Our Comments on the Pisgah and Nantahala Wilderness Evaluations

posted in: Indoors, Outdoors | 0

Below are the comments I am submitting to the National Forests in NC regarding their Wilderness Inventory Evaluation process, which is underway as a part of the Nantahala and Pisgah National Forests Plan Revision. They’re looking for very specific, particularly formatted comments, so due to time, I was not able to comment on all the areas I’d like to. However, I did draw up some comments for areas I felt particularly strongly about.

Where I didn’t write up any specific comments, I support the talking points produced by The Wilderness Society‘s North Carolina Mountain Treasures project. Those talking points, and the general plan outlined there, has become the basis for a proposal, the Conservation and Recreation Memorandum of Understanding, submitted to the Forest Service by a large and diverse group of organizations related to outdoor recreation in Western NC.

That proposal does not recommend wilderness designation for all of the areas the Forest Service is evaluating, nor any of the areas of the forest where mountain biking trails are currently available. However, it does recommend a baseline level of protection for all of the wilderness inventory areas which excludes most commercial logging. It proposes two new National Recreation Areas, one in Grandfather and one in Pisgah, which I also strongly support, and places areas with mountain biking trails in Backcountry rather than Wilderness areas.

The primary difference between the Talking Points/MOU and my comments are that I support Wilderness for Lost Cove but not Harper Creek in the Grandfather Mountain/Wilson Creek area.

If you would like to submit your comments, I recommend doing so using this form, which implores the Forest Service to open up discussion about management areas other than wilderness before the final plan alternatives are drafted. The language in that form addresses the whole issue I have with this part of the process, which is that they don’t seem to be taking comments on anything but wilderness at this time, and have provided very little feedback since last year’s heated discussion about what they might do to change other controversial management area proposals.

Wilderness-specific comments I submitted to the forest service start below this line, adhering to their proscribed format as closely as possible.


From: Jordan Mitchell, jordan@wncoutdoors.info
To: NCplanrevision@fs.fed.us
Subject: Wilderness evaluation input

I would like to submit the following comments relating to the Wilderness evaluation for your review before the alternatives to the new forest plan are completed.

For any of the inventory areas or evaluation categories I have not explicitly commented on, I concur with and hereby submit the comments published by the North Carolina Mountain Treasures project accessible via their web page “WIA Chart for Public Comment” (http://www.ncmountaintreasures.org/wia-chart-for-public-comment/) and the multi-organization Conservation and Recreation Memorandum of Understanding (http://www.ncmountaintreasures.org/conservation-and-recreation-memorandum-of-understanding/) regarding the wilderness inventory.

Specific Area Comments

We have specific comments to submit about the following inventory areas.

Wilson Creek

Solitude or Primitive and Unconfined Recreation

2b) Primitive and Unconfined Recreation

Poaching by mountain bikers of many trails in this area is frequent; however, there is an argument to be made that these (as well as some surrounding ones) would make great mountain bike trails and there is a greater demand for that activity region-wide.

2c) Other Solitude or Recreation

While the opportunities for recreation are excellent here, they do not necessarily feel as “unconfined” nor wilderness-like as they should for a proper wilderness designation, in my opinion.

Management

5d) Inholdings

Owing partly to the private inholding at the end of FS 4001, the area feels more fragmented than wilderness should.

5e) Ownership, Management, and/or Use of Adjacent Lands

Progressively busy roads and trails as you climb Grandfather Mountain toward the headwaters streams impact the wilderness quality downstream. While these are not present in the inventory area, they are ever present in my mind, looming above, when exploring the area.

Wilson Creek Conclusion

I would not be in support of new wilderness recommendation for the Wilson Creek area; however, I support its placement in a Management Area that maintains its roadless and natural character such as a Backcountry, Special Interest, or Special Biological Area (or part of a larger National Recreation Area).


