Helicopter Landings in the Twin Peaks, Lone Peak, and Mount

United States Department of Agriculture Forest Service Helicopter landings in the Twin Peaks, Lone Peak, and Mount Timpanogos wilderness areas to capture and collar mountain goats and bighorn sheep project Environmental Assessment

Uinta-Wasatch-Cache National Forest, Salt Lake and Pleasant Grove Ranger Districts, Salt Lake and Utah Counties, Utah July 2017

Environmental Assessment

Helicopter landings in the Twin Peaks, Lone Peak, and Mount Timpanogos wilderness areas to capture and collar mountain goats and bighorn sheep

Uinta-Wasatch-Cache National Forest, Salt Lake and Pleasant Grove Ranger Districts, Salt Lake and Utah Counties, Utah

Lead Agency: U.S. Forest Service

Responsible Official: David C. Whittekiend, Forest Supervisor 857 West South Jordan Parkway South Jordan, UT 84095

For Information Contact: Pamela Manders, Forest Wildlife Program Manager 857 West South Jordan Parkway South Jordan, UT 84095

Cover Photo: Photo by Rusty Robinson.

In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, religion, sex, gender identity (including gender expression), sexual orientation, disability, age, marital status, family/parental status, income derived from a public assistance program, political beliefs, or reprisal or retaliation for prior civil rights activity, in any program or activity conducted or funded by USDA (not all bases apply to all programs). Remedies and complaint filing deadlines vary by program or incident.

Persons with disabilities who require alternative means of communication for program information (e.g., Braille, large print, audiotape, American Sign Language, etc.) should contact the responsible Agency or USDA’s TARGET Center at (202) 720-2600 (voice and TTY) or contact USDA through the Federal Relay Service at (800) 877-8339. Additionally, program information may be made available in languages other than English.

To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, AD- 3027, found online at http://www.ascr.usda.gov/complaint_filing_cust.html and at any USDA office or write a letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to USDA by: (1) mail: U.S. Department of Agriculture, Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, SW, Washington, D.C. 20250-9410; (2) fax: (202) 690-7442; or (3) email: [email protected].

USDA is an equal opportunity provider, employer and lender.

Table of Contents Table of Contents ...... 3 Chapter 1: Purpose and Need ...... 4 1.1 Introduction ...... 4 1.2 Project Area ...... 4 1.3 Background ...... 5 1.3.1 Existing Condition ...... 6 1.4 Proposed Action ...... 8 1.5 Purpose and Need ...... 9 1.6 Forest Plan Consistency ...... 9 1.7 Public Involvement and Consultation ...... 11 1.7.1 Scoping/Comment Period ...... 11 1.8 Decision Framework ...... 11 1.9 Project Record ...... 12 1.10 Issues ...... 12 1.10.1 Key Issues ...... 12 1.10.2 Issues Addressed but not Analyzed in Detail ...... 13 Chapter 2: Alternatives ...... 14 2.1 Introduction ...... 14 2.2 Alternatives Considered in Detail ...... 14 2.2.1 Alternative A (No Action) ...... 14 2.2.2 Alternative B (Proposed Action) ...... 14 2.2.3 Alternatives Considered but Eliminated from Detailed Study ...... 15 2.2.4 Summary Comparison of Alternatives ...... 17 Chapter 3: Environmental Consequences ...... 18 3.1 Introduction ...... 18 3.1.1 Wilderness Resources ...... 18 Chapter 4: Consultation and Coordination ...... 26 4.1 Preparers and Contributors ...... 26 4.2 Consultation and Coordination ...... 26 4.3 Laws and Regulations ...... 26 Appendix A: Scoping Report ...... 30 Appendix B: Issues Addressed but not Analyzed in Detail ...... 99 Appendix C: Design Criteria & Mitigation Measures ...... 103 Appendix D: References ...... 105

Chapter 1: Purpose and Need

1.1 Introduction

This Environmental Assessment (EA) discloses the environmental impacts of landing helicopters and dropping materials from helicopters to collect biological samples and collar bighorn sheep and mountain goats in the Twin Peak, Lone Peak and Mount Timpanogos Wilderness areas within the Wasatch and Uinta National Forests. The Uinta-Wasatch-Cache (UWC) National Forest received this proposal from the Utah Department of Wildlife Resources (UDWR) as part of UDWR’s mission of conserving and managing protected wildlife populations. The biological samples enabled by the authorization of helicopter landings and drops would allow UDWR to test for disease and evaluate disease spread between the two species. The collaring enabled by the authorization of helicopter landings and drops would allow UDWR to monitor the two species’ interactions and movements in this area.

This document has been prepared pursuant to the requirements of the National Environmental Policy Act (NEPA), 40 CFR 1500-1508, the National Forest Management Act (NFMA) implementing regulations of, including transition language at 36 CFR 219.14, and the 2003 Wasatch-Cache (WCFP) and Uinta (UFP) National Forests Revised Forest Land and Resource Management Plans (LRMP) (USDA 2003 and 2003a). Formal planning for this project was initiated on May 25, 2016 with a legal notice in the Provo Herald and the Salt Lake Tribune. The initial proposal included the capture and collaring of mountain goats. That proposal was modified by UDWR and expanded to also include bighorn sheep because of concern of disease transfer from one species to another. A revised legal notice was published after this change on February 9, 2017.

1.2 Project Area

The project area falls within the UDWR’s Wasatch Mountains Management Unit, the Wasatch-Cache Forest Plan’s Central Wasatch, and the Uinta Forest Plan’s American Fork and Lower Provo Management Areas. The size of the project area is defined by the alpine habitat of mountain goats located on National Forest System (NFS) lands and where populations of mountain goat and bighorn sheep overlap. The southern boundary is Provo Canyon and the area extends north along the spine of the Wasatch Mountain Range and is bounded to the north by Big Cottonwood Canyon. Three National Wilderness Preservation System areas make up a majority of the habitat for mountain goat and include Mount Timpanogos, Lone Peak and Twin Peaks Wilderness areas. The east and west boundaries of the project areas are defined by the Uinta and Wasatch National Forest boundaries. See Figure 1 below.

Helicopter landings in the Twin Peaks, Lone Peak, and Mount Timpanogos wilderness areas to capture and collar mountain goats and bighorn sheep Project Environmental Assessment Salt Lake and Pleasant Grove Ranger Districts, Uinta-Wasatch-Cache National Forest 4

Figure 1. Project area map for the bighorn sheep and mountain goat capture project on the Uinta-Wasatch-Cache National Forest in Northern Utah adjacent to Salt Lake City, Utah.

1.3 Background

Bighorn sheep have been protected wildlife in Utah since 1896, and mountain goats have been protected wildlife in Utah since 1919. UDWR is charged by the Utah State Legislator to manage Utah’s wildlife resources and to assure the future of protected wildlife for its intrinsic, scientific, educational, and recreational values for the people in the State of Utah.

Through monitoring efforts, UDWR has become concerned about the mountain goat and bighorn sheep populations found between Big Cottonwood Canyon and Provo Canyon. UDWR’s findings indicate that mountain goat populations have declined by 40 percent since 1999 (UDWR Big Game Annual Report 1999 and 2015), and bighorn sheep populations have remained stagnant since their establishment in 2000 (Shannon, 2014). 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. Both populations have experienced poor herd performance for more than 15 years. Because they live sympatrically, it has been speculated that there is a potential to spread disease between the two species (UDWR, 2015). 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.

Bighorn sheep and mountain goat populations have the potential to be limited by respiratory disease, which may contribute to suppression of population growth on the Wasatch Mountains. Mycoplasma ovipneumoniae is a pathogen associated with respiratory disease (Besser et al. 2014) and has been documented in both bighorn sheep and mountain goat populations in Utah (UDWR unpublished data). Furthermore, bighorn sheep and mountain goats may serve as a reservoir and potential vector for disease transmission between the two species (Wolff et al. 2016). UDWR has made disease surveillance on all bighorn sheep and mountain goat populations a priority, and they are particularly interested in identifying pathogens with respective strain types in sympatric populations on the Wasatch Mountains.

According to aerial spatial data, approximately 90 percent of the mountain goat population, and approximately 40 percent of the bighorn sheep population is found within three wilderness areas located in the proposed project area (Personal Communication, Robinson 2017). Since the Wasatch mountain goat population rarely leave the wilderness areas, UDWR’s proposal is to capture the desired number of animals within the wilderness. Capture work may occur outside of wilderness area, as the opportunity exists, but these activities have already been authorized through a Memorandum of Understanding (MOU) between the UDWR and Forest Service.

1.3.1 Existing Condition

1.3.1.1 Wildlife – Bighorn Sheep

Bighorn sheep are native to Utah. Archeological evidence indicates they were well known to the prehistoric inhabitants of Utah, since bighorns are depicted in pictographs and petroglyphs more than any other form of wildlife. Historical records of the first settlers in the state also confirm the presence of bighorns. Father Escalante noted in his journal as he crossed the Colorado River in Utah, “through here wild sheep live in such abundance that their tracks are like those of great herds of domestic sheep” (Rawley 1985).

Native populations of Rocky Mountain bighorn sheep were nearly extirpated following pioneer settlement. A few scattered sightings of bighorns persisted in northern Utah as late as the 1960's. Factors contributing to their demise included competition with domestic livestock for forage and space, vulnerability to domestic livestock-borne diseases, habitat conversions away from native grasslands towards shrub lands due to excessive grazing and fire suppression, and unregulated hunting (Shields 1999).

Bighorn sheep were first reintroduced onto Mt. Timpanogos in January of 2000. Five releases have occurred in Grove Creek Canyon at the base of Mount Timpanogos totaling 82 bighorns. In January 2000, 25 bighorns were reintroduced from Rattlesnake Canyon, Utah. This herd included six rams, 16 ewes, and three lambs. Then, in January 2001, two rams and eight ewes were translocated from Hinton, Alberta, Canada. In February 2002, three rams and six ewes were reintroduced from Sula, Montana. In January 200, 20 ewes were brought and released again from Sula, MT followed by a release from Alamosa, CO in March 2007 consisting of 17 ewes and one ram. Despite management efforts to establish this population to a minimum viable population size of 125 animals, the Mt. Timpanogos herd reached a high of 65 individuals in 2007 but typically hovers between 30 and 40.

Commingling with domestic sheep and bighorns has been observed in the past on Mt. Timpanogos. Disease is suspected as a factor in poor population performance, but data regarding immunological, etiological, and pathogen strain typing have not been collected. Other documented causes of mortality are predation and vehicle collisions (Utah Division of Wildlife Resources, 2013).

It is believed, that as bighorn sheep interact across the population’s range exposure of bighorn sheep to other bighorn sheep carrying different strains of bacterium occurs. Therefore, proximity of bighorn sheep to domestic sheep grazing areas and the connectivity of habitats between other bighorn sheep herd’s seasonal ranges play a critical role in management of respiratory disease (Utah Division of Wildlife Resources, 2013).

Bighorn sheep are uniquely adapted to inhabit some of the most remote and rugged areas in Utah. They exist in some of the most hostile climatic conditions ranging from the hot, dry canyonlands of southern Utah to the cold, snowy alpine regions of Utah’s northern mountains. Bighorns are sometimes referred to as a wilderness species because of the naturally remote and inaccessible areas they inhabit. Bighorns prefer open habitat types with adjacent steep rocky areas for escape and safety. Habitat is characterized by rugged terrain including canyons, gulches, talus cliffs, steep slopes, mountaintops, and river benches. The diet of mountain sheep is comprised primarily of grasses and forbs, although sheep may also utilize shrubs depending on season and availability. Most Rocky Mountain bighorns have seasonal migrations with established winter and summer ranges, whereas desert bighorns generally do not migrate. Extensive historical bighorn habitat occurs throughout Utah, however, not all habitat is currently suitable for reestablishment of bighorn populations. Vegetative changes, human encroachment, and continued domestic sheep grazing make some areas unsuitable for bighorn restoration (Utah Division of Wildlife Resources, 2013).

Habitat management practices include conversions of domestic sheep grazing permits, vegetative treatments, and water developments. Habitat utilization distribution of bighorn sheep in the Mt. Timpanogos population stretches the Wasatch front from Provo Canyon on the south to Corner Canyon on the north, and includes Mt. Timpanogos, Mahogany Mtn., the areas of Dry Canyon, Battle Creek, and Grove Creek, Box Elder Peak, White Baldy Peak, American Fork Canyon, and Box Elder, Smooth, Preston, Willow, and Wadsworth Canyons (Utah Division of Wildlife Resources, 2013).

Bighorn sheep are a sensitive species for the Uinta-Wasatch-Cache National Forest. Bighorn sheep are managed as an once-in-a-lifetime species in Utah by the UDWR. The first hunt for bighorn sheep in Utah was held in 1967 for the desert subspecies on the San Juan Unit. Since the initial hunts, bighorn sheep permits have generally been increasing.

1.3.1.2 Wildlife – Mountain Goats

Mountain goats are native to the North American continent and the Northern Rocky Mountains. The first documented report of mountain goat found in Utah was in a census report created by the U.S. Forestry Department, which displayed game conditions for Utah’s National Forests. This report was referred to in the twelfth biennial report of the Fish and Game Commissioner of the State of Utah, for the years 1917- 1918. There are no confirmed sightings of mountain goat in Utah since 1918, until they were transplanted in the Lone Peak area in 1967.

Mountain goats (Oreamnos amreicanus) are not true goats as the name suggests, but share the family Bovidae with true goats (Capra spp.), gazelles (Gazella spp.) and cattle (Bos spp.). They are in the

subfamily Caprinae along with 32 other species including sheep (Ovis spp.) and muskoxen (Ovibos spp.). Mountain goats are the only living species in the genus Oreamnos.

Mountain goats are obligate occupants of the highest alpine environments in Utah. Elevations of up to 13,000 feet are frequented in summer, and winter habitat may be high as 12,000 feet on windblown ridges of some units. Exposed, precipitous cliffs are an essential component of mountain goat habitat. Mountain goats typically prefer sites that are close to escape terrain with an intermediate slope typically between 20 and 50 degrees (Gross, 2002). Suitable sites encompass most aspects of mountain goat habitat needs including escape terrain, feeding sites, and birthing and nursery areas.

Mountain goats currently inhabit several mountain ranges in Utah including numerous peaks along the Wasatch Front, Uinta Mountains, La Sal Mountains, Mt. Dutton and Tushar Mountains. All populations are the result of introductions; the first of which occurred in 1967 when six mountain goats (two billies, four nannies) were released in the Lone Peak area. Initial transplants used mountain goats from Olympic National Park in Washington as the source herd. After those transplanted herds became established, they became source herds for future transplants. The Tushar Mountains population has been the most common Utah source herd because of its rapidly growing population and relative ease of accessibility (Utah Division of Wildlife Resources, 2013).

