA including "Alternatives Considered but Eliminated from Detailed Analysis." The analysis provides a review of what is know of the mountain goat and bighorn sheep

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enhance their wilderness character.

population on the Wasatch Front.



It is an important fact that in Wolf Recovery Foundation v. United States Forest Service, the proposal was to land helicopters in a wilderness in order to collar wolves. The gray wolf was native to that ecosystem, though it had been missing for many decades, and its return via reintroduction plus the subsequent rapid growth of the wolf population, represented the return of an important apex predator to a system of which it was historically an integral part. It had a role in the ecology of the system. One can understand how being able to track the movements of collared wolves would not only assist Idaho Fish and Game with its management goals, but might also enable the FS to better manage the area for its wilderness character. For example, knowing where wolves

Wildlife management for wilderness character

Thank you for your comment. The analysis provides a review of what is know of the mountain goat and bighorn sheep population on the Wasatch Front. The EA addresses the effects to wilderness. See response to comment 004.

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denned could help the FS discourage backcountry use near den sites, so as to minimize conflict between humans and wolves, thereby to allow wolf families to rear pups successfully. The opportunity for wilderness visitors to observe wolves in the wild and to hear them howl might also be considered an important aspect of wilderness character. The documented movements of wolves in the wilderness might also enable the FS to better monitor their effects on the wilderness ecosystem. Is there anything comparable to this in the present case?

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The management goal of UDWR with respect to both Rocky Mountain Bighorn Sheep and Rocky Mountain goats is to provide (1) hunting opportunities for hunters and (2) wildlife viewing opportunities for people who visit the wilderness areas and who enjoy observing these animals in the wild. This is explicitly stated in the management plans for both species. For example, UDWR's statewide management plan for Rocky Mountain bighorn sheep states: Objective 1: Increase bighorn sheep populations within the state as conditions allow and bring all populations to at least the minimum viable level of 125 bighorns. Objective: Maintain or improve sufficient bighorn sheep habitat to allow herds to reach population objectives. Objective 2: Increase public awareness and expand viewing opportunities of bighorn sheep. Similarly, the UDWR statewide management plan for Rocky Mountain goats states: Mountain goats are managed as a once-in-a-lifetime species in

Hunting and viewing opportunities

Thank you for your comment. All alternatives being analyzed will meet the Forest Service legal requirements. The analysis provides a review of what is know of the mountain goat and bighorn sheep population on the Wasatch Front. An evaluation of hunting is outside the scope of this analysis.

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Utah. In addition to hunting, viewing mountain goats is one of the most exhilarating and memorable experiences available to users of high alpine areas in Utah. The Division plans to continue this management approach, while also establishing new mountain goat populations where possible. This will allow the Division to expand both hunting and viewing opportunities for mountain goats while ensuring their long-term viability in Utah. In short, the two management objectives for both species are to provide as many animals as possible for hunting and viewing. Undoubtedly, UDWR's interest in being permitted to land helicopters in Wasatch Mountain helicopters is meant to help them achieve these objectives.

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This introduces the question of how working to achieve these objectives is necessary to help the FS manage the wildernesses for wilderness character. So far as we can see, hunting goats and sheep has nothing at all to do with managing wilderness areas for wilderness character - especially so long as there are predators to eliminate the weaker and non-reproductive members of herds, which itself is a natural part of what goes on in wilderness and which therefore might even be considered essential to wilderness character. In this case, there are resident mountain lions and golden eagles, both of which prey on young sheep and goats. Enhancing wildlife hunting opportunities is not demonstrably necessary for filling the role of the natural predators, and would seem to be much more like recreational fishing so far as wilderness management goes: it is not an integral part of the wilderness nature of the three wilderness areas.


Thank you for your comment. All alternatives being analyzed will meet the Forest Service legal requirements. The analysis provides a review of what is know of the mountain goat and bighorn sheep population on the Wasatch Front. An evaluation of hunting is outside the scope of this analysis. See response to comment 004.

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A case might be made for the opportunity to view wild animals, such as Rocky Mountain bighorn sheep in their natural habitats as an important aspect of a wilderness experience - just as the opportunity to hear wolves howl or watch them take down an elk would be. But there are Rocky Mountain bighorn sheep in the wilderness areas for people to view; while on the other hand, Rocky Mountain goats are not native to Utah, having first been introduced to the state by UDWR in 1968 via transplant from Olympic National Park in Washington. Undoubtedly, they are wonderful animals and a delight to watch, but there is no evidence that they are native to the state. And this means that, unlike the bighorn sheep, they are not native to Wasatch Mountain wilderness areas. Consequently, it is hard to see how viewing them in the wilderness areas, however much enjoyment it might bring to hikers, is important to the wilderness character of the wilderness areas. In short, being able to observe non-native


See response to comment 035.11

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species in a wilderness seems to clearly not be integral to the wilderness character of the areas in question.