Lost Cove

Apparent Naturalness

1a) Apparent Naturalness

This area has considerably more designated Old Growth than, for example, the nearby Harper Creek area. The stream is wild and free-flowing, with waterfalls, large boulders, exposed rock, and deep, clear pools – all consistent with a Wilderness experience. The cliff-top areas, offering views down into the cove, show almost no evidence of human impact and feel exceptionally representative of the type of wild, natural appearance I’ve come to associate with wilderness.

1c) Presence and Extent of Improvements

Logging road beds do not appear to be as numerous or prominent in this watershed on the ground than surrounding ones, with the possible exception of FS 464A which is becoming obliterated into more of a trail as it descends to the creek.

Solitude or Primitive and Unconfined Recreation

2a) Solitude

Of all the inventoried areas in the Grandfather Mountain region, Lost Cove has always felt to me like it has the greatest opportunities for solitude. Deeper ingress into the upper watershed area is difficult to downright prohibitive. The large stream in the cove makes for difficult water crossings, without many bridges, turning people back and enhancing solitude beyond them.

2b) Primitive and Unconfined Recreation

The trail network is extensive enough to allow access to the area, but there is much less “poaching” of trails by mountain bikers in this area than, say, the Harper Creek or Wilson Creek areas. While other inventory areas are easily accessed from Forest Service roads, the Lost Cove area itself feels “cut off” from the rest of the forest and is only accessible via (at least) moderate to strenuous trails on remote sections of roads, or by cross-country trekking. Most visitor traffic stays very close to these easier access points and visitors do not penetrate into the heart of the wilderness study area as frequently.

Unique and Outstanding Qualities

4b) Outstanding Scenery or Landscape Features

The watershed is lined by mountains with foreboding cliffs on 3 sides. The eponymous stream is wide and wild, with waterfalls and huge boulders.

4e) High Quality Water Resources or Important Watershed Features

Nearly the entire Lost Cove watershed is under Forest Service ownership, making its water quality during and even long after rain events visibly higher than that of nearby areas such as Upper Wilson Creek or Harper Creek.

4f) Other Unique and Outstanding Qualities

Even the area’s name itself is evocative of wilderness!

Management

5a) Size, Shape, Configuration, and Boundaries

Waterways are such a huge part of the Southern Appalachian wilderness recreation experience. Having an entire watershed above a certain point open to recreation, without impedance, is a compelling force for an area to represent wilderness. In Lost Cove, nearly the entire watershed, from headwaters near the Blue Ridge Parkway to where Lost Cove Creek exits onto private land near Edgemont, is under public ownership. There are only a few exceptions along the very spine of the ridge. The opportunity to explore almost the entire Lost Cove watershed area, from down where Lost Cove Creek appears more like a river than a creek near Hunt-Fish Falls, all the way up to the headwaters and surrounding cliff-top mountain peaks (Big & Little Lost Cove Cliffs, Timber Ridge), unimpeded all the way by human significant intrusions (including private inholdings, busy roads, or even any significant evidence of past logging or development) is extremely compelling of a wilderness recreation experience to me.

This makes the area feel more “intact” than the surrounding inventory areas, which are much more fragmented. This type of recreation is much like what can be had in Shining Rock, Middle Prong, and Southern Nantahala wilderness areas farther south where entire watersheds are contained within wilderness.

5e) Ownership, Management, and/or Use of Adjacent Lands

The only private inholdings in the watershed – which are outside the wiilderness study area – are small and high up on the watershed, around the margins of the area, and have less of an impact than they would if they were inholdings deeper inside the wilderness or watershed boundary, as in Wilson Creek and Harper Creek. Ultimately, the presence of private land on the margins of the watershed area are not a tremendous impact on the wilderness quality of the Lost Cove area, which is significant.

Lost Cove Conclusion

Of all the areas in the Grandfather Mountain/Wilson Creek area, I support Lost Cove as the best candidate area for continued wilderness recommendation.


