August 2015 | Volume 21, Number 2
by DAVID N. COLE
To some degree, the United States’ Wilderness Act of 1964 codifies in law which activities and actions should or should not be taken in wilderness. Commercial enterprises that are not specifically provided for in the act, such as timber harvesting, are prohibited. Building reservoirs, power projects, and transmission lines are only allowed if the president of the United States deems them to be in the public interest. Actions to control fire, insects, and diseases are to be taken only if they are necessary and deemed desirable by the U.S. secretary of agriculture. The public use of aircraft and motorboats may only be permitted where such use was established prior to wilderness designation. Finally, there are to be “no temporary roads, no use of motor vehicles, motorized equipment or motorboats, no landing of aircraft, no other form of mechanical transport and no structure or installation” except where these activities are the minimum necessary to administer the area for the purpose of the act. In contrast to these generally prohibited uses, wilderness is to be devoted to recreational, scenic, scientific, conservation, and historical use.
The clarity that the Wilderness Act provides about the appropriateness of these activities and action does not extend to all the management decisions that wilderness stewards must make. Where the law can be interpreted in shades of gray, rather than in black and white, clarity regarding what stewards should decide can be provided through agency policy and guidance. Alternatively, if meaningful agency policy and guidance is not provided, decision makers are left with wide discretion to decide whatever they want, based largely on their personal value system and experience, along with outside influences such as traditional ways of doing things and local politics. To the extent that it is important for wilderness stewards to make consistent decisions, with outcomes that contribute to societal goals and values, agencies should provide clear and meaningful policy.
Management Dilemmas and Agency Policy
Fifteen years ago, I wrote a paper on management dilemmas facing wilderness stewards at the start of the 21st century (Cole 2001). I discussed two dilemmas, each the result of conflict between two desirable purposes or attributes of wilderness described in the Wilderness Act. One dilemma – not a new one – involves conflict between providing access to wilderness for its “use and enjoyment” and protecting the biophysical conditions and experiences that uniquely define wilderness but are degraded by recreational use. To what extent and in which situations should stewards limit the use and enjoyment of wilderness in order to avoid adverse effects on the environment and experiences? The other dilemma – only publicized within recent decades (Cole 1996; Smith 2014) – involves conflict between two desirable attributes of wilderness ecosystems, lack of intentional human manipulation (prescribed in the language of the act as untrammeled and sometimes referred to as wildness) and relative lack of human influence (sometimes referred to as naturalness). To what extent and in which situations should stewards intervene in wilderness ecosystem conditions and processes in an attempt to mitigate anthropogenic impacts? I argued that the future of wilderness and the values it provides will largely be determined by the decisions stewards make in response to these two dilemmas. Therefore, these decisions should be guided by clear federal policy.
Clear, specific, and meaningful policy was lacking in 2000 and is still lacking today. Regarding how to decide whether recreation use should be restricted, each U.S. federal land management agency’s policy says little more than that restrictions may be used to protect wilderness values. Bureau of Land Manage-ment policy, which was revised in 2012, provides the most specificity. It states that “solitude is not required on every acre of wilderness” and that “management restrictions are easier to justify if also taken to protect the area’s Natural quality” – rather than just to protect solitude and visitor experience quality (USDI Bureau of Land Management 2012). Given that all the agencies lack meaningful policy, whether restrictions such as use limits have been implemented is determined more by management agency and length of stay and less by the extent to which wilderness values have been degraded. Most wilder-nesses with use limits are managed by the National Park Service, most of those limits were put in place more than 30 years ago, and most apply only to overnight use.
Wilderness policy regarding the appropriateness of ecosystem intervention and manipulation is equally ambivalent. It typically states that management will not “intervene” (USDI National Park Service 2006) or “interfere” (USDI Fish and Wild-life Service 2008) with ecosystem processes, that such actions should be used only as “a last resort” (USDA Forest Service 2006). However, it goes on to state that manipulation “is permitted” (USDI Bureau of Land Management 2012) or processes “may need to be actively managed” (USDI National Park Service 2006) wherever they have “been disrupted by past or ongoing human activities” (USDI National Park Service 2006), have “become unnatural” (USDI Fish and Wildlife Service 2008) or “where natural processes alone cannot recover the area” to conditions that “would likely have developed with minimal human influence (USDI Bureau of Land Management 2012). Since even the most remote wildlands have been disturbed by human activities (Stephenson et al. 2010), the general direction to not intervene is not applicable on most wilderness lands. Given this seemingly contradictory guidance, it is not surprising that the practice of ecosystem intervention (prescribed fire, use of herbicides, etc.) is highly inconsistent. Whether intervention occurs or not has little to do with either the magnitude of human disturbance or the degree to which interventions trammel wilderness.