Furthermore, while the opportunity to view wild animals in their natural habitat is a wilderness value, wilderness character is essentially about wildness, not the recreation opportunity to view mountain goats or bighorn sheep or any other species.


The Wilderness values, with regards to the various alternatives, were evaluated in the Minimum Requirements Analysis (MRA) and are reflected in the NEPA analysis. See the purpose and need description as well as the effect to wilderness in the EA.

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Here it is worth noting the very interesting fact that UDWR believes the goats and sheep are not reaching herd objectives set by the agency. Since 1999, the mountain goat population in the three wildernesses has declined by 40%. (About 90 % of the mountain goats in the national forest, inclusive of the wilderness areas, are found inside the wilderness areas). Also, since reintroduction of bighorn sheep to the forest (which were translocated from Canada), the herd has, in the language chosen by UDWR, become "stagnant." Expressed less tendentiously, it has stopped growing. It is patently unscientific to assume that the population ought to be bigger than it is. To the contrary, the fact the population has declined since the advent of bighorn sheep suggests strongly that the habitat has reached carrying capacity for the sympatric species. Indeed, this assumption would explain why only 37% of the bighorn sheep on the forest are found within the wilderness areas. It is entirely plausible, even probable from an empirical

Wildlife UDWR uses the following definitions: The term "stable" is often used to describe a healthy population that exhibits relatively constant survival and recruitment rates, often near its carrying capacity or population objective. The term "stagnant" is used to describe a population that exhibits no clear growth trend and shows poor population performance relative to a population objective or what the habitat could sustain.

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point of view, that competition for forage between the two species is causing a degree of habitat partitioning between them by pushing bighorns into sub-optimal habitat outside the wilderness areas. It also offers an entirely plausible explanation for the concomitant decline in the number of mountain goats inside the wilderness areas. Indeed, UDWR acknowledges the points about competition and partitioning in its mountain goat management plan: Mountain goats and Rocky Mountain bighorn sheep typically occur in broadly similar habitats, at similar elevations, and consume many of the same forages. Thus, the potential exists for competition between these two species, particularly when seasonal habitat overlap occurs (Hobbs et al. 1990, Laundre 1994, Gross 2001). However, even where both are present, resource partitioning appears to minimize conflicts (Laundre 1994). Specifically, there is enough disparity in site selection, seasonal use, and forage preference such that range

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overlap does not result in as much direct competition as expected when each species' habitat requirements are considered separately. (Underline added to emphasize that, while partitioning might reduce competition, it does not eliminate it, and thus having both species occupy the same habitat - a habitat that they have not both occupied at least since the last ice age - would of course result in a reduction in the herd size of at least one of the species, probably both.)

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This is significant for several reasons: (1) It would easily explain why the bighorn sheep herd has stabilized at a lower number than UDWR hoped for; (2) it would at least partially explain why the mountain goat population has declined by 40% since the mountain sheep were reintroduced; (3) it is an unnatural situation and hence arguably contrary to the wilderness character of the wilderness areas to have both of these species attempt to occupy the same habitat to which only one of them is native; and (4) it is a situation that might foster disease transmission between members of the two species. In fact, both species are recognized vectors for contagious ecthyma, respiratory pneumonia and Johne's disease, all of which can be fatal to infected animals. This likely limits the potential size for both herds (bighorn and goat).

Wildlife Thank you for your comment. All alternatives being analyzed will meet the Forest Service legal requirements. . The Wilderness values, with regards to the various alternatives, were evaluated in the Minimum Requirements Analysis (MRA) and are reflected in the NEPA analysis. See the purpose and need description in the EA.

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UDWR wants to take tissue samples from both sheep and goats in part to identify any diseases that might be present. We have no quarrel with them wanting to do that, but we fail to see why landing helicopters in wilderness areas is necessary for doing it, since they can always examine the carcasses of sheep and goats killed by hunters. Furthermore, and more importantly for present purposes, we do not see how such information can be necessary for the FS to be able to manage the areas for wilderness character. The question of whether it is the minimum requirement for doing so doesn't even arise if it is not necessary in the first place.

Alternatives The Wilderness values, with regards to the various alternatives, were evaluated in the Minimum Requirements Analysis (MRA) and are reflected in the NEPA analysis. The use of mechanized equipment in a designated wilderness area can occur but should be analyzed and approved by the Forest Service.