Harper Creek

Apparent Naturalness

1a) Apparent Naturalness

While the peripheral trails are mostly on logging roads, the trails along the main stem of Harper Creek up to S. Harper Creek Falls, and along N. Harper Creek past Bard Falls and N. Harper Creek Falls pass through areas that do appear natural and unimpeded – provided that there are no water quality issues at the time.

1c) Presence and Extent of Improvements

Unfortunately there is a good bit more evidence of human intrusion into this area, including old logging road and railroad beds, some of which are appallingly eroded (such as Raider Camp).

Solitude or Primitive and Unconfined Recreation

2a) Solitude

Harper Creek has an extremely popular trailhead at Harper Creek Falls making it downright crowded most weekends all the way past the heavily used campsites up to the falls. Trash, discarded clothing, and permanently affixed ropes are common at the falls. Another area where you’re guaranteed to find company is at South Harper Creek Falls, and North Harper Creek Falls typically has at least few visitors due to its ease of access.

2b) Primitive and Unconfined Recreation

Heavy poaching by mountain bikers of almost all trails in this area is frequent. However, the presence of private in-holdings, roads, and past human intrusion is much less impactful on the experience of mountain biking than traditional wilderness recreation and I believe expansion of mountain biking opportunities in this area is appropriate.

Management

5e) Ownership, Management, and/or Use of Adjacent Lands

The upper parts of the watershed have private inholdings at Kawana and at the headwaters of North Harper Creek which are readily visible from within the inventory area and highly popular scenic areas (S. Harper Creek Falls). And it is not unusual for there to be visible water quality issues (muddy water) downstream from these, making a long and obvious human impact all the way down the stream. The headwaters of the area’s streams, which would be a natural target for exploration, are not even part of the inventory area and are relatively highly developed.

Harper Creek Conclusion

I would not be in support of continued wilderness recommendation for the Harper Creek area; rather, I support its placement in a Management Area that maintains its roadless and natural character such as a Backcountry, Special Interest, or Special Biological Area (or part of a larger National Recreation Area) but allows activities such as mountain biking.


Black Mountains

Apparent Naturalness

1a) Apparent Naturalness

The interior sections of this inventory area are so rugged and remote that the natural character is largely intact and not noticeably modified by humans at all. Areas near the very southern margin of the inventory area can experience noise intrusion from (primarily motorcycles on) the Blue Ridge Parkway and NC Hwy. 128 as it climbs to Mt. Mitchell; however, impacts are infrequent and not pervasive across the entire area.

1b) Deviations from the Natural Condition

Old logging roads, old railroad grades, and remnant clearings are present mostly in the southern part of the area. These areas have not been logged in a very long time and are reverting nicely to a natural condition. Especially north of Maple Camp Bald, there is very little evidence of deviation from the natural condition.

Solitude or Primitive and Unconfined Recreation

2a) Solitude

The steep slopes of the Black Mountains and drainage valleys below present nearly unlimited opportunities for solitude. Undocumented high waterfalls and other significant natural features that are “not on the map” so to speak lead me to believe that some of these areas haven’t been visited by humans in years. The foreboding terrain makes solitude a near guarantee within.

2b) Primitive and Unconfined Recreation

Trails in the margins of the area (Mt. Mitchell, Black Mountains Crest) and the Buncombe Horse Range trail do allow recreational users to access the area, but typically receive low usage (for areas farther from parking) which is consistent with wilderness. These trails are not used by mountain bikers or other mechanized users and wouldn’t be enjoyable for that type of use, making the issue of poaching here less concerning.

Black Mountains Conclusion

I believe the Black Mountains inventory area is a good candidate area for a new wilderness recommendation in the Pisgah National Forest and am in support of it in this area (especially north of Mt. Mitchell/Rock Creek drainage basin).