UDWR has reported a total of six transplants. One in Lone Peak area, two in the Mount Olympus area, one in the Mount Timpanogos area and two in the Provo Peak area. A total of 42 animals have been released over the past 50 years with no releases occurring in the past 27 years (Utah Division of Wildlife Resources, 2013).

In Utah, mountain goat populations are surveyed via helicopter every two to three years. During these flights, biologists survey all potential mountain goat habitat in August or September and classify all observed animals as billies, nannies, or kids. Previous studies have shown that sightability is usually around 80 to 85 percent for mountain goats. In addition to the helicopter surveys, most biologists conduct ground-based or fixed-wing classification counts on units during years when they are not surveyed with a helicopter. This provides biologists with data on annual production and greatly improves UDWR’s population models for those units (Utah Division of Wildlife Resources, 2013).

1.4 Proposed Action

UDWR proposes to capture up to 20 mountain goats and ten bighorn sheep across the project area with the focus placed on the individuals inhabiting the Twin Peaks, Lone Peak, and Mt. Timpanogos Peak Wilderness areas using the helicopter net-gun method. The Federal action requiring NEPA is the Forest Service decision to authorized the landing of helicopters to dropping off people and supplies to capture mountain goats and bighorn sheep per 36 CFR 261.18, 251.50, 261.1(b), and 261.1a. Landing helicopters or dropping material from helicopters without authorization is prohibited. Authorizing the activity is a “federal action” which triggers NEPA requirements.

UDWR’s proposal is to use a helicopter in the Twin Peaks, Lone Peak and Mt Timpanogos Wilderness areas to capture, take biological samples for disease testing, and GPS collar up to 20 mountain goats and ten Rocky Mountain bighorn sheep. The capture effort would take place from September through November. A net would be shot from the helicopter to capture the animals. It is estimated that it would take about 30 hours to capture the desired number of animals using this method.

UDWR’s proposal also includes helicopter staging areas. Specific locations have not been identified but would be located outside of the wilderness areas along public roads or at the Forest Service Silver Lake Flat and Timpooneke trailheads and Snowbird. UDWR would need to obtain separate approvals for staging areas not located on NFS lands.

1.5 Purpose and Need

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.

1.6 Forest Plan Consistency

This document is consistent with the 2003 Wasatch-Cache National Forest LRMP, as amended and the Uinta National Forest LRMP, as amended (USDA 2003 and 2003a). Information from the Forest Plans, the Forest Plan amendments, the Final Environmental Impact Statement prepared in concert with the plans and all associated appendices has been referenced and incorporated into this document. Management direction in the Forest Service Directive System, including the Forest Service Manual (FSM) and the Forest Service Handbook (FSH), is part of Forest Service management direction and is not repeated in the Forest Plan itself.

The Forest Service Manual states, “The allowance for management of wildlife in wilderness is set forth by manual direction and a formal Memorandum of Understanding. The first group of policies (a) indicate guidance from the Forest Service Manual for Wilderness management. The second group (B) describes guidance from the Forest Service manual for wildlife management. The third group of policies (C) pertain to guidance from other sources. a. Forest Service Manual Direction for Management of Wildlife within Wilderness 2323.3- Management of Wildlife and Fish 2323.31 Objectives 1. Provide an environment where the forces of natural selection and survival rather than human actions determine which and what numbers of wildlife species will exist. 2. Consistent with objective 1, protect wildlife and fish indigenous to the area from human caused conditions that could lead to Federal listing as threatened or endangered. 3. Provide protection for known populations and aid recovery in areas of previous habitation, of federally listed threatened or endangered species and their habitats. 2323.32 Policy 1. Recognize that States have jurisdiction and responsibilities for the protection and management of wildlife and fish populations in wilderness. Cooperate and work closely with State wildlife and fish authorities in all aspects of wildlife and fish management. Base any Forest Service

recommendation to the State wildlife and fish agencies on the need for protection and maintenance of the wilderness resource. 2. Recognize wilderness protection needs and identify any needed requirements in coordination efforts and in cooperative agreements with State agencies. 3. Wildlife and fish management programs shall be consistent with wilderness values. 4. Discourage measures for direct control (other than normal harvest) of wildlife and fish populations. 5. Apply the “Policies and Guidelines for Fish and Wildlife Management in Wilderness and Primitive Areas,” developed jointly by the Forest Service, Bureau of Land Management, and the International Association of Fish and Wildlife Agencies (IAFWA) in a practical, reasonable, and uniform manner in all National Forest wilderness units. Use the guidelines as a foundation for or as addendums to State or individual wilderness cooperative agreements.”

Additionally, the desired future condition for wildlife resources in the WCFP states, “Management activities move habitat conditions toward historic range of variability, contribute to recovery of listed species and maintain or improve conditions for sensitive species (Bighorn sheep).” (USDA 2003a p.4-6).

Table 1: Summary of management prescriptions by Forest Plan within the project area. Management Management Emphasis GIS Acres Prescription within Analysis Area Wasatch-Cache Forest Plan revised 2003 includes all of Twin Peaks Wilderness and the northern portion of Lone Peak Wilderness located in Salt Lake County and managed by the Salt Lake Ranger District 1.1 Opportunity Class I: This area in existing wilderness is characterized by an 17,594 unmodified natural environment. Human induced change is temporary and minor. Outstanding opportunities for solitude and unconfined recreation are available for visitors, who travel in small groups, practice excellent wilderness ethics and spend extra effort to leave no trace. Encounters with others are rare. 1.2 Opportunity Class II: This area in existing wilderness is characterized by 1,620 predominately unmodified natural environment. Human induced change is evident but will recover (slowly in higher elevation areas). Outstanding opportunities for solitude and unconfined recreation exist. Encounters with others are more frequent than Class I. 1.3 Opportunity Class III: This area in existing wilderness is characterized by 1,914 predominately unmodified natural environment, but impacts could persist from year to year. During peak season and in popular areas concentrated use is more common and opportunities for solitude and unconfined recreation more limited. Uinta Forest Plan revised 2003 includes the southern portion of Lone Peak Wilderness located in Utah County and Mount Timpanogos Wilderness managed by the Pleasant Grove Ranger District 1.4 Wilderness: These areas are managed consistent with the Wilderness Act of 31,349 1964 and the Utah Wilderness Act of 1984 with no delineation for condition class or recognition of varying levels of opportunities for solitude. These areas are managed to allow natural processes to prevail. Vegetation management is limited to wildland fire use and noxious weed treatments that do not employ mechanized or motorized means. Prescribed fire use is allowed only when necessary to promote or maintain wilderness characteristics or integrity. No timber harvest is allowed. Grazing will continue to be allowed per the Wilderness Act of 1964 and the Utah Wilderness Act of 1984. Recreation

Management Management Emphasis GIS Acres Prescription within Analysis Area developments such as pit toilets may exist where necessary to accommodate high visitor use.

1.7 Public Involvement and Consultation

1.7.1 Scoping/Comment Period

Public involvement has been extensive throughout the planning and analysis process leading to this document. Formal planning and the comment period per 36 CFR 218 for this project were first initiated on May 25, 2016 when a legal notice was published in the Salt Lake Tribune and Provo Daily Herald. A scoping letter was mailed to individuals and organizations on the Salt Lake and Pleasant Grove Ranger District mailing lists. Thirty-four comments were received and reviewed by the interdisciplinary team.

Following a revised proposal from UDWR in January of 2017, a second legal notice was published in the Salt Lake Tribune and Provo Daily Herald on February 9, 2017 and ended on March 9, 2017. A scoping letter was mailed to the same list of individuals and organizations. Approximately 2,400 comments were received and reviewed by the interdisciplinary team.

A summary of how all scoping comments were addressed is included in the scoping report which is included as Appendix A.

Commenters voiced a variety of concerns including, but not limited to, potential adverse impacts on wildlife and wildlife habitat and wilderness character. The comments were used to develop the key issues to be carried forward for analysis described below in Section 1.10.

1.8 Decision Framework

The purpose of this document is to disclose the effects and consequences of alternatives being considered in detail. Based on information disclosed in this EA, its associated planning record, and public feedback, the Uinta-Wasatch-Cache Forest Supervisor (Responsible Official) will make a decision as to whether or not to approve the project and issue a Finding of No Significant Impact (FONSI) if no significant impacts are found.

Based on the analysis documented in the EA, the decision to be made is whether or not the Forest Service should authorize the use of mechanized equipment (helicopter) in designated wilderness areas along with the associated staging areas.

The approval would allow UDWR to helicopter net gun capture, take biological samples and GPS radio collar mountain goats and bighorn sheep in wilderness areas and obtain disease profiles to determine if these populations have been exposed to various pathogens and/or transfer disease between the species in this area. This decision only covers the work within the designated Wilderness areas given that UDWR is permitted to conduct wildlife operations outside of wilderness, on Forest Service lands, based on 2012 Memorandum of Understanding between the USDA Forest Service, Intermountain Region and the State

of Utah, Utah Division of Wildlife Resources (USDA Intermountain Region of the Forest Service and Utah Division of Wildlife Resources, 2012).

1.9 Project Record

This environmental assessment hereby incorporates by reference all appendices and the project record. The project record contains specialists’ ancillary documentation and technical documentation used to support the analysis and conclusions in this environmental assessment. Relying on specialist reports and the project record helps implement the Council on Environmental Quality regulations’ provision that agencies should reduce NEPA paperwork (40 CFR 1500.4). The objective is to furnish enough site- specific information to demonstrate a reasoned consideration of the environmental impacts of the proposed action and how these impacts can be mitigated, without repeating detailed analysis and background information available elsewhere. The project record is available for review at the Supervisor’s Office in South Jordan, Utah.

1.10 Issues

Scoping is used to identify issues that relate to the effects of the proposed action. An issue is an unresolved conflict or public concern over a potential effect on a physical, biological, social or economic resource as a result of implementing the proposed action and alternatives to it. An issue is not an activity; instead, the projected effects of the proposed activity create the issue. Issues are generated by the public, other agencies, organizations and Forest Service resource specialists and are in response to the proposed action. Issues provide focus for the analysis of environmental effects and may influence alternative development, including development of project design criteria. In this document issues are tracked and are used to display differing effects of the proposed action and the alternatives. A complete issue identification summary is in the project record files, including issues eliminated from detailed study along with the rationale for their elimination.

The Forest Service separated the issues into two groups: key issues and non-key issues. Key issues were defined as issues identified during public scoping that suggested an alternative to meeting the purpose and need for action.

Letters submitted during the public scoping/comment period and Forest Service consideration of those letters is included in the project record which is located at the Supervisor’s Office in South Jordan, Utah. A summary of these comments is also included in Appendix A – Scoping Report.

1.10.1 Key Issues

After reviewing the public comments received during scoping the Forest Service did not identify any key issues that would drive the development of an additional action alternative. Wilderness was identified as the 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 this document. 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.

1.10.1.1 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 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, or plant or animal species?

1.10.2 Issues Addressed but not Analyzed in Detail

Non-key issues were identified as those that are either: 1) outside the scope of the proposed action; 2) already decided by law, regulation, Forest Plan, or other higher level decision; 3) irrelevant to the project or its resources; or 4) conjectural and not supported by scientific or factual evidence; or 5) have been addressed by eliminating any potential effects through alternative design, design criteria, and/or mitigation measures. There is no detailed discussion of these concerns in Chapter 3. Appendix B discusses issues that were considered but not analyzed in detail and their rationale for not analyzing them. Issues that were dismissed from further analysis include; air quality, botany, climate change, cultural resources, socioeconomics, fire and fuels, fisheries and aquatic resources, noxious weeds, range, recreation, transportation, scenic values, silviculture, soils, water resources, and wildlife.

Chapter 2: Alternatives

2.1 Introduction This chapter describes and compares the alternatives considered for the Project. Two alternatives are analyzed in detail in this chapter: Alternative 1 (No Action) and Alternative 2 (Proposed Action). This chapter includes a description of each alternative considered. This chapter also presents the alternatives in comparative form, sharply defining the differences between the alternatives and providing a clear basis for choice among options to be considered by the decision maker.

As disclosed in Chapter 1 of this document, one issue was identified during the scoping process and comment periods per 36 CFR 218. The effects to wilderness character could not be resolved, nor could anticipated impacts be mitigated to a point where landing would not occur. Other potential alternatives were evaluated within the Minimum Requirements Analysis (MRA) located in the project record to determine the potential of an alternative to be the minimum necessary and still respond to the issue. Other alternatives developed through the MRA were not considered the minimum necessary, would not meet the objectives identified in the purpose and need, and/or were eliminated from detailed study.

2.2 Alternatives Considered in Detail

2.2.1 Alternative A (No Action)

The National Environmental Policy Act (NEPA) requires consideration of a “No Action” alternative. The No Action Alternative serves as a baseline to analyze the environmental effects of the action alternatives. The No Action Alternative would mean that the Forest Service would not authorize helicopter landings and drop-offs in Wilderness. No federal action is required for proposed wildlife study activities that do not involve helicopter landings and drop-offs in wilderness. Under this alternative, UDWR would continue monitoring mountain goats and bighorn sheep in their Wasatch Mountain Unit once every other year to obtain population estimates and juvenile recruitment by conducting aerial surveys and collecting data from hunter participation surveys.

An aerial survey involves approximately six flight hours above wilderness only (no landings in wilderness). At their discretion, UDWR could opt to increase the frequency of aerial surveys, but doing so would impact the staffing and funding resources available for other important programs. Also at their discretion, UDWR could opt to capture and collar animals located outside of wilderness (USDA intermountain Region of the Forest Service and Utah Division of Wildlife Resources, 2012). Low-level aerial surveys affect wilderness character with noise and disturbance. However, since the Forest Service does not regulate air traffic, there are no limitations on the extent to which UDWR may conduct over flights for aerial surveys.

2.2.2 Alternative B (Proposed Action)

Under this alternative, the Forest Service would authorize the landing of helicopters and drop-offs from helicopters for UDWR to capture, take biological samples for disease testing, and collar mountain goats and bighorn sheep in the Twin Peaks, Lone Peak and Mt. Timpanogos wilderness areas. Capture locations would be based on where mountain goat and bighorn sheep are observed during flights and from previous

aerial surveys and historic data. It is estimated that the proposed method would take 30 hours of operations to complete the necessary number of captures.

