SEPA
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
EPA 910/9-85-126
APRIL 1985
OFFICE OF RESEARCH AND DEVELOPMENT
401 M STREET, S.W.
WASHINGTON, D.C. 20460
REGION 10
1200 SIXTH AVENUE
SEATTLE, WA 98101
National Surface Water Survey
Western Wilderness Area Lakes
ENVIRONMENTAL
ASSESSMENT
DISTRIBUTION OF LAKES TO BE SAI
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EPA 910/9-85-126
NATIONAL SURFACE WATER SURVEY
WESTERN WILDERNESS AREA LAKES
ENVIRONMENTAL ASSESSMENT
April 1985
RESPONSIBLE OFFICIALS:
Bernard D. Goldstein Ernesta B. Barnes
Assistant Administrator for Regional Administrator
Research and Development U.S. Environmental Protection Agency
U.S. Environmental Protection Agency Region 10
401 M Street, S.W. 1200 Sixth Avenue
Washington, D.C. 20460 Seattle, WA 98101
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CONTENTS
Page
PREFACE iv
SUMMARY AND CONCLUSIONS v
APPENDIX E SUPPLEMENTARY INFORMATION AND ANALYSIS E-l
E.I. AN EVALUATION OF THE POTENTIAL FOR TWO ALTERNATIVE E-2
METHODS OF SAMPLING/CHEMICAL ANALYSIS TO BE "SIMILAR"
E.2. RANDOMNESS OF SAMPLING E-7
E.3. SAMPLING SCHEDULE FOR EACH SUBREGION E-10
E.4. ACCESSIBILITY OF LAKES UNDER ALTERNATIVE 3 E-ll
E.5. ATMOSPHERIC EMISSIONS OF HELICOPTER ENGINES E-12
E.6. COORDINATION AND PLANNING ACTIVITIES E-13
E.7. ALTERNATIVE CONSIDERED BUT NOT ANALYZED E-15
E.8. ERRATA FOR THE DRAFT EA E-16
APPENDIX F RESPONSIVENESS SUMMARY F-l
F.I. LIST OF COMMENTS F-2
F.2. COMMENT LETTERS SUBMITTED ON THE DRAFT EA F-3
F.3. RESPONSE TO COMMENTS F-34
APPENDIX G PUBLIC INVOLVEMENT PLAN G-l
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PREFACE
This Environmental Assessment (EA) has been prepared by the U.S.
Environmental Protection Agency (EPA) under the National Environmental Policy Act
of 1969 to evaluate the environmental consequences of sampling lakes in federally
designated wilderness areas in the West. The proposed sampling would be done as
part of the National Surface Water Survey. The EA evaluates various alternatives for
gaining access to wilderness areas, including: Alternative 1 - access by helicopter
only; Alternative 2 - access by ground; Alternative 3 - access by a combination of
helicopter and ground; and Alternative 4 - no sampling of wilderness area lakes. With
respect to Alternative 1 and 3, the EA also addresses the concerns of the U.S. Forest
Service and the National Park Service about the use of helicopters under the strict
limitations of the Wilderness Act of 1964.
The present document modifies and supplements the Draft EA which was
distributed for public comment in March 1985. The present document contains the
following sections:
1. A revised Summary and Conclusions which incorporates changes in
response to government agency and public comment;
2. Supplementary analysis that has been developed in response to
government agency and public comment;
3. Errata, giving changes of text of Draft EA;
4. Comments on the Draft EA and EPA responses; and
5. A public involvement plan.
References to the EA in this document refer to the Draft EA and revisions
included with the present document. Copies of the March 1985 Draft EA can be
obtained by request at the following address:
Wayne D. Elson
EA Project Officer, M/S 443
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Telephone: (206) 442-1463
(FTS) 399-1463
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SUMMARY AND CONCLUSIONS
PURPOSE AND NEED
The U.S. Environmental Protection Agency (EPA) is proposing to sample 498
lakes in federally designated wilderness areas and national parks during the western
part of the National Surface Water Survey (NSWS). The NSWS is a key component of
a Congressionally mandated national effort to evaluate the extent of aquatic
resources sensitive to acidic deposition and to assess the environmental, social, and
economic effects on these resources.
Sampling protocols established for the national survey call for the use of
helicopters to gain access to lakes. The Wilderness Act of 1964 severely limits the
use of helicopters and other mechanized equipment in wilderness areas. However,
there are two relevant exceptions in the Act under which the Forest Service (FS) and
National Park Service (NPS) might permit authorization of EPA's proposed helicopter
use:
1. Helicopter entry may be authorized if such entry is necessary to
meet minimum requirements for administration of the wilderness
areas [Sec. 4(c)]; and,
2. Helicopters may be used for the purposes of gathering information
about resources if helicopter operations are carried on in a manner
compatible with preservation of the wilderness environment
[Sec. 4(d)(2)].