Craggy

Apparent Naturalness

1a) Apparent Naturalness

In addition to the evidence of logging from the valley floor up to the Laurel Creek Road (FS 5548) corridor, noise from the Blue Ridge Parkway (especially motorcycle noise) is present in the upper reaches of the area. Noise impacts lessen considerably north of Walker Ridge toward Corner Rock and Big Butt and deeper into the existing wilderness study area, where there is little evidence of human intrusion of any kind. Any noise intrusion drops off in areas where the most solitude can be expected, which is consistent with wilderness.

Additionally, the slopes below Brush Fence Ridge make an excellent, gradual transition from Northern Hardwood forest to the Spruce-Fir forest zone, a transition which is even less like the hard lines found in the Mount Mitchell area due to past logging activity. It is a very natural-appearing area in addition to its considerable ecological value.

Solitude or Primitive and Unconfined Recreation

Off-trail hiking is difficult yet rewarding above FS 5548 up to the Blue Ridge Parkway, and from Corner Rock up to the Big Butt trail near Little Butt/Point Misery.

2a) Solitude

The existing Wilderness Study area is an excellent opportunity to find solitude even though it is not considered very large by wilderness standards. The area is rugged and foreboding, yet still accessible via Stony Fork Road and FS 74/Douglas Falls trail. The areas in the triangle between Corner Rock, Big Butt, and Point Misery, including Locust Pen Gap, are not normally visited and also consistent with wilderness.

These experiences provide excellent opportunities for solitude and are consistent with wilderness recreation.

Visitors are far less likely to find solitude in the area downslope of FS 5548, around FS 74 and the multi-use trail network.

2b) Primitive and Unconfined Recreation

The Craggy Mountains area outside of the existing Wilderness Study Area contains an extensive network of multi-use trails, which are currently enjoyed by mountain bikers as well as other trail users.

Craggy Mountains Conclusion

Ultimately, I am in support of the plan outlined by the Friends of Big Ivy, the NC Mtn. Treasurs project, and othres: adding the area “upslope” from FS 5548 outside the existing multi-use trail network to the wilderness recommendation area. For the existing trail network and “interior” areas downhill of Laurel Gap Road, I support placement in a Management Area that maintains its natural character such as a Backcountry, Special Interest, or Special Biological Area but continues to allow mechanized activities such as mountain biking and trail maintenance with machinery.


South Mills River

Apparent Naturalness

1a) Apparent Naturalness

There are considerable traces of logging in the area west of Turkey Pen Gap (around the Mullinax and Poundingmill trails), including an obvious network of old logging roads. The road up the South Mills River is another obvious human improvement in the area.

1b) Deviations from the Natural Condition

Openings in the forest near the South Mills River trail and Mullinax trails, as well as extensive areas of young appearing forests, are enjoyable to visit, but not representative of the natural condition of the area.

1c) Presence and Extent of Improvements

The old Cantrell Creek Lodge site is present in the area and an obvious relic of human impact.

Solitude or Primitive and Unconfined Recreation

2a) Solitude

The area has high recreational use and is close to populated areas which generates high use of this area of the forest. However, solitude is achievable deeper into the area or in off-trail areas. This is more consistent with its current backcountry management status, however, than wilderness.

2b) Primitive and Unconfined Recreation

The area has an extensive network of heavily used trails, which includes mountain bike trails. These trails are very important to the mountain biking community in the region and help meet the considerable demand for this activity on the forest.

South Mills River Conclusion

I am not in support of wilderness designation in this area; rather, I support this area’s placement in a Management Area that maintains its roadless and natural character such as a Backcountry, Special Interest, or Special Biological Area (or part of a larger National Recreation Area) but allows activities such as mountain biking.


Daniel Ridge

Apparent Naturalness

1a) Apparent Naturalness

A network of old logging roads laces the southern and eastern edges of this inventory area. The impacts from past logging lessens as you move up in the watersheds; however, overall, the inventory area feels more consistent with backcountry than wilderness.