In addition to Forest Plans standards and guidelines designed to mitigate impacts, design features would also apply and are included in Appendix C.

The three staging areas that would be approved for use in this alternative on NFS lands are: Timpooneke Trailhead Parking Lot, Silver Lake Flat Parking Lot and Snowbird. Since the USFS does not have authority to permit actions on private lands, UDWR would be required to obtain permission from the respective landowners. All staging sites are outside of the wilderness areas. These areas would be used for the helicopter staging and access into the wilderness. These sites would also be used for refueling the helicopter and staff support as needed.

The UDWR plans to capture up to twenty mountain goats and ten bighorn sheep across the project area using the helicopter net-gun method. This was identified as the minimum number of animals needed for the study. Once an animal is net gunned from the helicopter, the helicopter touches down to offload one to two personnel for processing the animal. Processing the animal includes taking a blood sample, placing a collar on the animal and then releasing it. While one crew is processing the first captured animal, the helicopter proceeds to find another animal to capture and offload the second crew to process the second animal. The pilot then returns to retrieve the first capture crew.

In order to capture 30 animals, UDWR anticipates an estimated 60 landings would be required. Additional landings may occur to pick up nets if a net is shot and misses a target animal (less than ten percent of shots), but landings would be kept to a minimum, and no unnecessary landings would take place. Multiple captures would occur each day with the objective to capture a representative sample based on group size and distribution of animals.

Animals would be processed at the capture site by the helicopter crew. GPS radio collars and biological sampling kits would be used by capture crew on each captured animal. Animals that are injured, in poor health or compromised during the biological sampling may be slung to the staging area. Net gunning is the safest capture method available for animal wellbeing. (Krausman et al. 1985). The GPS radio collars would not be equipped with a drop-off mechanism but would transmit a mortality signal when an animal dies. Therefore, in the event of a mortality the collar can be retrieved. The collars are retrieved by biologists on foot so no additional landings would be required after the initial capture.

2.2.3 Alternatives Considered but Eliminated from Detailed Study

Federal agencies are required by NEPA to rigorously explore and objectively evaluate all reasonable alternatives and to briefly discuss the reasons for eliminating any alternatives that were not developed in detail (40 CFR 1502.14). In addition to the alternatives evaluated in this document, other alternatives were considered by the Interdisciplinary Team in response to concerns generated from internal and external scoping and comment. These alternatives, which were not considered in detail, are described in this section along with an explanation of why the alternatives were not considered further.

2.2.3.1 Net trapping using helicopter with ground support

This alternative was addressed in the Minimum Requirements Analysis (MRA) but eliminated from further analysis due to the fact that under this alternative, there would be similar if not greater impacts to wilderness values than under the proposed action. Under this alternative helicopter touchdowns would

still be required to support a ground crew. A proposal to provide helicopter support to fly in all materials to build, maintain, and bait multiple traps would require a comparable number of helicopter landings over a longer duration than under the proposed action.

2.2.3.2 Net trapping – ground crew only

Under this alternative, the Forest Service would authorize extended stays for ground crews and would also allow the number in a crew to be larger than what is currently allowed in wilderness. The Forest Service would not authorize the use of mechanized equipment in any of the three wilderness areas. UDWR has provided the following information to indicate that the ground crew only alternative is not feasible.  While bighorn sheep and mountain goats can certainly be captured by drop net, it is typically only effective in areas that animals are already frequenting on a regular basis. UDWR has attempted the use of drop nets to capture bighorn sheep in the past with mixed results. Usually baiting is required for two weeks or more and sometimes animals ultimately avoid the area with the bait and trap. Personnel have attempted setting up a bait site once without a net (using hay and apple mash). The sheep were seen daily less than 100 yards from the bait and never approached it in two weeks.  Drop nets are dangerous for mountain goats, which can gore each other when multiple goats are caught in the same trap (Festa-Bianchet and Cote 2008).  Approximately ten different trap sites would be required to set-up, bait, monitor, and trigger a drop net which would require a length of time that vastly exceeds UDWR’s narrow capture window of September to November. The probability of being successful at every site so that biological sampling is distributed proportionally throughout the population is unlikely.  Processing times may increase with the use of a drop net as multiple animals must be processed at once and could add stress to the animals.

Because this alternative would not meet the minimum requirements for an effective study and does not meet the needs of UDWR, it was eliminated from further review.

2.2.3.3 Chemical Immobilization – ground or aerial using dart gun

This alternative was addressed but eliminated from further analysis for two reasons. First, bighorn sheep and mountain goats would be at greater risk. Using this technique from a helicopter would not allow for recovery of the immobilized animal in enough time for crew to retrieve the mountain goat or bighorn sheep. Once the animal is darted there is a 5-15 minute induction period, the terrain is difficult and more important the animal could fall to its death before capture (Feldhamer, George, Thompson, Bruce, Chapman, Joseph, 2003) (Park, 1995). Second, it is not possible for UDWR personnel to approach the animals close enough to permit effective use of dart guns, especially from the ground.

2.2.3.4 Net gunning using helicopter – reduced helicopter landings in wilderness areas

This alternative considers a reduced number of helicopter landings in wilderness areas to capture mountain goats and bighorn sheep. The mountain goat population primarily reside in wilderness areas. The bighorn sheep that UDWR wants to capture are those that interact with the mountain goat population. A reduction of landings in wilderness would not allow the desired number of animals to be captured for the study. This alternative was therefore not analyzed in detail.

2.2.4 Summary Comparison of Alternatives

A comparison of activities between the No Action and Proposed Action Alternatives is shown below in Table 2. The summary is limited to the effects on project objectives, issues or concerns, Forest Plan standards, and other resources the Interdisciplinary Team deemed important for an informed decision. More detailed information is available in the descriptions of the alternatives in this chapter, Chapter 3, Appendix B and the project record.

Table 2. Comparison of Activities and Effects by Alternative Project Objective Indicators Alt. A Alt. B Authorize the use of mechanical equipment in wilderness to capture and No Yes collar mountain goat and Rocky Mountain bighorn sheep? Authorize an exception to the size of party and number of stock taken No No into the wilderness by one party. Wilderness Project Issue Indicators Would Activities Adversely Affect Untrammeled Character? No Yes Would Activities Adversely Affect Undeveloped Character? No Yes Would Activities Adversely Affect Natural Character? Yes No Would Activities Adversely Affect Opportunities for Solitude? No Yes Would Activities Adversely Affect Opportunities for Primitive and No No Unconfined Recreation? Would Activities Adversely Affect Other Features of Value? No No Would Activities Adversely Affect Non-use Wilderness Values? No No

Chapter 3: Environmental Consequences

3.1 Introduction

This chapter summarizes the physical, biological, social, and economic environments of the project area and the effects of implementing each alternative on that environment. It also presents the scientific and analytical basis for the comparison of alternatives presented in the alternatives chapter. The analysis is based on a thorough review of relevant scientific information, a consideration of responsible opposing views, and the acknowledgement of incomplete or unavailable information, scientific uncertainty and risk. Chapter 3 complies with the implementing regulations of the National Environmental Policy Act (NEPA) for analytic and concise environmental documents (40 CFR 1500-1508).

The scientific integrity of the discussions and analyses presented in this chapter are based on best available science, which includes discussion of the methodology used in the analysis; scientific sources that are relied upon and referenced; relevant literature that is reviewed; scientific literature that is cited by the public and which is considered when shown to be relevant; opposing views that are discussed when they are raised by the public or other agencies; and the disclosure of incomplete or unavailable information.

The current condition of each resource is described only to the extent needed to provide a baseline to compare the changes (direct, indirect and cumulative effects) that would occur under each alternative. Direct effects are caused by the action and occur at the same time and place. Indirect effects occur later in time as a result of the action, but are still reasonably foreseeable. Cumulative effects result from the incremental impact of an action when added to other past, present and ongoing, and reasonably foreseeable actions, regardless of what agency or person undertakes the action. Activities proposed under the alternatives are described in Chapter 2 of this document.

The methodology used to describe and predict effects (indicators and measures of change) is available in project record (i.e., specialists’ ancillary documentation (consistency with the standards, legal requirements or other policies), and other technical documentation). Spatial and temporal boundaries set the limits for selecting the actions most likely to contribute to cumulative effects (FSH 1909.15, 15.2). In addition, the applicable regulatory policies and guidance are discussed; the Forest Plan identifies standards designed to meet these regulations. Incomplete and/or unavailable information is identified where appropriate. If it is not identified, there is no incomplete or unavailable information for that particular resource.

3.1.1 Wilderness Resources

3.1.1.1 Wilderness Act of 1964

The Wilderness Act of 1964 mandates that “each agency administering any area designated as wilderness shall be responsible for preserving the wilderness character of the area (Section 4(b)).”

Section 2(c) of the Wilderness Act defines wilderness:

“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, where man himself is a visitor who does not remain. An area of wilderness is further defined to mean in this Act

an area of undeveloped Federal land retaining its primeval character and influence, without permanent improvements or human habitation, which is protected and managed so as to preserves its natural conditions and which (1) generally appears to have been affected primarily by the forces of nature, with the imprint of man’s work substantially unnoticeable; (2) has outstanding opportunities for solitude or a primitive and unconfined type of recreation; (3) has at least five thousand acres of land or is of sufficient size as to make practicable its preservation and use in an unimpaired condition; and (4) may also contain ecological, geological, or other features of scientific, educational, scenic, or historical value.”

The Wilderness Act identifies five qualities of wilderness. (Landres, et al, 2015) defined of these qualities as:  “Untrammeled” – wilderness is unhindered and free from modern human control or manipulation. This quality is degraded by modern human activities or actions that control or manipulate the components or processes of ecological systems inside the wilderness.  “Natural” – wilderness ecological systems are substantially free from the effects of modern civilization. According to ACNWTC (2016), preserving this quality ensures that indigenous species, patterns and ecological processes are protected and allows us to understand and learn from natural features.  “Undeveloped” – wilderness is substantially without permanent improvements or modern human occupation. This quality is degraded by the presence of structures, installations, habitations, and by the use of motor vehicles, motorized equipment, or mechanical transport that increases people’s ability to occupy or modify the environment.  “Outstanding opportunities” – wilderness provides opportunities for people to experience solitude or primitive and unconfined recreation, including the values of inspiration and physical and mental challenges. This quality is degraded by settings that reduce these opportunities, such as visitor encounters, signs of modern civilization, recreation facilities, and management restrictions on visitor behavior.  “Other features of value” - “may also contain ecological, geological, or other features of scientific, educational, scenic, or historical use.” Some of these features, such as the presence of threatened and endangered species, are also part of the natural quality of a wilderness. Other features, such as the presence of important geological formations, cultural resources, historical sites, or paleontological localities, may be significant or integral to the wilderness area and do not fit easily into one of the other four qualities of wilderness character.

Together, the five qualities of wilderness character are commonly used to assist wilderness managers with the management of wilderness. They mutually reinforce each other and together can comprise an approximation of wilderness character for the purposes of assisting monitoring and management efforts on these lands (Landres et al. 2008). All five qualities are equally important and none is held in higher or lower regard than the others.

In addition to the five qualities of wilderness character defined above, the Wilderness Act mentions societal benefits to wilderness that go beyond recreational use. These “non-use values” are, for the most part, not observable and marketable (Cordell et al. 2003). These values can include, but are not limited to: 1) the contributions of wilderness to individual and social well-being such as air and water quality; 2) cultural and historic preservation; 3) scenic beauty and immensity of an area; 4) opportunities for self- discovery, self-reliance, and challenge; 5) a sense of connection with nature and mental and spiritual restoration in the absence of urban pressures; 6) existence value – the satisfaction felt by knowing a wild place exists; and 7) bequest value – the value derived from being able to give wilderness to future

generations (ACNWTC Undated; Walsh et al. 1984; Cordell et al. 2003; Schuster et al. 2005; Landres et al. 2008).

Wilderness character may be either preserved or degraded by the actions or inactions of managers. The challenge of wilderness stewardship is that decisions and actions taken to protect one aspect of wilderness character may diminish another aspect (Landres et al. 2008). The Wilderness Act does not specify how to resolve potential conflicts between actions or between uses. Nor does the Wilderness Act address how to resolve conflicts between public or administrative uses of wilderness and the mandate to preserve wilderness character. We are to look at wilderness as a whole, “an enduring resource of wilderness” (Wilderness Act, Section 2(a)).

Section 4(b) of the Wilderness Act permits a number of specific uses in wilderness:

“Wilderness areas shall be devoted to the public purposes of recreational, scenic, scientific, educational, conservation, and historical use.”

Section 4(c) of the Wilderness Act prohibits certain uses and also allows exceptions to some of the prohibitions provided they are the minimum necessary to administer the area for the purposes of the Wilderness Act:

“Except as specifically provided for in this Act, and subject to existing private rights, there shall be no commercial enterprise and no permanent road within any wilderness area designated by this Act and except as necessary to meet minimum requirements for the administration of the area for the purpose of this Act (including measures required in emergencies involving the health and safety of persons within the area), there shall be no temporary road, no use of motor vehicles, motorized equipment or motorboats, no landing of aircraft, no other form of mechanical transport, and no structure or installation within any such area.”

3.1.1.2 Affected Environment

Approximately 52,000 acres of the three wilderness areas that are within the project area of this EA, offer extensive undeveloped natural environments and opportunities to experience varying qualities of wilderness character. The three wilderness areas are islands of primitive landscapes characterized by large cirque basins and exposed rocky ridges that are surrounded by built environment of civilization. Each wilderness is bounded on its northern and southern flanks by State and National Forest Scenic Byways and Backways whose designation benefit from the picturesque rugged terrain of high peaks and slopes in framed by a tapestry of mountain shrub, aspen and conifer forests. Their western slopes provide a spectacular backdrop to the growing urban areas of the Wasatch Front of both Salt Lake County and Utah County residences and businesses. Easterly views from the upper most spine of the these three wilderness areas overlook seven major ski areas, resort development and communities like Park City and the rural landscapes of Heber Valley. The recreational use of these wilderness areas is based in the complexity of the accent to their highest points, basins, lakes and waterfalls. Given the fact that the wildernesses are adjacent to private lands and urban development, the sights and sounds of humanity are easily visible and audible from many wilderness vantage points.