If UDWR feels that it is important, for its own management purposes, to obtain tissue samples from sheep and goats in the wilderness areas, it can sample dead animals brought in by hunters and/or send personnel in on foot or horseback to dart the animals. This second option would no doubt be difficult to do, but it could be done; and it would not

Alternatives Thank you for your comment. All alternatives being analyzed will meet the Forest Service legal requirements. . The Wilderness values, with regards to the various alternatives, were evaluated in the Minimum

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pose a problem so far as wilderness management is concerned. Forest Service policy provides guidance on this point: "Where a choice must be made between wilderness values and visitor or any other activity, preserving the wilderness resource is the overriding value. Economy, convenience, commercial value, and comfort are not standards of management or use of wilderness." (FSM 2320.6)

Requirements Analysis (MRA) and are reflected in the NEPA analysis. See the purpose and need description in the EA.



UDWR's other stated purpose for its proposal, is to fit captured sheep and goats with collars that will allow UDWR personnel to track the movements of the animals. We have no problem with UDWR wanting to track the movements of the animals, perhaps to see which parts of the habitat they use during different seasons. But again, what has this got to do with the Forest Service's statutory duty to manage the wildernesses for wilderness character? Is this kind of knowledge something that the FS needs to acquire in order to preserve or enhance the wilderness character of the


The Wilderness values, with regards to the various alternatives, were evaluated in the Minimum Requirements Analysis (MRA) and are reflected in the NEPA analysis. See the purpose and need description in the EA.

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wilderness areas? We do not see how this can be so.



Finally, we note that UDWR fails to explain how they might use whatever information they could hope to gain from the proposed research project in order to meet the agency's twin objectives of providing a maximum number of sheep and goats for hunting and viewing. In the total absence of any information regarding this, it is not possible to know whether UDWR will want to do a follow-up study, or several of them, in which case we are concerned that ultimately there may be a request for many more studies tiered off the one being proposed. And obviously, this would severely complicate the issue so far as managing the wildernesses for wilderness character is concerned. It would open a whole new can of worms, as it were. Until UDWR explains how findings from the


Thank you for your comment. All alternatives being analyzed will meet the Forest Service legal requirements. . The Wilderness values, with regards to the various alternatives, were evaluated in the Minimum Requirements Analysis (MRA) and are reflected in the NEPA analysis. See the purpose and need description in the EA.

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proposed study might influence future management decisions (including possibly the desire for further intrusive research in the wilderness areas), neither the FS nor the public can accurately assess the impacts to wilderness character that this proposal might bring in its train if it is approved.



For the reasons stated above, the signatories to this letter are opposed to UDWR's proposal and we urge the Forest Service to deny it. Please notify us when a decision has been made and inform us of objection opportunities.

General oppostion, request for information

Thank you for you comment. The Forest Service will provide a 30-day comment period on the draft EA as well as a 45-day objection period on the final EA and draft decision.

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2017 N/A - Form

Mutiple Form Letter Various Please reject the Utah Division of Wildlife Resource's proposal to capture mountain goats and bighorn sheep in the Twin Peaks, Lone Peak and Mt. Timpanogos Wilderness areas. The U.S. Forest Service's first responsibility is to protect the wilderness character of the Wildernesses. Specifically: o The Forest Service needs to say "NO" to helicopter landings in these three Wildernesses. o Helicopter use is incompatible with Wilderness, harasses wildlife, and destroys the experience for wilderness visitors. o The Forest Service needs to protect the areas' wilderness character by rejecting efforts to perpetuate non-native mountain goats in these Wildernesses. o Wildlife in Wilderness should only be evaluated with noninvasive, wilderness-compatible means. This not only protects Wilderness, but reduces the stress animals suffer when captured.

Wildlife/wilderness Thank you for your comment. All alternatives being analyzed will meet the Forest Service legal requirements. . The Wilderness values, with regards to the various alternatives, were evaluated in the Minimum Requirements Analysis (MRA) and are reflected in the NEPA analysis. See the purpose and need description in the EA. See response to comment 004.

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2017 N/A - Form

Multiple Form Plus/Unique Comments

Various Commenters stated that the proposal is intended to keep the population numbers large to benefit hunting based on hunting permits being issued for the area.

Hunting and viewing opportunities

Hunting regulations are outside the scope of this analysis and the Forest Service's authority.

2017 N/A - Form


Various Commenters stated that the USFS should deny the proposal based on the district court ruling in Idaho that recently ruled against the use of helicopters in the Frank Church-River of No Return Wilderness to capture and collar elk at the request of the IDFG.