As the agencies responsible for managing the wilderness areas involved, the FS
and NPS will determine whether an exception to the Wilderness Act's general
prohibition of helicopter use applies. Thus, the FS and NPS can grant permission to
EPA to carry out the lake survey if either of two findings can be made:
1. Helicopter access to acquire information to be used to assess the
extent of acidic deposition, to develop baseline data, and to
contribute to programs for controlling acidic deposition is necessary
to meet minimum requirements for the administration of the
wilderness areas; or
2. Helicopter access as proposed by EPA for the purpose of gathering
information about natural resources is carried on in a manner
compatible with the preservation of the wilderness environment.
EPA has prepared this Environmental Assessment (EA) to evaluate the
environmental consequences of alternative means of gaining access to wilderness
areas to meet the objectives of the NSWS. This assessment is being provided to the
FS and the NPS.
The NSWS is part of the Interagency Federal program on acidic deposition
(NAPAP). Under this program the aquatic effects task group has three major
objectives:
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o quantification of the extent of acidification and sensitivity of lakes,
streams, and groundwaters;
o identification, quantification and predictive modelling of the factors
that control the susceptibility of surface waters to acidification;
o determination of the relationships between surface water chemistry
and aquatic biota.
The NSWS consists of three phases designed to contribute data for the Federal
Interagency Task Force to be used in assessments submitted to Congress: Phase [ is
designed to quantify the regional chemistry of lakes and streams throughout the
United States, with a focus on areas now believed to contain the majority of low
alkalinity waters; Phase II will quantify the biological components and temporal
variability of water chemistry within and among regionally representative lakes and
streams, as determined in Phase I, and Phase III will initiate long-term monitoring of
lakes and streams representative of major geographic regions of the United States.
This EA is concerned only with Phase I of the NSWS except as it relates to selecting
lakes for Phases II and III. EPA contemplates no need for using mechanized access or
structures in wilderness during Phases II and III of the survey.
The primary objectives of the Phase I survey are to determine:
1. what percent (number, area) of lakes in regions of the United States
potentially sensitive to acidic deposition are acidic (have pH values
less than 5.0);
2. what percent (number, area) of lakes in regions of the United States
potentially sensitive to acidic deposition have low alkalinity, and
what is the distribution of alkalinity values;
3. what is the chemical composition of lakes in regions of the United
States potentially sensitive to acidic deposition; and
4. what lakes are regionally representative and should be selected for
study in Phases II and III.
The Phase I portion of the NSWS was completed for 2046 lakes in the eastern
and midwestern portions of the United States during the fall of 1984. In these
regions, lakes were sampled by helicopter. The continuation of the NSWS on 888
western lakes, of which 425 fall within wilderness boundaries, is proposed for the fall
of 1985 and will complete the Phase I effort. Field sampling is scheduled to occur
during the fall because mixing of the lakes at that time will minimize seasonal and
spatial variability of lake chemistry and maximize comparison between lakes.
It is critical that a national survey of surface waters develop data on the entire
geographic distribution of vulnerable surface waters within each region because (1)
the potential consequences of emission- control policy decisions are national in scope
and (2) long-range transport of pollutants can result in impacts remote from the
emission sources. As a result of the distribution of lakes in the West, sampling within
the boundaries of wilderness areas is necessary to preserve the geographic coverage
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of the survey. This is especially true because the majority of lakes of the greatest
susceptibility (lowest alkalinities) occur in the wilderness areas. Phase I is an
essential first step in the NSWS, and has been statistically designed with the
objectives listed above to address key questions posed by policy and assessment
staff. An important consideration in designing Phase I has been to ensure that the
data collected are of sufficiently high quality to serve as a basis for choosing
representative sites for Phases II and III.
The variables, analytical methods, and sampling protocols proposed for the
NSWS (and used in the East in 1984) were critically reviewed by, and developed with
concurrence of environmental scientists and analytical chemists from a variety of
U.S. and Canadian institutions including the USGS, Illinois State Water Survey,
universities, and consulting firms (USEPA I984b,c). The chemical variables chosen, as
well as color and turbidity, were selected as the minimum number to be measured to
evaluate adequately the present status of future effects on sensitive lakes. The
selection of specific methods was governed primarily by requirements for low
minimum detection Limits, necessarily low due to the nature of the most sensitive
lakes, which characteristically have very low concentrations of the constituents of
interest in this study.
Survey data are not being collected directly for regulatory purposes, but rather,
to document the extent and distribution of sensitive and already acidic systems. EPA
needs high quality data to ensure that future policy is based on a sound, scientifically
defensible position. The adequacy of the data for a given objective is a scientific
judgment which is necessarily subjective. EPA has determined the necessary quality
of data by communicating directly with all primary data users and by subjecting the
NSWS design to extensive peer review by experts in the field of acidic deposition.