The southern end of the project area is Mount Timpanogos Wilderness and was designated by Congress in 1984 as part of the 1984 Wilderness Act. The Wilderness area consists of 10,527 acres located on the Uinta National Forest and is managed by Pleasant Grove Ranger District. Situated between Provo Canyon and American Fork Canyon with a summit of 11,753 feet which is the highest peak in the Southern Wasatch Mountain range. Mount Timpanogos Wilderness is rugged embellished by waterfalls, steep

topography descends towards the cliff shelf canyons and Utah Valley on the west and Heber Valley on the east. The headwaters for streams and rivers too many communities on both sides start in this wilderness. There are outstanding glacial cirques and moraines that are framed in blooming high alpine meadows. Below the tree line are forests of aspen, Douglas fir, subalpine fir, limber pine, Gambel oak, maple, and chokecherry. There is an abundance of wildlife, viewing mountain goat, bighorn sheep, elk, birds and other species is not unusual. The summit is accessed by trails from Timpooneke and Aspen Grove, which are very popular trailheads. There is high use on Saturdays and holidays where it is not uncommon to have over 2,000 hikers on these weekend from July through mid-September. There are no trails in the high mountain basins on the north, south and west faces of the wilderness.

In the mid portion of the project area is Lone Peak Wilderness. It covers 30,577 acre and was designated to be part of the National Wilderness Preservation System by United States Congress in 1978. The Lone Peak Wilderness area is divided between the Uinta and Wasatch National Forests and is managed by both the Pleasant Grove Ranger District on its south side and Salt Lake Ranger District on the north (Figure 1). Among the highest peaks are the Little Matterhorn at 11,326 feet and Lone Peak at 11,253 feet, where snow often can remain until midsummer. Much of the higher elevation is alpine, with large, open cirque basins and exposed rocky ridges. The region is geologically complex. You'll see sedimentary, metamorphic, and igneous rock formations in dramatic relief, as well as colorful bands stretching for great distances across mountainsides. A few small lakes add to the scenic beauty of the area. Douglas fir, subalpine fir, and aspen grow in isolated patches on north-facing slopes. Dense mountain brush and grass dominates the lower altitudes. State Highway Route 92 follows the American Fork Canyon and with the short stretch of State Highway Route 144, it forms the southern-southeastern boundary of the wilderness and provides access to trailheads and campgrounds. State Highway Route 210, along Little Cottonwood Creek Canyon, which also provides access, forms the northern boundary and separates Lone Peak Wilderness from Twin Peaks Wilderness just to the north. Several of the trails are easy to follow, but many require advanced navigation and route finding skills. Many people from the Salt Lake City area visit this wilderness area all year long. There are about six system trails totaling approximately 14 miles in the Lone Peak Wilderness area on the Salt Lake Ranger District side and eight system trails totaling approximately 32 miles on the Pleasant Grove Ranger District side.

Popular destinations in the Lone Peak Wilderness are Silver Lake in Utah County where weekends and holidays the parking lot at Silver Lake Flat is full and people expand the parking along FS road 08 to access Silver Lake that is in the wilderness (Butler, 2017). On the Salt Lake County side of the wilderness Red Pine Lake connects many visitors to Lone Peak’s high alpine environment. Red Pine Trail shares the first part of the trail with White Pine trail. The trailhead is full with as many as 200 vehicles parking down the highway. (Lane, 2017)

The Twin Peak Wilderness is at northern end of the three wildernesses. It was designated by Congress in 1984 as part of the 1984 Wilderness Act and consists of 11,432 acres. It is part of the dramatic backdrop of the southeast boarder of the Salt Lake Valley. Carved by glaciation and remodeled by erosion, this wilderness consists of narrow canyons and high peaks (including Twin Peaks, Superior Peak, and Dromedary Peak) that combine to form a rugged and spectacular imperious formation over the communities of Alta and Snowbird. Elevations range from just under 5,000 feet to 11,319 feet on Twin Peaks. Much of the higher terrain is classified as alpine and characterized by large cirque basins and exposed rocky ridges. Dense mountain brush mixed with oak/maple and grass dominates the vegetation at lower elevations. The canyons that are on both of the wilderness have streams that have cascades and pools that provide refreshment excellent scenic photo opportunities. Along the Scenic Byways recreationist can find trailheads that access the grandeur of the wilderness areas. Trails are often steep and

strenuous. Trails are limited as the Twin Peaks Wilderness has only five system trails totaling approximately ten miles. Crowds of people can be common on these trails, especially on weekends. Use is primarily day-use, although there is some overnight backpacking opportunities in the Lake Blanche area. The wilderness is within the Salt Lake City Watershed and has restrictions on dogs, horses and swimming.

Lake Blanche trail into the Twin Peaks Wilderness high use and high visitor encounters on weekends and holidays. While Broads Fork, Cardiff Pass and Ferguson trails have much less documented use and visitor encounters. (Lilly, 2016)

Wilderness Character Qualities are similar in all three wilderness areas.  Untrammeled – A number of trammeling actions have occurred and continue to occur in these wilderness areas. Due to the proximity of all three wildernesses to urban areas, natural fire is often suppressed. Additionally trails have been constructed and regulations put in place to manage visitor use. These are also trammeling actions as they manipulate and control. Despite these common trammeling actions, the untrammeled quality of these areas has remained relatively stable since their designation. Additional discussion of past actions is found the cumulative effects section. o Activities that took place before designation are not considered trammeling actions. . “Past actions that manipulated the biophysical environment before an area was designated as wilderness are not considered trammeling actions because the provisions of the 1964 Wilderness Act do not apply to an area prior to designation.” (Landres, et al., 2015)  Undeveloped – Infrastructure in these wilderness areas is mostly associated with visitor use. There are a number of heavily used trails as well as bridges and signs. Additionally helicopter flights are not uncommon and are utilized in emergency situations, most commonly for search and rescue operations. There is also some infrastructure that predates designation including structures associated with the Salt Lake City Watershed.  Natural – These three wilderness areas generally retain a similar degree of naturalness as they had at designation. Ecological processes continue to function and a wide range of habitats, flora and fauna exist these areas. Large ungulates such as bighorn sheep are an important component of naturalness. These native animals have been reintroduced and this may have improved naturalness. There is professional disagreement on whether or not mountain goats are native to these wilderness areas, but they are native to the Northern Rocky Mountains. For the sake of this analysis they will be considered as part of the natural quality of wilderness character. Heavy visitor use in some areas may be causing minor localized changes to naturalness, but over all there is no measurable change since designation.  Opportunities for Solitude or Primitive and Unconfined Recreation o Solitude – Remoteness from the sights and sounds of human activity along high use trails during some weekdays and almost all weekends and holiday during the summer season is limited. Off and away from these main trails, visitors (Feldhamer, George, Thompson, Bruce, Chapman, Joseph, 2003) can find areas of solitude. Visitor use has increased over the years, but most is along trails and opportunities for solitude still exist in many areas of these wildernesses. o Primitive or unconfined recreation – Facilities that decrease self-reliant recreation are associated with the high use trails in these wilderness, such as bridges and trail mitigation structures to reduce erosion. Regulations are in effect to limit group size, camping, stock

and dogs (in the Salt Lake City Watershed). Opportunities continue to be available however for primitive recreation.

Other Features of Value – This quality typically refers to something specifically referred to in legislation or something unique or of high value that is not covered by the other qualities of wilderness character. While these wilderness areas provide spectacular scenery, glacial geology, mountain lakes and a variety of alpine and sub-alpine settings, nothing has been identified as a feature of value for these wilderness areas as pertains to this project.

3.1.1.3 Environmental Consequences In considering effects to Wilderness Resources, a qualitative discussion of how each alternative could affect the qualities of wilderness character (untrammeled, undeveloped, natural, outstanding opportunities for solitude or primitive and unconfined recreation) is the basis for analysis. Likely intensity and duration of effects is considered.

Alternative A – No Action  Untrammeled – there would be no direct or indirect effects from the no action alternative. There is no attempt to intentionally manipulate the biophysical environment in any of the three wilderness areas.  Undeveloped – Because there is no use of motor vehicles, motorized equipment, mechanical transport or any installation, there would be no direct or indirect effect to the undeveloped quality of wilderness character.  Natural – There could be long term indirect effects from the no action alternative. If no action is taken, there is legitimate concern that these species populations will continue to decline and this important aspect of the natural quality of wilderness could be impacted. The population of the bighorn sheep within the three wilderness areas may continue to be stagnant over time or could go into a downward trend because of disease spread through interaction with domestic animals outside the three wilderness areas. The possible transmission of disease to bighorn sheep and mountain goats inside the wilderness areas from those bighorn sheep that have interacted with domestic animals is the primary concern and a likely cause of the underperformance of bighorn sheep and mountain goats in the Wasatch. Whether or not the underperformance of these herds is a natural process or if it is being caused by disease from domestic livestock or something else would not be understood if no action is taken. Effects to natural quality could range from minor to catastrophic (loss of one or both of the herds) if no action is taken. Because other herds in nearby areas have been significantly affected by disease from domestic livestock, including the near loss of the entire herd in the Deseret Peak Wilderness, the no action could affect the natural quality significantly and for a long duration.  Opportunities for solitude and primitive or unconfined recreation – The no action would have no direct or indirect effect to this quality. There would be no change in visitor use management or any aspect of wilderness management that would affect opportunities for solitude and primitive or unconfined recreation.

Alternative B - Proposed Action  Untrammeled – Animals would be captured by shooting a net from helicopter and then personal would secure the net. This is a very clear trammeling action as human intervention occurs to capture and manipulate the animals. Intensity and duration of the effect is not known as pertains to each specific animal, but 20 mountain goats and ten bighorn sheep would be captured. The

actual trammeling action is high intensity, of short duration and likely has no lasting effects. Taking a blood sample for study from the captured animals would be an additional trammeling action. This is a clear human manipulation, but the trammeling effect, though high intensity, is short term and with no lasting effects. Twenty mountain goats and ten bighorn sheep would be fitted with radio collars to track their movement and interactions. This is also a clear trammeling action as it is an attempt to control nature and is human interference in the normal lifecycle of the animals. The action is high intensity and because the goats are collared for their lifetime it would have moderate duration. The effect to untrammeled quality would not be permanent as collars are removed once mortality occurs.  Undeveloped – Personnel would be transferred using a Helicopter. There is an estimated 60 landings over two to four days which may not be consecutive days. The presence of a helicopter is a relatively intense effect to undeveloped quality, though the duration is short and not permanent. GPS radio collars would be in place on each animal for the life time of the animal. This is considered an installation and the effect is likely low intensity with moderate duration.  Natural – Nets are shot from helicopter and animals are secured for health check, blood draw and collaring. This could have negative effects to natural quality if animals are injured or killed. In similar activities approximately three percent of captured animals are injured and some injuries lead to mortality. Though specific animals could be injured or killed, the effect to natural quality is high intensity, but short duration with no lasting effects. Drawing blood samples would provide UDWR the opportunity to understand what is causing poor heard performance. This is potentially very important information for preservation of both species in the wilderness areas. Understanding if this is a natural process or if disease from domestic livestock or something else is causing the poor herd performance, would inform future management actions and potentially have long term positive effects to the natural quality of wilderness character. Similarly, collaring would allow UDWR to track movements and interactions of these species which would help inform the understanding of the potential for spread of disease within and between species. Positive effects to natural quality could range from minimal to substantial and long lasting.  Solitude or Primitive and Unconfined Recreation – The sights and sounds of up to 60 helicopter landings would have a negative effect to solitude. Wilderness visitors would likely notice the helicopters and this can intrude on their wilderness experience. Because activity is planned for the fall when there is less recreation, this effect is reduced but still exists. The negative effect would likely be moderate to intense, of short duration, and no lasting effect. In addition to the presence and landing of helicopters, the net gunning and capture of animals has a potential negative effect to solitude if observed by wilderness visitors. The sights and sounds of the actual operation of netting, capturing and processing the animals could be very intense, though the effect would be of short duration.

3.1.1.5 Cumulative Effects

To analyze cumulative effects to wilderness character related to this project, similar past management actions are considered. It is evident from news reports and Forest Service records that helicopters are used each year in response to emergencies in each of the three wilderness areas. Results of web searches using “helicopter rescue” and the name of each wilderness indicate there were numerous articles regarding the use of helicopters in the three wilderness areas for emergency purposes. Approximately four to five flights occur in wilderness each year as a result of search and rescue operations with one to two of those actually touching down on the ground. Forest Service wilderness program records indicate 26 reported

search and rescue actions using helicopters over the last ten years. It is reasonable to expect based on the past and present actions, helicopter use for search and rescue operations would continue into the reasonably foreseeable future. Additionally helicopters and aircraft are periodically used in fire suppression efforts. Wilderness program records indicate helicopter use was approved and used for 4 fires over the last ten years. Additionally these records indicate motorized use was authorized for a dam stabilization project, flood repairs, and fish stocking. The proposed action of an estimated 60 helicopter landings over a two to four day time period would have a minimal cumulative effect when combined with the ongoing emergency and authorized use of helicopters. These past, present and future helicopter landings have an ongoing negative effect to the undeveloped quality of wilderness character, but this effect is not permanent and does not leave a lasting impression on the landscape.

Chapter 4: Consultation and Coordination

4.1 Preparers and Contributors Table 3: Forest Service Interdisciplinary Team Name/ Area of Expertise Resource Area Pamela Manders Interdisciplinary Team (IDT) Leader and Wildlife Fish and Wildlife Program Manager Lee Rackham Aviation Aviation Manager Jana Leinbach Botany/Noxious Weeds Botanist Tom Flanigan Cultural Resources Archeologist Renee Flanagan Engineering Engineer Guy Wilson Fuels Fuels Specialist Darcy Stock GIS GIS Coordinator Elisha Hornung NEPA NEPA Planner Renae Bragonje Range Range Conservationist Dave Hatch/Landscape Architect Recreation/Wilderness Daniel Morris/Wilderness Specialist Paul Gauchay Safety Safety Officer Stacey Weems Soils Soil Scientist Brendon Waterman Watershed Hydrologist

4.2 Consultation and Coordination

An invitation to provide scoping/comments was sent to the district mailing lists for the Salt Lake and Pleasant Grove Ranger districts. These lists include federal, state, local and tribal governments. These same groups will be notified that the EA is available for review.