Solitude or Primitive and Unconfined Recreation

2a) Solitude

The area has high recreational use and is close to populated areas which generates high use of this area of the forest.

2b) Primitive and Unconfined Recreation

The area has an extensive network of heavily used trails, which includes mountain bike trails. These trails are very important to the mountain biking community in the region and help meet the considerable demand for this activity on the forest.

Unique and Outstanding Qualities

4c) Structures, Dwellings, Sites or Other Remnants of Past Occupation

Old power poles and lines follow the Davidson River along the Daniel Ridge trail; there are also remains of the old fish hatchery in this area. Invasives are present along this corridor as well.

Daniel Ridge Conclusion

I am not in support of wilderness designation in this inventory area; rather, I support recognizing this area’s natural character, outstanding recreation and scenic qualities, and biological importance by placing it into a management area such as a Backcountry, Special Interest, or Special Biological Area (or part of a larger National Recreation Area) that does this but allows activities such as mountain biking.


Laurel Mountain

Apparent Naturalness

1a) Apparent Naturalness

Higher elevations in the Laurel Mountain area are good representations of the natural condition of the uncommon high-elevation environment and, as such, should be preserved.

Solitude or Primitive and Unconfined Recreation

2a) Solitude

The area has high recreational use and is close to populated areas which generates high use of this area of the forest. While solitude can be found deeper into the area or, of course, off-trail, the usage pattern is more closely aligned with Backcountry designation than wilderness. In areas where more solitude can be found (especially upper Big Creek), noise from the Parkway begins to intrude.

2b) Primitive and Unconfined Recreation

The area has an extensive network of heavily used and regionally important trails, which includes mountain bike trails. These trails help meet the considerable demand for mountain biking on the forest.

Unique and Outstanding Qualities

4b) Outstanding Scenery or Landscape Features

Pilot Rock is the dominant scenic feature in the area and it is regionally significant. The upper Big Creek watershed is pristine, roadless, and representative of some of the higher quality watersheds in the region. As such, it should be protected – but alone, may not be sufficient for wilderness designation.

Management

5e) Ownership, Management, and/or Use of Adjacent Lands

The Blue Ridge Parkway runs along the edge of this area. This stretch of the Parkway, as it provides access to the Pisgah Inn, is very busy and, as such, noise (especially motorcycles) from the roadway can intrude into the inventory area – unfortunately, into many of the same area where the most solitude can be found.

5f) Other Management

I am not in support of wilderness designation in this area; rather, I support this area’s placement in a Management Area that maintains its roadless and natural character such as a Backcountry, Special Interest, or Special Biological Area (or part of a larger National Recreation Area) that does this but allows activities such as mountain biking.


Cedar Rock Mountain

Apparent Naturalness

1a) Apparent Naturalness

This area contains a variety of old logging roads around all of its boundaries. The older, non-inventoried roads are recovering well but still obvious signs of human impact.

1b) Deviations from the Natural Condition

The Picklesimer Fields area is an unusual open bottomland area which is a fairly obvious sign of prior human occupation; there are also white pine plantations in the area that – while inviting – do not appear natural.

Solitude or Primitive and Unconfined Recreation

2a) Solitude

The area has high recreational use and is close to populated areas which generates high use of this area of the forest.

2b) Primitive and Unconfined Recreation

The area has an extensive network of heavily used trails, which includes mountain bike trails. These trails are important to the region and help meet the considerable demand for this activity on the forest.

Unique and Outstanding Qualities

4a) Rare Plant or Animal Communities or Ecosystems

4b) Outstanding Scenery or Landscape Features

In particular, John Rock and Cedar Rock Mountain, as well as the waterfalls on Cedar Rock Creek and beside the Butter Gap trail are exceptionally scenic, even if not entirely absent from signs of human impact. This makes the area feel more consistent with backcountry rather than wilderness, but deserved of protections from timber management in the future and recognition for their outstanding value to the region.