Decision-Making Frameworks Instead of Policy
In response to widespread confusion about how to resolve these dilemmas and inconsistency in practice, agency scientists and training specialists, particularly those at the Aldo Leopold Wilderness Research Institute and Arthur Carhart National Wilderness Training Center, have developed a number of rational frameworks for making decisions. Perhaps the first of these, devised to help wilderness stewards decide where restrictions on recreation use are appropriate, was the Limits of Acceptable Change planning framework (Stankey et al. 1985). More recently, frameworks have been devised for deciding on the appropriateness of scientific activities in wilderness (Landres et al. 2010), and a framework is currently being developed for deciding on the appropriateness of ecosystem restoration (Hahn and Landres 2014). The most ambitious of these frameworks is the Minimum Requirements Analysis (MRA), implemented using the Minimum Requirements Decision Guide (MRDG) (Arthur Carhart National Wilderness Training Center 2014). The MRA was originally developed for the specific purpose of deciding whether uses generally prohibited by the Wilderness Act (e.g., temporary roads, motor vehicles, and structures) should be allowed because they are the minimum necessary to administer the area to meet the purpose of the Wilderness Act. Recently, the MRA and MRDG have been expanded and generalized to make them applicable to decisions regarding the appropriateness of virtually any action that might be taken in wilderness.
What these processes have in common is that they lead wilder-ness stewards through a structured process of documenting the assumptions, facts, and value choices that go into making a decision. They typically consist of a sequenced list of questions or things to consider, often organized as a cost-benefit analysis that assesses whether wilder-ness values are collectively enhanced or degraded by taking a proposed action. Widespread use of these frameworks has had a number of benefits, including increasing the thoughtfulness and transparency of wilderness stewardship decisions and consistency in how decisions are made. However, use of these frameworks has not necessarily resulted in better decisions – decisions that are more consistent and more in line with desired outcomes. Decisions are fundamentally choices among competing values. A framework is simply an edifice or structure in which to organize the decisions among competing values that make up the ultimate decision. It is the role of policy and guidance – not the framework – to ensure that such decisions reflect societal values rather than those of whoever happens to have the authority to make decisions. Frameworks guide how decisions are made, but only meaningful policy can guide what those decisions should be.
This difference between the roles and capabilities of policy and analytical frameworks is not always appreciated. An example can be found in the 2020 Vision document, a set of interagency goals, objectives, and actions, adopted by the United States’ wilderness management agencies at the conference celebrating the 50th anniversary of the Wilderness Act, and intended to guide collaborative stewardship of wilderness into the future. One of the proposed actions is to “minimize management interventions that modify natural conditions by using the Minimum Requirements Analysis process to make decisions on all proposed management interventions” (2020 Vision 2014). Working through the MRA, however, will do little to achieve the desired outcome of minimizing interventions if those making decisions view loss of natural conditions to be a graver threat to wilderness values than the trammel-ing that occurs with intervention. If the agencies truly want to minimize interventions they need to incorporate that goal into policy, by making it clear that the untrammeled quality of wilderness is the foremost wilderness quality to protect – that interventions are seldom appropriate, even where conditions have been disrupted by human activity and those conditions cannot recover by natural processes alone. With such a policy in place, using the MRA will have the desired result. Without such policy, it will not.
More Meaningful Stewardship Policy Is Needed Now
Where the collective outcome of numerous decisions, independently made by many different people, is considered important, those decisions should be guided by clear, specific, and meaningful policy. When the U.S. government got serious about reducing dependence on foreign oil, it did not simply ask car buyers to do a cost-benefit analysis that considers fuel economy along with factors such as performance, appearance, and safety; instead it implemented policy that regulates the fuel efficiency of the nation’s cars. Even when it comes to decisions that line officers in the U.S. federal land management agencies make regarding response to wildfire or extraction of timber and mineral resources, decisions are highly constrained by agency policy and guidance. Isn’t wilderness stewardship also important enough to be guided by meaningful policy?
There are a number of barriers to the development of meaningful policy, not the least of which are procedural requirements, which generally involve substantial public involvement. Perhaps the foremost barrier, however, is the tendency to avoid making difficult and controversial decisions, particularly when there are few vocal advocates for more specific policy. Consider the dilemma regarding whether to intervene in an attempt to restore humanly disturbed ecosystem processes in wilderness. If policy was developed that discouraged intervention, those who most value self-willed wilderness would be happy, while those who are more concerned with protection of native biodiversity would be unhappy (Smith 2014). Where values conflict, it is easier for agency leaders to ignore this conflict than to confront it by developing policy that clarifies which set of values has priority.