4.3 Laws and Regulations

American Indian Religious Freedom Act, Executive Order 12875, Executive Order 13007, Executive Order 13175, and Native American Graves Protection and Repatriation Act

The American Indian Religious Freedom Act, Public Law No. 95-341, 92 Stat. 469 (Aug. 11, 1978) (commonly abbreviated to AIRFA), is a United States federal law and a joint resolution of Congress that was passed in 1978. AIRFA was enacted to protect and preserve the traditional religious rights and cultural practices of American Indians, Eskimos, Aleuts, and native Hawaiians. Executive Order 13175 established a requirement for regular and meaningful consultation between federal and tribal government

officials on federal policies that have tribal implications. Executive Order 12785 was enacted in order to reduce unfunded mandates upon State, local, and tribal governments; to streamline the application process for and increase the availability of waivers to State, local, and tribal governments; and to establish regular and meaningful consultation and collaboration with State, local, and tribal governments on Federal matters that significantly or uniquely affect their communities. Executive Order 13007 was enacted in order to protect and preserve Indian religious practices. The Native American Graves Protection and Repatriation Act provides a process for museums and Federal agencies to return certain Native American cultural items, such as human remains, funerary objects, sacred objects, or objects of cultural patrimony, to lineal descendants, and culturally affiliated Indian tribes and Native Hawaiian organizations.

Clean Air Act, as amended in 1990

The purpose of this Act is “…to protect and enhance the quality of the Nation’s air resources so as to promote the public health and welfare and the productive capacity of its population; to initiate and accelerate a national research and development program to achieve the prevention and control of air pollution; to provide technical and financial assistance to State and local governments in connection with the development and execution of their air pollution prevention and control programs; and to encourage and assist the development and operation of regional air pollution prevention and control programs.”

While the proposed action would increase particulates helicopter emissions in the area, it would not have measurable impacts on air quality in any Class I or II areas identified above or at monitoring sites, given the distance and dilution that would occur as particles and air mix over distance.

Clean Water Act, The Federal Water Pollution Control Act of 1972 (PL 92-500) as amended in 1977 (PL 95-217) and 1987 (PL 100-4)

The objective of the Federal Water Pollution Control Act, commonly referred to as the Clean Water Act (CWA), is to restore and maintain the chemical, physical, and biological integrity of the nation's waters by preventing point and nonpoint pollution sources. This Act establishes a non-degradation policy for all federally proposed projects to be accomplished through planning, application, and monitoring of Best Management Practices (BMPs). Identification of BMPs is mandated by Section 319 of the Water Quality Act of 1987 (also referred to as the Clean Water Act), which states, “It is national policy that programs for the control of nonpoint sources of pollution be developed and implemented.” As described in Section 3.1.1, this project would have little or no potential to impact water resources.

Endangered American Wilderness Act 1978 - Public law 95-237 (2/24/1978)

To designate certain endangered public lands for preservation as wilderness, and for other purposes.

This public law also includes the following wilderness area(s): Chama River Canyon Wilderness, Golden Trout Wilderness, Gospel-Hump Wilderness, Hunter-Fryingpan Wilderness, Kalmiopsis Wilderness, Lone Peak Wilderness, Manzano Mountain Wilderness, Mount Hood Wilderness, Pusch Ridge Wilderness, Sandia Mountain Wilderness, Santa Lucia Wilderness, Savage Run Wilderness, Three Sisters Wilderness, Ventana Wilderness, Welcome Creek Wilderness, Wenaha-Tucannon Wilderness, and Wild Rogue Wilderness.

Endangered Species Act (ESA, 16 USC 35 §§1531 et seq. 1988)

The Endangered Species Act provides for the protection and conservation of threatened and endangered plants and animal species. All alternatives were assessed to determine their effects on threatened and

endangered plant and animal species. The U.S. Fish and Wildlife Service (USFWS) provides a list of threatened, endangered, proposed, and candidate species to consider in project planning. The current list identifies threatened species as western yellow-billed cuckoo and Canada lynx, Ute ladies’ tresses, and Jones cycladenia (USFWS 2017). Additional information on effect determinations can be found in the wildlife and botany specialist reports in the project record.

Environmental Justice (E.O. 12898)

Executive Order 12898 (59 Fed. Register 7629, 1994) directs federal agencies to identify and address, as appropriate, any disproportionately high and adverse human health or environmental effects on minority populations and low-income populations. Based upon the analysis disclosed in the project record, the project is in compliance with Executive Order 12898.

Invasive Species (E.O. 13112)

Executive Order 13112 on Invasive Species directs that federal agencies should not authorize any activities that would increase the spread of invasive species. This project includes design features and mitigation measures to limit the spread of invasive species (Appendix C) and incorporates those applicable Uinta and Wasatch-Cache Forest Standards and Guidelines (USDA 2003a Uinta 2003b).

Migratory Bird Treaty Act

The Migratory Bird Treaty Act decreed that all migratory birds and their parts (including eggs, nests, and feathers) were fully protected. Under the Act, taking, killing, or possessing migratory birds is unlawful. The original intent was to put an end to the commercial trade of birds and their feathers that had wreaked havoc on the populations of many native bird species. On January 17, 2001, President William Clinton signed an executive order directing executive departments and agencies to take certain actions to further implement the Migratory Bird Treaty Act (FR Vol. 66, No.11, January 17, 2001).

Migratory birds occupy all source habitats found in the analysis area. If new requirements or direction result from subsequent interagency memorandums of understanding pursuant to Executive Order 13186, this project would be reevaluated to ensure that it is consistent.

Migratory birds as a group encompass a broad array of avian taxa, including, but not limited to, the following:

The mechanism of effect on birds is the auditory and visual disturbance created by helicopter landings and the activity on the ground that would take place when mountain goat and bighorn sheep are collared. There should be no impact to birds during the breeding season when displacing tending adults from a nest containing eggs or young could reduce the chance of reproductive success via exposure to predation or the elements. Consequently, the project would result in no adverse impacts to migratory birds resulting from the proposed action.

The proposed action would not result in ‘take’ of any migratory birds.

National Forest Management Act (NFMA)

The NFMA guides development and revision of National Forest Land Management Plans and contains regulations that prescribe how land and resource management planning is to be conducted on Forest Service lands to protect National Forest resources. The different alternatives for this project were developed to comply with NFMA and represent varying degrees of resource protection.

National Historic Preservation Act

The National Historic Preservation Act (NHPA) of 1966 is the principle guiding statute for the management of cultural resources on Forest Service lands. Section 106 of NHPA requires federal agencies to consider the effects of their activities and programs on historic properties. Historic Properties are any prehistoric or historic district, site, building, structure, or object included or eligible for inclusion, in the National Register of Historic Places maintained in the Secretary of the Interior. This term includes artifacts, records, and remains that are related to and located within such properties. The term includes properties of traditional religious and cultural importance to an Indian tribe or Native Hawaiian organization and that meet the National Register criteria. [36cfr800.16 (l)(1)]. The criteria for National Register eligibility and procedures for implementing Section 106 of NHPA are outlined in the U.S. Code of Federal Regulations (36 CFR Parts 60 and 800), respective.

Utah Wilderness Act of 1984 - Public law 98-428 (9/28/1984)

To designate certain national forest system lands in the state of Utah for inclusion in the National Wilderness Preservation System to release other forest lands for multiple use management, and for other purposes. This public law also includes the following wilderness area(s): Ashdown Gorge Wilderness, Box-Death Hollow Wilderness, Dark Canyon Wilderness, Deseret Peak Wilderness, High Uintas Wilderness, Mount Naomi Wilderness, Mount Olympus Wilderness, Mount Timpanogos Wilderness, Pine Valley Mountain Wilderness, Twin Peaks Wilderness, and Wellsville Mountain Wilderness.

Wilderness Act of 1964, Endangered American Wilderness Act of 1978 and Utah Wilderness Act of 1984

The Wilderness Act of 1964 (Public Law 88-577; 16 U.S.C. 1131) (amended in 1978) was enacted by Congress to “secure for the American people, an enduring resource of wilderness for the enjoyment of present and future generations”. This act was passed “in order to ensure that an increasing population, accompanied by expanding settlement and growing mechanization, does not occupy and modify all areas within the United States and its possessions, leaving no lands designated for preservation and protection in their natural condition...”(Section 2 [a]). The Wilderness Act contains provisions for conducting operations to meet the minimum requirements for administration that include: “Except as specifically provided for in this Act, and subject to existing private rights, there shall be no commercial enterprise and no permanent road within any wilderness area designated by this Act and except as necessary to meet minimum requirements for the administration of the area for the purpose of this Act (including measures required in emergencies involving the health and safety of persons within the area), there shall be no temporary road, no use of motor vehicles, motorized equipment or motorboats, no landing of aircraft, no other form of mechanical transport, and no structure or installation within any such area” (Section 4 [c]). Additional provisions in the Act and effects are described in the Wilderness Resources section, Chapter 3.

Appendix A: Scoping Report

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

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

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: comments-intermtn-wasatch-cache- [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: comments- [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

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.

Table A-1 Summary of scoping comments received and responses Scoping Number First Last Name Organization Comment Resource Response Period Name Category 2016 001 Adam Bronson Utah Due to the nature of mountain General support Thank you for your Foundation goats and the rugged country comment. You have for North they inhabit, helicopter captures been added to the American are about the only way to get mailing list for the Wild Sheep goats in hand across a random project. 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 all bighorn sheep and mountain

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 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.

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 2016 002 Bill King Utah Native UNPS has been tracking rare Botany We appreciate the Plant Society plant species in the Wasatch concern over narrow Mountains for many years and endemic plants and recently have published the potential of Calochortiana Number 3, landing a helicopter February, 2016, which details in the general our findings. We believe that the proximity of one or following high priority rare more of these plants. species could fall into the An environmental helicopter goat capture project assessment has been area and could be negatively prepared to address impacted: Crepis runcinata ssp. potential impacts. Runcinata (Meadow We have had our hawksbeard), Erigeron botanist review your goodrichii (Goodrich's concerns in regards fleabane), Boechera harrsonii to this project. They (Harrison's rockcress), Boechera have analyzed the lasiocarpa (Wasatch rockcress), potential impacts to Lepidium montanum var. vegetation and these alpinum (Wasatch pepperwort), have been address in Corydalis caseana var the environmental brachycarpa (Case's corydalis), assessment which Jamesia americana var. includes mitigation macrocalyx (Wasatch jamesia), measures. 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 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 General support Thank you for your goat population was declining in comment. 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 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 General opposition Thank you for your to the proposal from the Utah comment. All DWR to land helicopters in alternatives being Wilderness areas for the purpose analyzed will meet of studying mountain goat the Forest Service populations. The goats are not a legal requirements. native species, and the DWR's The analysis ultimate purpose is to increase provides a review of the number of goats available to what is known of be shot by hunters. This is not a the mountain goat sufficient reason to violate the population on the Wilderness Act, which the Wasatch Front. The Forest Service is legally native status of obligated to uphold. 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 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 General opposition See response to 004. 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 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 Wildlife - status of Thank you for your opposed to using helicopters in species comment. designated wilderness areas for collaring mountain goats. I think this is very inappropriate. The goats don't belong there in the first place. 2016 008 Paul Diegel I am writing to express my Wilderness Act Both bighorn sheep strong opposition to the proposal and mountain goat to grant special permission to are be studied as use helicopters in the Wasatch part of the proposed Wilderness Areas for purposes action. See the of studying Mountain Goats. purpose and need The State and the Forest Service for the project and have not provided compelling response to 004. 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 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 Wilderness Act See response to 004 to the Wasatch Mountains! and 008. 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 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 General support - Thank you for your UDWR in these studies and I request for info comment. 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.

Scoping Number First Last Name Organization Comment Resource Response Period Name Category

Please confirm receipt of this email.

2016 011 Kristen Shelley I would like to object to the Wilderness Act Helicopters have proposal for helicopters going been used to assist into the 3 Wilderness areas to in human rescue tag mountain goats. I know the efforts in the goat population has diminished wilderness. Thank but there is no reason for the you for your government to have an comment. 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.

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 2016 012 Kristen Shelley The Mountain Goat study into Wilderness Act Please see the Wilderness areas via helicopter purpose and need is a ridiculous idea. We agree for the project for a that the goats are disappearing, description of the but they have most likely moved issues being South into the Nebo areas. What addressed. See will you do once you find out response to that they are gone, just as you comment 004. A thought? The Wilderness ground only designation is not just there to alternative is be turned over when a discussed in the government employee is too "Alternatives lazy to hike or ride a horse up to Considered but where you need to be to study Eliminated" section the goats. Just get up there like of the EA. 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.

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 2016 013 Bob Brister I am writing to comment on the Wilderness Act The use of proposal to land helicopters in mechanized the Twin Peaks, Lone Peak, and equipment in a Mount Timpanogos wilderness designated Forest areas to capture and collar Service managed mountain goats. Isn't the use of wilderness area can mechanical objects in designated occur but should be wilderness against the law? analyzed and approved by the Forest Service. 2016 014 Richard Steiner Do not allow helicopters in the Wilderness Act See response to wilderness. This is against comments 004 and regulations and opens a slippery 013. 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. 2016 015 Jay Griffith It has come to my attention that Wilderness Act Please see the the Utah DWR is requesting purpose and need permission to fly and land for the project for a helicopters into wilderness area description of the to study mountain goat issues being populations. That is unlawful addressed. See and inappropriate for wilderness response to area. We go to these quiet and comment 004. A beautiful places because they are ground only quiet and beautiful. Please find a alternative is different method (like horseback discussed in the if necessary) to reach the locals. "Alternatives Considered but Eliminated" section of the EA.

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 2016 016 Richard Middleton I believe that you should deny Wildlife - status of Thank you for your UDWR's application to land species comment. The helicopters in the Twin Peaks, evaluation of other Lone Peak and Timpanogos potentially Wilderness areas to study detrimental impacts mountain goats. to mountain goat First, it is debatable whether populations is mountain goats belong in these outside of the scope areas at all, since they were of this analysis. A introduced by UDWR. Second, ground only if there has been a decline in the alternative is herd from previous peak levels, discussed in the this may be natural fluctuation "Alternatives (or a natural corrective response Considered but to being introduced to the wrong Eliminated" section place). Third, there are plenty of the EA. See of stressors in this environment response to which could account for the comments 004 and drop in numbers, for example: 013. 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 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 General support Thank you for your inside the 3 wilderness areas to comment. Please take a survey of Mtn. Goats, I contact UDWR to have no objections. Only the request the results of most radical of their work. 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.