4c) Structures, Dwellings, Sites or Other Remnants of Past Occupation

The Picklesimer Fields area is an unusual open bottomland area which is a fairly obvious sign of prior human occupation; there are also white pine plantations in the area that – while inviting – do not appear natural and show that the area was occupied in the past.

Cedar Rock Mountain Conclusion

I am not in support of wilderness designation in this inventory area; rather, I support recognizing this area’s natural character, outstanding recreation and scenic qualities, and biological importance by placing it into a management area such as a Backcountry, Special Interest, or Special Biological Area (or part of a larger National Recreation Area) that does this but allows activities such as mountain biking.


Shining Rock Extensions

Apparent Naturalness

1b) Deviations from the Natural Condition

The Graveyard Ridge and Black Balsam areas are largely denuded and very unusual for the area. A large plantation of spruce trees exists between Black Balsam and south of the Flat Laurel Creek trail which – although beautiful – is uniform and unnatural looking. Although these areas are beautiful and harbor some fantastic, fragile natural habitats which are indeed recovering from past abuses, they are hardly representative of the original natural condition of the area.

1c) Presence and Extent of Improvements

Black Balsam is a developed trailhead with paved parking, restroom facilities, and extensive signage. This road penetrates into the area considered for extension and in fact splits the area in two.

Solitude or Primitive and Unconfined Recreation

2a) Solitude

There should be no expectation for solitude anywhere near Graveyard Fields or the south side of Graveyard Ridge. On the contrary, this area is one of the most heavily used in all of the Forest during the warmer months. The openness of the land is inviting to off-trail exploration, and even those areas are not free from frequent visitors. The situation around Black Balsam, to Sam Knob, down Flat Laurel Creek or the Mountains to Sea Trail to NC Hwy. 215, and indeed even reaching beyond Ivestor gap into the existing wilderness is very heavily traveled. This is not the area one looks to find solitude.

The existing Shining Rock wilderness area, by contrast, provides some excellent opportunities for solitude especially deeper within the area, but the above-mentioned areas provide a good buffer against the already-designated wilderness, proving out the forethought of those who designated those areas originally.

2b) Primitive and Unconfined Recreation

An extensive network of old logging road and railroad grades, some of which are maintained as open to vehicles (Ivestor Gap) and mountain bikes (Ivestor Gap and Flat Laurel Creek) wrap around the mountains in this area. These uses of the area, which are critical and should be allowed to continue, are not consistent with wilderness.

Unique and Outstanding Qualities

4f) Other Unique and Outstanding Qualities

Despite these apparent preclusions to becoming wilderness, the areas inventoried for the Shining Rock Extensions are indescribably unique, scenic, and valuable to the region. Yet they are very fragile habitats, owing to the abuse the area has received in the past. As such, this area should be protected from extractive use and managed as backcountry as it is now.

Management

5e) Ownership, Management, and/or Use of Adjacent Lands

The Blue Ridge Parkway borders the Graveyard Fields/Graveyard Ridge area, and a near-continuous cacophony of noise (especially from motorcycles) pervades across the entire upper Yellowstone Prong valley when the road is open. Its impact wanes approximately along the spine of Graveyard Ridge, making everything north of that (e.g the Dark Prong drainage) a good candidate for additional wilderness acreage in this regard.

Shining Rock Extensions Conclusion

I am not in support of wilderness designation in most of this inventory area; rather, I support this area’s placement in a Management Area that maintains its roadless and natural character such as a Backcountry, Special Interest, or Special Biological Area (or part of a larger National Recreation Area) but allows activities such as mountain biking.

An extension of the existing boundaries to include the Dark Cove drainage up to the Mountains to Sea Trail along Graveyard Ridge would be appropriate, as would the inclusion of the Wash Creek and Sam Branch drainages up to the summit of Sam Knob, and also the Middle Prong Addition, expanding the acreage available to wilderness recreation in the existing areas without including all of the inventoried land.