A common argument for not developing specific policy is that managers need the flexibility to respond to diverse situations. This is a valid concern. The management techniques most appropriate in desert wilderness are likely different from those in high mountains or lush forests. Managers need situational flexibility – the ability to vary how they respond with differences in situational variables such as environmental characteristics. Flexibility becomes problematic, however, when two different decision makers, managing the same situation, seek widely divergent outcomes because they have different personal views about the relative importance of competing values. Good policy will narrow managerial discretion regarding the desired outcome of management, while retaining the situational flexibility to vary how a given outcome is reached.
Decision making has been improved by widespread use of decision-making frameworks. The transparent and thoughtful decisions that result from using these frameworks are better than decisions without those qualities. However, it is even more important to ensure that stewards make the “right” decisions – that their decisions consistently contribute to societal goals and values. This requires more specific policy about the desired outcomes of stewardship – policy that will guide the choices between competing values that are at the heart of any decision, regardless of the decision-making framework employed.
In 1999, the agencies charged with the responsibility of managing wilderness formed an Interagency Wilderness Policy Council to, among other things, “coordinate and improve consistency in the interpretation and implementation of the Wilderness Act.” Wilderness stewardship would benefit greatly if the council moved aggressively, and in an interagency fashion, to increase the clarity and meaningfulness of wilderness stewardship policy. They could create a task force to listen to stakeholders with varied values and divergent opinions about stewardship issues and policy. The task force could identify policy choices and describe the likely consequences of these choices, providing the Policy Council with the information it needs to develop more meaningful policy. The ultimate result would be more consistent, efficient, and effective wilderness stewardship.
2020 Vision. 2014. 2020 Vision: Interagency Stewardship Priorities for America’s National Wilderness Preservation System. Retrieved February 17, 2015, from www.wilderness. net/toolboxes/documents/50th/2020_ Vision.pdf.
Arthur Carhart National Wilderness Training Center. 2014. Minimum Requirements Decision Guide, 2014 Revision. Retrieved February 17, 2015, from www.wilderness. net/MRA.
Cole, D. N. 1996. Ecological manipulation in wilderness: An emerging management dilemma. International Journal of Wilderness 2(1): 15–19.
—. 2001. Management dilemmas that will shape wilderness in the 21st century. Journal of Forestry 99: 4–8.
Hahn, B., and P. Landres. 2014. The Unique Legal, Scientific, and Ethical Challenges of Restoration in Wilderness. Powerpoint presentation retrieved February 17, 2015, from www.wilderness.net/NWPS/webinars.
Landres, P. ed. 2010. A Framework to Evaluate Proposals for Scientific Activities in Wilderness. General Technical Report RMRS-GTR-234. Fort Collins, CO: USDA Forest Service, Rocky Mountain Research Station.
Smith, J. F. 2014. The wilderness paradox. Orion September–October 2014.
Stankey, G. H., D. N. Cole, R. C. Lucas, M. E. Petersen, and S. S. Frissell. 1985. The Limits of Acceptable Change (LAC) System for Wilderness Planning. General Technical Report INT-176. Ogden, UT: USDA Forest Service, Intermountain Research Station.
Stephenson, N. L., C. I. Millar, and D. N. Cole. 2010. Shifting environmental foundations: The unprecedented and unpredictable future. In Beyond Naturalness: Rethinking Park and Wilderness Stewardship in an Era of Rapid Change, ed. D. N. Cole and L. Yung (pp. 50–66). Washington, DC: Island Press.
USDA Forest Service. 2006. FS Manual Chapter 2320 – Wilderness Management. Washington, DC.
USDI Bureau of Land Management. 2012. BLM Manual 6340 – Management of BLM Wilderness. Washington, DC.
USDI Fish and Wildlife Service. 2008. FWS Manual, Natural and Cultural Resources Management Chapter – Part 610 Wilderness Stewardship. Washington, DC.
USDI National Park Service. 2006. Management Policies 2006. Washington, DC.
DAVID N. COLE is emeritus scientist with the Aldo Leopold Wilderness Research Institute and on the board of the Society for Wilderness Stewardship. The views expressed in this article are the author’s and should not be attributed to either of these organizations; email: dncole. [email protected]