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 2016 018 Nate Jones I have to say that I love General opposition Thank you for your Mountain Goats and love seeing comment. 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. 2016 019 Eric Sadler Wasatch Will McCarvill was kind enough Request for Info You have been Mountain to forward this to me. I am the added to the mailing Club Conservation Director for the list for this project. Wasatch Mountain Club. Please add me to the distribution list for this correspondence. 2016 020 Kathleen Rice I have learned that the Utah Wildlife Thank you for your Division of Wildlife Resources comment. 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 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 General support Thank you for your the 4 times I've guided on Mt. comment. 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]

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 2016 022 Troy Justensen Sportsmen I am writing this letter on behalf General support Thank you for your for Fish and of 7,200 members of our comment. Wildlife 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 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 Western This letter is to inform you that General opposition, The Wilderness (multiple) Wildlife the not-for-profit conservation wilderness values, with regards Conservancy organizations listed at the end character to the various of this letter are opposed to the alternatives, were Utah Division of Wildlife evaluated in the Resources' proposal that the Minimum Forest Service allow the agency Requirements (UDWR) to employ helicopter Analysis (MRA) landings in Wasatch Mountain and are reflected in wilderness areas in order to the NEPA analysis. 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 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. 2016 023.2 Kirk Robinson Western 1) The pending case from Idaho, Timing of analysis A decision has been (multiple) Wildlife Wilderness Watch y. Vilsack. issued on the case. Conservancy addresses nearly the same issue Thank you for your as raised by UDWR's proposal comment. See to use helicopter landings to response to collar mountain goats in comment 004. 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category (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. 2016 023.3 Kirk Robinson Western 2) The Wilderness Act expressly Wilderness Act The Wilderness (multiple) Wildlife prohibits any "landing of values, with regards Conservancy aircraft" and any "installation" to the various within designated wilderness alternatives, were "except as necessary to meet evaluated in the minimum requirements for the Minimum administration of the area" as Requirements wilderness. 16 U.S.C. § 1133(c). Analysis (MRA) Radio telemetry collars on and are reflected in wildlife constitute "installations" the NEPA analysis. that are generally prohibited by See the purpose and the Wilderness Act. Thus, in need description in order to avoid violating the the EA. 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category administering the Twin Peaks, Lone Peak, and the Mount Timpanogos wildernesses so as to preserve or enhance their wilderness character?

2016 023.4 Kirk Robinson Western 3) Why is this specific project, Alternatives, A Minimum (multiple) Wildlife which will involve helicopter request for MRDG Requirements Conservancy landings in wilderness and Analysis (MRA) has collaring of mountain goats, been developed for necessary for obtaining the this project. A desired information about the ground only mountain goats? Are there alternative is alternative ways in which discussed in the UDWR can acquire the "Alternatives information it seeks that isn't a Considered but prima facie violation of the Eliminated" section Wilderness Act triggering the of the EA. An "minimum requirements" evaluation of exception? To meet minimum hunting is outside needs for protection and the scope of this administration of the area as analysis. 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category a copy of the MRA or MRDG document.

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 2016 023.5 Kirk Robinson Western 4) UDWR states in its Wilderness See the purpose and (multiple) Wildlife management plan for Rocky character need and response to Conservancy Mountain goats, "This will comment 004. 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 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").

2016 023.6 Kirk Robinson Western 5) What type of collars will be Request for project The collars being (multiple) Wildlife used - radio collars or satellite detail used are satellite Conservancy collars? collars that are 6) Will UDWR request future tracked with satellite helicopter landings to replace signals transferred collars? In other words, is this through the internet. likely part of an ongoing This may reduce the project? number of 7) Will there be ongoing overflights required flyovers to gather information to manage these from the collars once the goats populations. Hike in have been collared? crews would be used to retrieve these collars is an animal dies or when the collar drops off.

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 2016 023.7 Kirk Robinson Western 8) The reintroduction of wildlife Wildlife - status of See the discussion in (multiple) Wildlife species is permitted only if the species existing condition Conservancy species was once indigenous to for wildlife and an area and was extirpated by response to human-induced events. comment 004. 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.) 2016 023.8 Kirk Robinson Western 9) The Forest Service must also Analysis and An environmental (multiple) Wildlife complete an appropriate alternatives assessment has been Conservancy National Environmental Policy prepared to address Act ("NEPA") analysis for the potential impacts project addressing the above and will be made concerns, fully analyzing direct, available for public indirect and cumulative impacts review and as well as a reasonable range of comment. A range alternatives that may avoid or of alternatives was

Scoping Number First Last Name Organization Comment Resource Response Period Name Category lessen adverse impacts. The analyzed in the EA Environmental Impact including Statement is NEPA's core "Alternatives requirement. Does the Forest Considered but Service intend to do an EIS on Eliminated from this project with further public Detailed Analysis." input? If not, will there be an Regulating harvest opportunity to comment on the is outside the EA? Will the Forest Service authority of the consider options such as no Forest Service. 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? 2016 024 Andy White I have, for years enjoyed the General opposition A ground only sightings and occasional alternative is companionship of our local discussed in the mountain goats on my forays "Alternatives into the wasatch and though the Considered but health of that environment due Eliminated" section to their presence has, for some of the EA. 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 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 General support - Thank you for your goat population was declining in request for info comment. 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.

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 2016 026 Erme Catino I'm opposed to the following Wilderness Act Thank you for your proposal given the following. As comment. All defined by the Wilderness Act alternatives being of 1964, wilderness areas do not analyzed will meet allow motorized equipment and the Forest Service provide opportunities for legal requirements. solitude. The Utah Division of The analysis Wildlife Resources (UDWR) provides a review of has released a proposal to land what is known of helicopters in the Twin Peaks, the mountain goat Lone Peak, and Timpanogos population on the Wilderness areas for the purpose Wasatch Front. of studying what they say is a Hunting issues are significant decline in mountain outside the scope of goat populations since 1999. this project. 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.

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 2016 027 Carlton DeTar and We are writing to urge you to Wilderness Act See responses to Laurel deny the request by Utah comments 004 and Casjens Division of Wildlife Resources comment 013. 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. 2016 028 Brad Clinch I write in support of the letter Wilderness Act Thank you for your from Save Our Canyons and comment. 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 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 General opposition Thank you for your landing helicopters in the comment. Wilderness. I’m all about doing studies and research but the helicopter is unnecessary. SO I say no go. 2016 030 Creighton Hart No comments included or attached to email. 2016 031 Suzie Ellison UDRW should adhere to the General opposition A ground only rules of wilderness areas! Send alternative is researchers in on foot. Please Do discussed in the not disturb our precious few "Alternatives areas in the wasatch wilderness Considered but with helicopters. Eliminated" section of the EA. 2016 032 Mark Lusch If someone wants to study General opposition A ground only mountain goats, fine. Let them alternative is walk up the mountain or ride a discussed in the horse and they can study all they "Alternatives want. No helicopters. That's Considered but cheating. It's a wilderness. Eliminated" section of the EA.

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 2016 033 Earle Bevins The request by the UDWR to Wilderness Act Thank you for your helicopter into the Wilderness comment. See areas of the Wasatch range response to should be denied. The comment 013. All Wilderness Act of 1964 clearly alternatives being prohibits motorized equipment analyzed will meet in areas designated as the Forest Service Wilderness. For the UDWR to legal requirements. request a waiver to study what is The analysis happening to what may be a non provides a review of native mammal the introduction what is known of of which has harmed rare and the mountain goat sensitive vegetation is simply population on the wrong. UDWR should have Wasatch Front. developed a plan to monitor the Hunting issues are goats consistent with the outside the scope of limitation of the Wilderness Act this analysis. 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.

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 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 Wilderness Act See response to exception to the wilderness comment 013. 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.

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 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.

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 2017 035 Kirk Robinson Western The proposed action is for the Wilderness Act Please see the (multiple) Wildlife Utah Division of Wildlife purpose and need Conservancy Resources (UDWR) to make up for the project for a (Wildlands to 60 helicopter landings in three description of the Network, Wasatch Mountain wilderness issues being Wild Utah areas in the fall of 2017 in order addressed. See Project, Save to capture and collar response to our Canyons, approximately 20 Rocky comment 004. A Sierra Club, Mountain goats (Oreamnos ground only Yellowstone americanus) and approximately alternative is to Uintas 10 Rocky Mountain bighorn discussed in the connection, sheep (Ovis Canadensis), and to "Alternatives Voices of take tissue samples from them. Considered but Wildlife, The wilderness areas where Eliminated" section Wilderness helicopter landings would take of the EA. Watch) 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category acquire will better enable them to manage both species in the wildernesses and surrounding habitats of the Wasatch Mountains.

2017 035.1 Kirk Robinson Western The Wilderness Act of 1964, as Wilderness Act See response to (multiple) Wildlife amended, is the governing comment 013. Conservancy document pertaining to (Multiple) 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category wilderness would also violate the prohibition because they are considered installations.

2017 035.2 Kirk Robinson Western The U.S. Forest Service is the USFS Decision Thank you for your (multiple) Wildlife managing agency in this case. comment. A Conservancy Thus, the Forest Service (FS) Minimum (Multiple) must determine whether the Requirements proposed action is "necessary to Analysis (MRA) has meet minimum requirements" been developed for for the administration of the this project. 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.

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 2017 035.3 Kirk Robinson Western The following passage is from Wilderness Act Thank you for your (multiple) Wildlife Wolf Recovery Foundation v. (Idaho Court Case) comment. Conservancy United States Forest Service, (Multiple) (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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 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).' 2017 035.4 Kirk Robinson Western In Wolf Recovery Foundation v. Wilderness Act Thank you for your (multiple) Wildlife U.S. Forest Service, from which (Idaho Court Case) comment. Conservancy the above passage is excerpted, (Multiple) 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category and collar gray wolves (Canes 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) 2017 035.5 Kirk Robinson Western So, the question in this case is Wilderness Act Thank you for your (multiple) Wildlife whether the value of the (Idaho Court Case) comment. Conservancy research that UDWR proposes (Multiple) 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.

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 2017 035.6 Kirk Robinson Western In this connection, we must be Wilderness Act Thank you for your (multiple) Wildlife careful to distinguish the wolf (Idaho Court Case) comment. Conservancy collaring project from other (Multiple) 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.' 2017 035.7 Kirk Robinson Western We have concerns regarding the Wilderness Thank you for your (multiple) Wildlife proposition that the proposed character comment. Please see Conservancy project would be of unique value the purpose and (Multiple) for enabling the FS to better need for the project manage the wilderness areas in for a description of question for their wilderness the issues being character. We do not see how addressed. An this might be so. We do not see environmental how the proposal is more like assessment has been wolf collaring than like dam prepared to address

Scoping Number First Last Name Organization Comment Resource Response Period Name Category building for the purpose of potential impacts enhancing recreational fishing. and will be made Indeed, it seems to us that the available for public opposite is true. Therefore, we review and believe the challenge for the FS, comment. A range before permitting the proposed of alternatives was project, is to make a sufficiently analyzed in the EA strong case that the reverse of including what we believe is actually true. "Alternatives Considered but Eliminated from Detailed Analysis." 2017 035.8 Kirk Robinson Western In this connection, we note that Wilderness Thank you for your (multiple) Wildlife the missions of the two agencies character comment. An Conservancy (FS and UDWR respectively) environmental (Multiple) are quite different. The mission assessment has been of UDWR is to manage the two prepared to address species of ungulates that it potential impacts wishes to study (Rocky and will be made Mountain goats and sheep), available for public while the mission of the FS is to review and manage the wilderness areas comment. A range where these species reside to of alternatives was preserve or enhance their analyzed in the EA wilderness character. Thus, the including FS must articulate a plausible "Alternatives explanation for how data or Considered but information that can be expected Eliminated from to be obtained from the project, Detailed Analysis." concerning animal movements The analysis and diseases, will enable it to provides a review of better manage the three what is known of wilderness areas to preserve or the mountain goat and bighorn sheep

Scoping Number First Last Name Organization Comment Resource Response Period Name Category enhance their wilderness population on the character. Wasatch Front.

2017 035.9 Kirk Robinson Western It is an important fact that in Wildlife Thank you for your (multiple) Wildlife Wolf Recovery Foundation v. management for comment. The Conservancy United States Forest Service, the wilderness analysis provides a (Multiple) proposal was to land helicopters character review of what is in a wilderness in order to collar known of the wolves. The gray wolf was mountain goat and native to that ecosystem, though bighorn sheep it had been missing for many population on the decades, and its return via Wasatch Front. The reintroduction plus the EA addresses the subsequent rapid growth of the effects to wolf population, represented the wilderness. See return of an important apex response to predator to a system of which it comment 004. 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 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?

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 2017 035.10 Kirk Robinson Western The management goal of Hunting and Thank you for your (multiple) Wildlife UDWR with respect to both viewing comment. All Conservancy Rocky Mountain Bighorn Sheep opportunities alternatives being (Multiple) and Rocky Mountain goats is to analyzed will meet provide (1) hunting the Forest Service opportunities for hunters and (2) legal requirements. wildlife viewing opportunities The analysis for people who visit the provides a review of wilderness areas and who enjoy what is known of observing these animals in the the mountain goat wild. This is explicitly stated in and bighorn sheep the management plans for both population on the species. For example, UDWR's Wasatch Front. An statewide management plan for evaluation of Rocky Mountain bighorn sheep hunting is outside states: the scope of this Objective 1: Increase bighorn analysis. 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 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.

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 2017 035.11 Kirk Robinson Western This introduces the question of Wilderness Thank you for your (multiple) Wildlife how working to achieve these character comment. All Conservancy objectives is necessary to help alternatives being (Multiple) the FS manage the wildernesses analyzed will meet for wilderness character. So far the Forest Service as we can see, hunting goats and legal requirements. sheep has nothing at all to do The analysis with managing wilderness areas provides a review of for wilderness character - what is known of especially so long as there are the mountain goat predators to eliminate the and bighorn sheep weaker and non-reproductive population on the members of herds, which itself Wasatch Front. An is a natural part of what goes on evaluation of in wilderness and which hunting is outside therefore might even be the scope of this considered essential to analysis. See wilderness character. In this response to case, there are resident mountain comment 004. 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.

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 2017 035.12 Kirk Robinson Western A case might be made for the Wilderness See response to (multiple) Wildlife opportunity to view wild character comment 035.11 Conservancy animals, such as Rocky (Multiple) 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category species in a wilderness seems to clearly not be integral to the wilderness character of the areas in question.

2017 035.13 Kirk Robinson Western Furthermore, while the Wilderness The Wilderness (multiple) Wildlife opportunity to view wild character values, with regards Conservancy animals in their natural habitat is to the various (Multiple) a wilderness value, wilderness alternatives, were character is essentially about evaluated in the wildness, not the recreation Minimum opportunity to view mountain Requirements goats or bighorn sheep or any Analysis (MRA) other species. and are reflected in the NEPA analysis. See the purpose and need description as well as the effect to wilderness in the EA.