2017 N/A - Form


Various Commenters stated that the USFS should deny the proposal stating that the proposal violates the Wilderness Act.

Wilderness Act Effects to Wilderness were analyzed in the EA.

2017 N/A - Form


Various Commenters stated that the State should undertake a habitat analysis to assess whether the non-native goats have run their course.

Wildlife This suggestiion has been forwarded on to Utah Division of Wildlife Resources.

2017 N/A - Form


Various Commenters stated that the State should hike in rather than use helicopters.

Alternatives A range of alternatives was analyzed in the EA including "Alternatives Considered but Eliminated from Detailed Analysis."

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2017 N/A - Form


Various Commenters stated that proceeding with the project is a waste of taxpayer dollars.

Budget Thank you for your comment.

2017 N/A - Form


Various Commenters stated that the use of helicopters is considered noise pollution.

Noise Noise pollution was not carried forward as a key issue for analysis.

2017 N/A - Form


Various Commenters stated that killing and capturing animals is cruel.


2017 N/A - Form


Various Commenters stated that helicopter use should be for life threatening emergencies only.

Safety Search and rescue operations have been addressed in the EA.

2017 N/A - Form


Various Commenters stated that roughly two-thirds of Bighorn range lies outside the Wilderness and they could be captured there.

Wildlife UDWRs proposal is to determine potential disease transmission between mountain goat and bigorn sheep. It is the animals that interact in wilderness that are of the greatest concern which has

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lead to the proposed action.

2017 N/A - Form


Various Commenters expressed concern regarding the frequency of landings, specifically that this effort could lead to additional landings and set a precedent for future proposals. It was also stated that the goats and sheep are to be captured via helicopter netting, so every animal taken for analysis will require at least two helicopter landings.

Frequency of landings

The proposed action is described in Chapter 2 of the EA.

2017 N/A - Form


Various Commenters stated that the cause of sickness to the animals could be caused by humans.


2017 N/A - Form


Various Commenters stated that mountain goats are not native to the Wasatch and were introduced solely to provide additional hunting opportunities. Also that mountain goats compete with native bighorn sheep for forage and their noticeable effects on high alpine vegetation have not been evaluated. The goats and sheep are to be captured via helicopter

Wildlife See the existing condition for a discussion on mountain goat and bighorn sheep. Vegetation impacts assoicated with the proposed action are discussed. The hunting of certain species and the competition between

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netting, so every animal taken for analysis will require at least two helicopter landings.

species is outside the scope of this analysis.

2017 N/A - Form


Various Commenters stated that the analysis could be conducted via occular observation.

Alternatives Occular observations do not accomplish the purpose and need of the project.

2017 N/A - Form


Various Commenters asked the USFS to consider the cumulative impacts of helicopter use and noise pollution.

Noise Cumulative effects are evaluated as part of this analysis.

2017 N/A - Form


Various Commenters stated that the State sould conduct a study to determine the cause of decline of the animals.

Wildlife The purpose and need of this project is to respond to this question.

2017 N/A - Form


Various Commenters stated that several months ago, the UDWR asked permission to capture mountain goats, but because they aren’t native it was virtually impossible to show the project was necessary to benefit the Wildernesses. They included that it now appears the UDWR is piggybacking bighorn sheep onto the project to make it

Proposed Action and Purpose and Need

The Utah Division of Wildlife Resources have modified their proposal to include bighorn sheep. This has modified the analysis while maintaining the purpose and need. A discussion of the

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appear it might help a native species.

species to be evaluated is found in the exisiting conditiions.

2017 N/A - Form


Various Commenters stated that the Trump administration is making a disgrace of the environment.

Outside the scope of analysis


2017 N/A - Form


Various Commenters stated that helicopters in the wilderness would cause a disturbance to hikers.


Effects to Wilderness were analyzed in the EA.

2017 N/A - Form


Various Commenters stated that the last thing the plants, wild animals, and human visitors need is buzzing helicopters which at the very least would bring noise and air pollution, terrorize animals, and cause serious erosion.


Effects to key issues are addressed or dismissed in the EA.

2017 N/A - Form


Various Commenters stated that non-native species should not be allowed to compete with native species.

Wildlife Thank you for your comment. A discussion of mountain goat and bighorn sheep can be found in the existing conditon discussion in wildllfe.

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2017 N/A - Form


Various Commenters stated that the safety of operations should be considered.

Safety Safety would be addressed in UDWRs operations plan.

2017 N/A - Form


Various Commenters stated that State Management Plans are not as protective as they should be.

Wildlife An evaluation of the State Management Plans are outside the scope of this analysis.

u.s. department of agriculture forest service utah division of wildlife resources...

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