Panthertown Valley

Apparent Naturalness

1c) Presence and Extent of Improvements

The area abuts a utility transmission line. While the presence of this line doesn’t necessarily degrade the recreational value of the area, and can even have only marginal impact on the special ecology of the area, it doesn’t smack of wilderness. The lines are visible from many points inside the inventory area.

1d) Other Apparent Naturalness

Solitude or Primitive and Unconfined Recreation

2a) Solitude

There should be no expectation for solitude anywhere within Panthertown Valley, with the possible exception of some far off-trail corners of the area. Even outside the designated trail area, a vast network of smaller trails supports human ingress into the area.

The area has high recreational use and is close to populated areas which generates high use of this area of the forest.

2b) Primitive and Unconfined Recreation

An extensive network of old logging road grades, some of which are maintained as open to vehicles, wind around in this area. These uses of the area, which should be allowed to continue, are not consistent with wilderness.

The area has an extensive network of heavily used trails, which includes recently designated mountain bike trails. These trails are an important addition to the supply of mountain biking trails in the region and help meet the considerable demand for this activity on the forest.

Stand-alone Area of less than 5,000 Acres

3a) Sufficient Size for Wilderness

The area is probably barely big enough for wilderness qualities on its own if it were not for the other mitigating factors present here. However, the smallish size combined with the other mitigating factors make it unsuitable for wilderness.

Unique and Outstanding Qualities

4b) Outstanding Scenery or Landscape Features

The Panthertown Valley is known, perhaps in delusions of grandeur, to be called the Yosemite of the East. Nevertheless, it is full of absolutely stunning and uncommon natural features, including waterfalls, lazy streams in flat valley bottoms, sheer granite cliffs, and intact forests, which should be recognized and protected from extractive activities.

Management

5a) Size, Shape, Configuration, and Boundaries

The presence of the power lines in the area is problematic, because established recreational trails in the area wind around beneath them without much regard to their placement and without much impact from their presence; however, this makes establishing the wilderness boundary tricky as users would wind in and out of wilderness as they traveled.

Panthertown Valley Conclusion

I am not in support of wilderness designation in this inventory area; rather, I support recognizing this area’s natural character, outstanding recreation and scenic qualities, and biological importance by placing it into a management area such as a Backcountry, Special Interest, or Special Biological Area (or part of a larger National Recreation Area) that does this but allows activities such as mountain biking.


General Comments

Additionally, I would like to submit the following general comments which apply to all areas in the wilderness inventory.

  • The areas inventoried for this evaluation correspond well with the last remaining intact, robust, diverse, and wild publicly-owned forest land in the southern Appalachian Mountains, and in the eastern United States in general.
  • Regardless of whether they are recommended for Wilderness, all of the inventoried areas – which align closely to NC Mountain Treasure Areas – should be placed in a Management Area that maintains their roadless and natural character such as a Backcountry, Special Interest, or Special Biological Area. None of the inventoried areas should ever again be considered suitable for Timber Production and road building through a change in management area designation.
  • All natural heritage areas identified by the North Carolina Natural Heritage Program should be placed in Management Areas unsuitable for timber production in perpetuity.
  • Areas adjoining the inventory boundaries that are either acquired by the Forest Service in the future or are “aged out” from the most recent timber management activities and revert to a more natural state than they are currently in should be similarly managed.
  • The impact from dead trees resulting from Balsam and Hemlock Wooly Adelgid infestations is present forest-wide, is widespread across the southern Appalachians, and should not be considered to be against an area’s wilderness potential.
  • However, stands of living Hemlock that remain as a result of active management practices not compatible with wilderness are valuable, and that should be taken into consideration if recommendation for wilderness would restrict those management practices.
  • No areas that currently contain designated mountain bike trails should be recommended for wilderness.

Sincerely,
Jordan Mitchell
WNCOutdoors.info
Asheville, NC
jordan@wncoutdoors.info

Leave a Reply