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 2017 035.14 Kirk Robinson Western Here it is worth noting the very Wildlife UDWR uses the (multiple) Wildlife interesting fact that UDWR following Conservancy believes the goats and sheep are definitions: The (Multiple) not reaching herd objectives set term "stable" is by the agency. Since 1999, the often used to mountain goat population in the describe a healthy three wildernesses has declined population that by 40%. (About 90 % of the exhibits relatively mountain goats in the national constant survival forest, inclusive of the and recruitment wilderness areas, are found rates, often near its inside the wilderness areas). carrying capacity or Also, since reintroduction of population bighorn sheep to the forest objective. The term (which were translocated from "stagnant" is used to Canada), the herd has, in the describe a language chosen by UDWR, population that become "stagnant." Expressed exhibits no clear less tendentiously, it has stopped growth trend and growing. It is patently shows poor unscientific to assume that the population population ought to be bigger performance relative than it is. To the contrary, the to a population fact the population has declined objective or what since the advent of bighorn the habitat could sheep suggests strongly that the sustain. 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 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.)

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 2017 035.15 Kirk Robinson Western This is significant for several Wildlife Thank you for your (multiple) Wildlife reasons: (1) It would easily comment. All Conservancy explain why the bighorn sheep alternatives being (Multiple) herd has stabilized at a lower analyzed will meet number than UDWR hoped for; the Forest Service (2) it would at least partially legal requirements. . explain why the mountain goat The Wilderness population has declined by 40% values, with regards since the mountain sheep were to the various reintroduced; (3) it is an alternatives, were unnatural situation and hence evaluated in the arguably contrary to the Minimum wilderness character of the Requirements wilderness areas to have both of Analysis (MRA) these species attempt to occupy and are reflected in the same habitat to which only the NEPA analysis. one of them is native; and (4) it See the purpose and is a situation that might foster need description in disease transmission between the EA. 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).

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 2017 035.16 Kirk Robinson Western UDWR wants to take tissue Alternatives The Wilderness (multiple) Wildlife samples from both sheep and values, with regards Conservancy goats in part to identify any to the various (Multiple) diseases that might be present. alternatives, were We have no quarrel with them evaluated in the wanting to do that, but we fail to Minimum see why landing helicopters in Requirements wilderness areas is necessary for Analysis (MRA) doing it, since they can always and are reflected in examine the carcasses of sheep the NEPA analysis. and goats killed by hunters. The use of Furthermore, and more mechanized importantly for present equipment in a purposes, we do not see how designated such information can be wilderness area can necessary for the FS to be able occur but should be to manage the areas for analyzed and wilderness character. The approved by the question of whether it is the Forest Service. minimum requirement for doing so doesn't even arise if it is not necessary in the first place. 2017 035.17 Kirk Robinson Western If UDWR feels that it is Alternatives Thank you for your (multiple) Wildlife important, for its own comment. All Conservancy management purposes, to obtain alternatives being (Multiple) tissue samples from sheep and analyzed will meet goats in the wilderness areas, it the Forest Service can sample dead animals legal requirements. . brought in by hunters and/or The Wilderness send personnel in on foot or values, with regards horseback to dart the animals. to the various This second option would no alternatives, were doubt be difficult to do, but it evaluated in the could be done; and it would not Minimum

Scoping Number First Last Name Organization Comment Resource Response Period Name Category pose a problem so far as Requirements wilderness management is Analysis (MRA) concerned. Forest Service and are reflected in policy provides guidance on this the NEPA analysis. point: "Where a choice must be See the purpose and made between wilderness values need description in and visitor or any other activity, the EA. 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) 2017 035.18 Kirk Robinson Western UDWR's other stated purpose Wilderness The Wilderness (multiple) Wildlife for its proposal, is to fit captured character values, with regards Conservancy sheep and goats with collars that to the various (Multiple) will allow UDWR personnel to alternatives, were track the movements of the evaluated in the animals. We have no problem Minimum with UDWR wanting to track Requirements the movements of the animals, Analysis (MRA) perhaps to see which parts of the and are reflected in habitat they use during different the NEPA analysis. seasons. But again, what has See the purpose and this got to do with the Forest need description in Service's statutory duty to the EA. 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category wilderness areas? We do not see how this can be so.

2017 035.19 Kirk Robinson Western Finally, we note that UDWR Wilderness Thank you for your (multiple) Wildlife fails to explain how they might character comment. All Conservancy use whatever information they alternatives being (Multiple) could hope to gain from the analyzed will meet proposed research project in the Forest Service order to meet the agency's twin legal requirements. . objectives of providing a The Wilderness maximum number of sheep and values, with regards goats for hunting and viewing. to the various In the total absence of any alternatives, were information regarding this, it is evaluated in the not possible to know whether Minimum UDWR will want to do a Requirements follow-up study, or several of Analysis (MRA) them, in which case we are and are reflected in concerned that ultimately there the NEPA analysis. may be a request for many more See the purpose and studies tiered off the one being need description in proposed. And obviously, this the EA. 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

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 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.

2017 035.20 Kirk Robinson Western For the reasons stated above, the General opposition, Thank you for your (multiple) Wildlife signatories to this letter are request for comment. The Conservancy opposed to UDWR's proposal information Forest Service will (Multiple) and we urge the Forest Service provide a 30-day to deny it. Please notify us when comment period on a decision has been made and the draft EA as well inform us of objection as a 45-day opportunities. objection period on the final EA and draft decision.

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 2017 N/A - Multiple Form Letter Various Please reject the Utah Division Wildlife/wilderness Thank you for your Form of Wildlife Resource's proposal comment. All to capture mountain goats and alternatives being bighorn sheep in the Twin analyzed will meet Peaks, Lone Peak and Mt. the Forest Service Timpanogos Wilderness areas. legal requirements. . The U.S. Forest Service's first The Wilderness responsibility is to protect the values, with regards wilderness character of the to the various Wildernesses. alternatives, were Specifically: evaluated in the o The Forest Service needs to Minimum say "NO" to helicopter landings Requirements in these three Wildernesses. Analysis (MRA) o Helicopter use is incompatible and are reflected in with Wilderness, harasses the NEPA analysis. wildlife, and destroys the See the purpose and experience for wilderness need description in visitors. the EA. See o The Forest Service needs to response to protect the areas' wilderness comment 004. 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.

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 2017 N/A - Multiple Form Various Commenters stated that the Hunting and Hunting regulations Form Plus/Unique proposal is intended to keep the viewing are outside the scope Comments population numbers large to opportunities of this analysis and benefit hunting based on hunting the Forest Service's permits being issued for the authority. area. 2017 N/A - Multiple Form Various Commenters stated that the Wilderness Act Thank you for your Form Plus/Unique USFS should deny the proposal (Idaho Court Case) comment. Comments 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 - Multiple Form Various Commenters stated that the Wilderness Act Effects to Form Plus/Unique USFS should deny the proposal Wilderness were Comments stating that the proposal violates analyzed in the EA. the Wilderness Act.

2017 N/A - Multiple Form Various Commenters stated that the State Wildlife This suggestion has Form Plus/Unique should undertake a habitat been forwarded on Comments analysis to assess whether the to Utah Division of non-native goats have run their Wildlife Resources. course. 2017 N/A - Multiple Form Various Commenters stated that the State Alternatives A range of Form Plus/Unique should hike in rather than use alternatives was Comments helicopters. analyzed in the EA including "Alternatives Considered but Eliminated from Detailed Analysis."

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 2017 N/A - Multiple Form Various Commenters stated that Budget Thank you for your Form Plus/Unique proceeding with the project is a comment. Comments waste of taxpayer dollars.

2017 N/A - Multiple Form Various Commenters stated that the use Noise Noise pollution was Form Plus/Unique of helicopters is considered not carried forward Comments noise pollution. as a key issue for analysis.

2017 N/A - Multiple Form Various Commenters stated that killing Wildlife Thank you for your Form Plus/Unique and capturing animals is cruel. comment. Comments

2017 N/A - Multiple Form Various Commenters stated that Safety Search and rescue Form Plus/Unique helicopter use should be for life operations have Comments threatening emergencies only. been addressed in the EA.

2017 N/A - Multiple Form Various Commenters stated that roughly Wildlife UDWRs proposal is Form Plus/Unique two-thirds of Bighorn range lies to determine Comments outside the Wilderness and they potential disease could be captured there. transmission between mountain goat and bighorn sheep. It is the animals that interact in wilderness that are of the greatest concern which has

Scoping Number First Last Name Organization Comment Resource Response Period Name Category led to the proposed action.

2017 N/A - Multiple Form Various Commenters expressed concern Frequency of The proposed action Form Plus/Unique regarding the frequency of landings is described in Comments landings, specifically that this Chapter 2 of the EA. 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. 2017 N/A - Multiple Form Various Commenters stated that the Wildlife Thank you for your Form Plus/Unique cause of sickness to the animals comment. Comments could be caused by humans.

2017 N/A - Multiple Form Various Commenters stated that Wildlife See the existing Form Plus/Unique mountain goats are not native to condition for a Comments the Wasatch and were discussion on introduced solely to provide mountain goat and additional hunting opportunities. bighorn sheep. Also that mountain goats Vegetation impacts compete with native bighorn associated with the sheep for forage and their proposed action are noticeable effects on high alpine discussed. The vegetation have not been hunting of certain evaluated. The goats and sheep species and the are to be captured via helicopter competition between

Scoping Number First Last Name Organization Comment Resource Response Period Name Category netting, so every animal taken species is outside for analysis will require at least the scope of this two helicopter landings. analysis.

2017 N/A - Multiple Form Various Commenters stated that the Alternatives Occular Form Plus/Unique analysis could be conducted via observations do not Comments occular observation. accomplish the purpose and need of the project. 2017 N/A - Multiple Form Various Commenters asked the USFS to Noise Cumulative effects Form Plus/Unique consider the cumulative impacts are evaluated as part Comments of helicopter use and noise of this analysis. pollution.

2017 N/A - Multiple Form Various Commenters stated that the State Wildlife The purpose and Form Plus/Unique should conduct a study to need of this project Comments determine the cause of decline is to respond to this of the animals. question.

2017 N/A - Multiple Form Various Commenters stated that several Proposed Action The Utah Division Form Plus/Unique months ago, the UDWR asked and Purpose and of Wildlife Comments permission to capture mountain Need Resources have goats, but because they aren’t modified their native it was virtually proposal to include impossible to show the project bighorn sheep. This was necessary to benefit the has modified the Wildernesses. They included analysis while that it now appears the UDWR maintaining the is piggybacking bighorn sheep purpose and need. A onto the project to make it discussion of the

Scoping Number First Last Name Organization Comment Resource Response Period Name Category appear it might help a native species to be species. evaluated is found in the existing conditions.

2017 N/A - Multiple Form Various Commenters stated that the Outside the scope Thank you for your Form Plus/Unique Trump administration is making of analysis comment. Comments a disgrace of the environment.

2017 N/A - Multiple Form Various Commenters stated that Wilderness Effects to Form Plus/Unique helicopters in the wilderness character Wilderness were Comments would cause a disturbance to analyzed in the EA. hikers.

2017 N/A - Multiple Form Various Commenters stated that the last Wilderness Effects to key issues Form Plus/Unique thing the plants, wild animals, character are addressed or Comments and human visitors need is dismissed in the EA. buzzing helicopters which at the very least would bring noise and air pollution, terrorize animals, and cause serious erosion. 2017 N/A - Multiple Form Various Commenters stated that non- Wildlife Thank you for your Form Plus/Unique native species should not be comment. A Comments allowed to compete with native discussion of species. mountain goat and bighorn sheep can be found in the existing condition discussion in wildlife.

Scoping Number First Last Name Organization Comment Resource Response Period Name Category 2017 N/A - Multiple Form Various Commenters stated that the Safety Safety would be Form Plus/Unique safety of operations should be addressed in Comments considered. UDWRs operations plan.

2017 N/A - Multiple Form Various Commenters stated that State Wildlife An evaluation of the Form Plus/Unique Management Plans are not as State Management Comments protective as they should be. Plans are outside the scope of this analysis.

Appendix B: Issues Addressed but not Analyzed in Detail

The following section discusses issues that were considered but not analyzed and their rationale for not analyzing them. These issues were those that were: 1) outside the scope of the proposed action; 2) already decided by law, regulation, Forest Plan, or other higher level decision; 3) irrelevant to the project or its resources; or 4) conjectural and not supported by scientific or factual evidence; or 5) have been addressed by eliminating any potential effects through alternative design, design criteria, and/or mitigation measures (described in Appendix C).

B1. Air Quality

While the proposed action would increase exhaust pollutant emissions in the immediate area, it would not have measurable impacts on air quality given the distance and dilution that would occur as particles and air mix over distance and is therefore not analyzed in detail in this EA.

B2. Botany

The project is not anticipated to have any direct, indirect, or cumulative effects to vegetation and botany resources due to the fact that the project does not involve any ground disturbing activities. Many of the Threatened, Endangered, and Sensitive, (TES) plant species reviewed do not occur in the three wilderness areas due to lack of habitat. In addition, the proposed helicopter landings would also occur between the fall and early winter months of September and November when most plants are dormant, underground, and have already flowered and set seed. Therefore, there are no direct or indirect effects expected to occur to any TES or candidate plant species or their habitats.

Sensitive Plant Species

Forest Service Sensitive plant species which would not be impacted by the proposed action include: Wheelers Angelica, Dainty moonwort, Slender moonwort, Wasatch fitweed, Brownie lady's slipper, Lesser yellow lady’s slipper, Wasatch Shooting Star, Wasatch Draba, Burkes Draba, Rockcress draba, Maguire whitlow-grass, Santaquin draba, Cronquist's daisy, Garrets fleabane, Logan buckwheat, Utah ivesia, Wasatch Jamesia, Wasatch pepperwort, Garrett's bladder pod, Alpine poppy, Cache penstemon, Cottam cinquefoil, Uinta Greenthread, Barneby woody aster and Frank Smith's violet.

Species at Risk

Multiple other plants, “Species at Risk” and/or Wasatch-Cache “Watch List” plant species were also evaluated as part of this process, and it is expected that the project would not have an impact these other species either.

B3. Climate Change

The project would not have any measurable direct, indirect, or cumulative effects on climate change. This level of carbon dioxide emissions is low enough as to be discountable and no direct or indirect effects to climate change would be expected.

B4. Cultural Resources

The proposed mountain goat and bighorn sheep capture and collar in the Twin Peaks, Lone Peak, and Mount Timpanogos Wilderness Areas, has no potential to affect historic properties.

The proposal to capture and collar wildlife via a net gun and helicopter operations for a limited duration of time (approximately 30 hours), does not involve any ground disturbance activities, no modification of structures that are over 50 years in age, and would have no direct or indirect effect on cultural resources.

Due the fact that the nature of the proposed action has no potential to affect historic properties, the USDA Forest Service, UWCNF, has made the determination of No Historic Properties Affected as per 36 CFR 800.4(d)(1), and recommends that the project proceed from a cultural resources perspective.

B5. Socioeconomics

Socioeconomic effects are limited in this case or measurable effects meaningful to the analysis are detailed with other resource discussions. The creation of jobs or economic returns associated with the permitting of mechanized equipment in wilderness is extremely limited.

B6. Fire and Fuels

The proposed mountain goat and bighorn sheep capture in the Twin Peaks, Lone Peak, and Mount Timpanogos Wilderness Areas has no potential direct affect the fire and fuels program.

B7. Fisheries and Aquatic Resources

The proposed Mountain goat and Bighorn sheep capture and collar in the Twin Peaks, Lone Peak, and Mount Timpanogos Wilderness Areas has no direct or indirect effects or impacts to fisheries or aquatic species resources.

Based on the nature or helicopter capture of ungulates and the normal habitat occupation of Bighorn sheep and mountain goats, potential to impact fish and amphibian occupied habitats is extremely low. Further, the absence of known Threatened/Endangered aquatic species within the capture area and limited low elevation distribution of Forest Sensitive species, likelihood of overlap is minimal.

B8. Noxious Weeds

Introduction and/or spread of invasive and/or noxious weeds into and/or throughout or between each of the three wilderness areas. There are no ground disturbing activities being proposed as part of this project. With the Forest Plans, (Wasatch-Cache and Uinta), standards and guidelines being adhered to, as well as project design criteria and mitigation measures being implemented to reduce or prevent undesirable effects to the wilderness areas from noxious and invasive weed invasion and spread, it is anticipated that there would be very little, to no opportunity for weeds to invade or be spread as a result of this project work. In general, high elevation plant communities with cooler temperatures are also more resistant to weed invasion and spread than those at lower elevations on the forests, which also minimizes the chance for weed species to become established in the wilderness areas. Another factor is the relatively short duration, of the project, (number of hours estimated to complete), and very minimal impact of the project work itself. The staging areas are located at lower elevations, but are hard surface locations and again with standards and guidelines, design criteria and mitigation measures being adhered to, there should be very little to no impacts as well. It is anticipated that the project would not have any measurable direct, indirect, or cumulative effects to noxious and invasive weed spread.

B9. Recreation

See Section 3.1.1, Wilderness Resources, for the analysis of the direct and indirect effects on Recreation inside the three wilderness areas. Impacts to recreation outside the three wilderness areas recreation was not carried forward because of timing of the proposed action during September-November and that the

100

activities would not occur on weekends or holidays. Based on this criteria there would be little to no effect to recreationists that could occur at the two developed recreation sites as a result of staging operations.

B10. Range

There are no prime farmlands or rangelands located on the Uinta-Wasatch-Cache National Forest. Therefore, no effects to prime farmland or rangeland would occur with implementation of any alternative.

B11. Scenic Values

There are no direct or indirect effects to the landscape resulting in changes to the visual quality and/or landscape integrity of the area. Since there is no direct or indirect effects to the visual quality objectives (VQOs) and/or scenic integrity objective (SIOs) resulting from the proposed action would be anticipated, there would be no cumulative impacts.

B12. Silviculture

There would be no timber resources removed from the Uinta-Wasatch-Cache National Forest. Therefore, no effects to timber resources would occur with implementation of any alternative.

B13. Soils and Water Resources

Due to the lack of ground disturbing activities and development of project specific design features to eliminate impacts from helicopter landing and refueling (Appendix C), there would be no direct, indirect, or cumulative effects to soil and water resources.

B14. Wildlife (Terrestrial)

Terrestrial Threatened and Endangered Species

There are three threatened species listed for the forest the Gray wolf, Canada lynx and Western yellow billed cuckoo. There is very limited habitat on the forest for all three species and the species are not found within the project area.

Terrestrial Sensitive Species

USDA Forest Service Sensitive terrestrial species evaluated in the EA include American Peregrine Falcon, American three-toed woodpecker, bald eagle, bighorn sheep, boreal owl, Columbian sharp-tailed grouse, fisher, flammulated owl, greater sage-grouse, great gray owl, northern goshawk, peregrine falcon, spotted bat, and Townsend’s big-eared bat (Table B-1). Of the sixteen species, eleven of them have potential habitat or may occur within the project area, but would not be impacted by the proposed action.

Table B-1: Forest Plan Consistency Forest Plan Consistency/Other Key Items Alt A Alt B Activities Result in Forest Plan Amendment? No No Activities Increase Potential Spread of Noxious Weeds? No No Activities Compliant with National Historic Preservation Act and Yes Yes Archaeological Resources Protection Act? (See Appendix B) Activities Result in Measureable Effects Air Quality? (See Appendix B) No No Activities Consistent with ROS Designations? (See Appendix B) Yes Yes Activities would result in effects to soil or hydrologic resources? (See No No Appendix B)

101

Activities consistent with VQO/SIO Designations? (See Appendix B) No No Would activities result in effects to socio/economic resources? (See No No Appendix B) Would activities result in effects to transportation facilities? (See No No Appendix B) Would activities likely result in a fuel spill? (See Appendix C) No No Would activities result in meaningful inputs of emissions contributing to No No climate change? (See Appendix B) Threatened, Endangered, and Proposed Species Alt. A Alt. B Wildlife Species NE NE Plant Species NE NE Fish Species NE NE Sensitive and Candidate Species Alt. A Alt. B Bighorn sheep NI BI Gray wolf (Rocky Mtn DPS) NI NI Fisher NI NI Townsend's Western big-eared bat NI NI Spotted bat NI NI Bald eagle NI NI Boreal owl NI NI Greater sage-grouse NI NI Peregrine falcon NI NI Flammulated owl NI NI Three-toed woodpecker NI NI Great gray owl NI NI Columbian sharp-tailed grouse NI NI Northern goshawk NI NI Columbia spotted frog NI NI Boreal toad NI NI Plant Species NI NI Fish Species NI NI Focal Species Alt. A Alt. B Bonneville Cutthroat Trout NI NI Northern Goshawk NI NI

102

Appendix C: Design Criteria & Mitigation Measures

Design features are incorporated to reduce or prevent undesirable effects to the Forest resulting from proposed management activities.

C1. Design Criteria proposed by UDWR

 In addition to Forest Plans standards and guidelines designed to mitigate impacts, the following design features would also apply. They are incorporated to reduce or prevent undesirable effects to the Forest resulting from proposed management activities.

 Use existing unimproved openings for capture areas; no cutting of vegetation within the wilderness area.

 All equipment, including the camping and nets, and clothing are to be free from weeds or dirt.

 UDWR would notify Northern Utah Interagency Fire Center (NUIFC) 801-495-7600 on days that the flights

 The authorization would be in place after Labor Day through the end of November to minimize conflicts with other recreational activities within the three wilderness areas.

 The number of people needed to safely and efficiently handle each animal would be minimized.

C2. Mitigation Measures required by UWC

 Avoid use of Riparian Habitat Conservation Areas (RHCA) as landing zones to remove potential of and for downstream transport of impacts to fish and amphibian habitats.

 Fuel storage is prohibited (Standard Aqua-7) within RHCAs in the Uinta planning area should be applied as a project design feature within the Wasatch-Cache planning area given the importance of water quality protection in Little Cottonwood Canyon (municipal watershed). “Fuel storage” in this case is the parking of the fuel truck while it is not actively refueling the helicopter. Refueling should be done outside of the RHCA unless a safe landing can’t be completed outside of the RHCA. If refueling must occur in the RHCA, spill containment measures should be employed at the refueling site and the fuel truck should leave the RHCA upon completion of refueling.

 Noxious and invasive weeds, (in addition to following all Forest Plan noxious and invasive weed standards and guidelines):

o Ensure all equipment, (boots, clothing, nets, camping gear including tents, vehicles and helicopter), used for the project work are cleaned and noxious and invasive weed free, (avoid bringing in soil or other material contaminated with weed seeds or plants from other locations).

o Avoid walking or driving through, camping on or landing helicopter in any areas with existing noxious or invasive weed infestations, (weeds would most likely have set seed by the period of planned operations and could easily be spread further if not avoided).

o Both the Salt Lake and Pleasant Grove Ranger Districts have issues with roadside, and trailhead weeds in a variety of locations, avoid parking vehicles in infested locations.

103

o Coordinate with the Forest Service to ensure noxious and invasive weed treatments of any existing weed infestations, at the staging areas, occurs prior to the start of the project. o If noxious weed infestations are located in the wilderness, map and provide location to the FS. o Follow up monitoring should occur at the staging area locations for a minimum of 3 years post project, to detect and immediately treat any new invading noxious or invasive weed species. o Treat any existing noxious or invasive weed infestations that remain, for 3 years post project, (or longer, depending on the weed species, as length of seed viability in the soil, can vary by species). o If any unforeseen ground disturb occurs, reseed the disturbed area using only certified noxious weed free seed mix, post project, prior to snowfall. o Follow all State of Utah regulations related to noxious weeds in the state, and obtain the new list of Utah State listed noxious weeds for their use, (noxious weed booklets can be obtained from Utah State University, Office of Research, Logan Utah, Online, or at the Pleasant Grove Ranger District.)

104

Appendix D: References

Arthur Carhart National Wilderness Training Center. Undated. What is wilderness character? Interagency document in the Wilderness Character Toolbox at http://www.wilderness.net/toolboxes/documents/WC/FWS%20610%201.13,1.14,1.17.pdf. Accessed June 07, 2017

Arthur Carhart National Wilderness Training Center. (2016). Minimum requirements decision guide instructions. December 15, 2016 version.

Besser TE; Cassirer EF; Potter KA; Lahmers K; Oaks JL, et al. (2014) Epizootic Pneumonia of Bighorn Sheep following Experimental Exposure to Mycoplasma ovipneumoniae. PLoS ONE 9(10): e110039. doi:10.1371/journal.pone.0110039

Butler, C. (2017, April 05). Pleasant Grove Ranger District Trails and Wilderness Manager. (D. Hatch, Interviewer)

Cordell, H. Ken; Tarrant, Michael A.; Green, Gary T. (2003). Is the Public Viewpoint of Wilderness Shifting? International Journal of Wilderness Volume 9, Number 2

Feldhamer, George; Thompson, Bruce; Chapman, Joseph. (2003). Wild Mammals of North America, Biology, Management, Conservation. Baltimore: John Hopkins University Press.

Festa-Bianchet, M. and S. D. Cote. (2008). Mountain Goats. Island Press, Washington DC, USA.

Gross, J. K. (2002). GIS-Based Habitat Models for Mountain Goats. Journal of Mammalogy, 218-228.

Krausman, Paul R.; Hervert, John J.; Ordway, Leonard L.; Wildlife Society Bulletin (1973-2006), Vol. 13, No. 1 (Spring, 1985), pp. 71-73, Capturing Deer and Mountain Sheep with a Net-Gun

Landres, P., C. Barns, J. Dennis, T. Devine, P. Geissler, C. McCasland, L. Merigliano, J. Seastrand, and R. Swain. (2008). Keeping it wild: an interagency strategy to monitor trends in wilderness character across the National Wilderness Preservation System. Gen. Tech. Rep. RMRS-GTR-212. Fort Collins: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station.

Landres, Peter; Barns, Chris; Boutcher, Steve; Devine, Tim; Dratch, Peter; Lindholm, Adrienne; Merigliano, Linda; Roeper, Nancy; Simpson, Emily. (2015). Keeping it wild 2: an updated interagency strategy to monitor trends in wilderness character across the National Wilderness Preservation System. Gen. Tech. Rep. RMRS-GTR-340. Fort Collins, CO: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station.

Lane, M. (2017, April 06). Heber-Kamas Ranger District Natural Resource Specialist and prior Salt Lake Ranger District Trails and Wilderness manager. (D. Hatch, Interviewer)

Lilly, R. B. (2016). Opportunities for Solitude in Salt Lake Ranger District Wilderness Areas; Wasatch National Forest. University of Utah, Outdoor Recreation, Education, and Tourism, Salt Lake City, Utah.

Park, O. N. (1995). Mountain Goat Management Plan, Environmental Impact Statement Olympic National Park. Moorhead: Olympic National Park.

105

Rawley, E. V. (1985). Early records of wildlife in Utah. Publication number 86-2. Division of Wildlife Resources, Department of Natural Resources, Salt Lake City, Utah, USA.

Resources, U. D. (2013). Utah Mountain Goat Statewide Management Plan. Salt Lake City: Department of Natural Resources.

Schuster, R. M., H. K. Cordell, and B. Phillips. (2005). Understanding the cultural, existence, and bequest values of wilderness. International Journal of Wilderness 11(3): 22.

Shannon, J. W. (2014). Population response of reintroduced bighorn sheep after observed commingling with domestic sheep. Salt Lake City: Springer.

Shields, W. (1999). Rocky Mountain bighorns - Utah. Pages 108–111 in D. E. Toweill and V. Geist, editors. Return of Royalty - Wild Sheep of North America. Boone and Crocket Club and Foundation for North American Wild Sheep, Missoula, Montana, USA.

USDA Forest Service (2003). Uinta National Forest Land and Resource Management Plan.

USDA Forest Service (2003a). Wasatch-Cache National Forest Land and Resource Management Plan.

USDA Intermountain Region of the Forest Service and Utah Division of Wildlife Resources. (2012). Memorandum of Understanding between USDA Forest Service, Intermountain Region and the State of Utah, Utah Division of Wildlife Resources. Ogden, Utah, United State of America.

Utah Division of Wildlife Resources. (2013). Utah Bighorn Sheep Statewide Management Plan. Salt Lake City: Utah Department of Natural Resources.

Utah Division of Wildlife Resources. (2013). Utah Mountain Goat Statewide Management Plan. Salt Lake City: Utah Department of Natural Resources.

Walsh, R. G., J. B. Loomis, and R. A. Gillman. (1984). Valuing option, existence, and bequest demands for wilderness. Land Economics. Vol. 60, Number 1. February 1984.

Wolff, Peregrine; Cox, Mike; McAdoo, Caleb; Anderson, Chris A. (2016). Disease Transmission between Sympatric Mountain Goats and Bighorn Sheep. Oral presentation under review.

106