The quality of data is not a legal issue at this time; however, it will underpin future
policy decisions and possibly regulatory actions.
From the standpoint of timely development of acid rain policy, it is of extreme
Importance that the current status of all potentially sensitive United States surface
waters is understood. Until recently acid rain policy analysis has focused primarily
upon the need for protecting eastern surface waters.
This focus resulted from the recognition that the northeastern U.S. contained
potentially sensitive areas downwind from the areas of highest emission density. It is
recognized that portions of the mountainous West are also potentially sensitive to
acidic deposition. However, the absence of emission densities of the magnitude of
those found in the Midwest and a less certain source-receptor relationship resulted in
a general perception that acidic deposition was of less serious concern in the West.
Recent reports from the Environmental Defense Fund and the World Resource
Institute have argued that existing emissions sources do pose a threat to sensitive
areas in the West. The arguments put forth are primarily based upon emissions and
deposition data and not upon observed effects on surface waters. The quickest and
most definitive way to evaluate the seriousness of this concern is to carry out a
systematic survey of sensitive surface waters in the West. However, to effectively
incorporate the West into the development of national acid rain policy and acid rain
research planning, it would be necessary that a western survey parallel the existing
survey, both in terms of its timeliness and the comparability of data. To delay the
collection of these data to the fall of 1986 or later would seriously hamper the
development of a comprehensive acid rain policy and the coordinated planning of acid
rain research.
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Without quantitative, empirical data on acidification of western surface waters,
EPA would not be in a position to consider the need for emission reductions in the
West for the purpose of protecting western sensitive areas. This would mean, if
damage is occurring, that a direct consequence of deferring its detection would be to
defer the initiation of appropriate actions to halt or reverse this damage. The
Administration has chosen to defer a decision on the need for additional controls on
sulfur oxides pending additional scientific information. Both Congress and the
Administration are working to find as expeditious a solution to the acidic deposition
problem as scientific understanding will allow. An empirical understanding of the
status of western lakes is critical for forming a national view of the acid deposition
problem.
The Wilderness Act (1964) gives the FS responsibility to protect the wilderness
resource on National Forest System lands from man-caused degradation. However, in
response to air pollution, action under the Wilderness Act could probably be taken
only after an impact on the Wilderness has occurred and consequences may be
difficult to reverse once detected.
The 1977 Amendment to the Clean Air Act established an air quality program,
Prevention of Significant Deterioration (PSD), which is designed to maintain air
quality in those portions of the country where the air is cleaner than that which is
required to protect public health.
Included in the PSD program are the following:
1. The establishment of certain national parks and wilderness areas as
Class I areas.
2. The establishment of a permitting process that requires certain new
sources of air pollution to obtain PSD permit before construction
and operation.
3. The establishment of small incremental limits or the amount of
sulfur dioxide (SO2) and total suspended particulates (TSP) that,
except under certain circumstances, permitted new sources can add
to Class I areas.
4. The requirement that the federal land manager take an affirmative
responsibility to protect air quality related values (AQRVs) in Class
I areas from adverse impacts caused by air pollution. Such action
may result in denial of a PSD permit.
5. The establishment of a system which may allow the exceedence of
Class I increments if a new air pollution source can demonstrate to
the satisfaction of the federal land manager that there will be no
adverse impact on air quality related values.
The only AQRV identified in the Clean Air Act is visibility. However, other
AWRVs identified by the FS are flora, fauna, soil, water, odor, cultural, archeological
and geological features.
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ALTERNATIVES
Four alternatives are evaluated in the EA: (1) access by helicopter to all
wilderness lakes to be sampled, (2) access by horseback or foot to all wilderness area
lakes to be sampled, (3) access by helicopter or ground (the mix to be determined by a
maximum 7 h transport time from the lake to a helicopter landing site outside the
wilderness), and (4) no sampling of wilderness area lakes in the study (i.e., the no
action alternative).
Alternative I would involve using sampling protocols developed for the NSWS
and already used successfully in completing the survey in the upper Midwest, the
Northeast, and the Southeast. Helicopters would fly to each lake, land on the lake to
obtain a water sample (a process taking approximately 20 min.), and then proceed to
the next lake or return to a field base laboratory. All samples would be analyzed and
processed for shipment to an analytical laboratory for further analyses by methods
identical to those used in the East.
Alternative 2 would involve horse or foot access to all lakes to be sampled.
With horse access, sampling crews of four people (two samplers, a wrangler/guide,
and at least one rider to transport the samples) and eight animals (four riding horses
and four pack animals) would be used. If access by foot were to be used, a crew of at
least four people would be needed for packing the sampling and camping equipment.
Additional people (total 6 to 8) would be needed for transporting the samples out of
the wilderness area. Samples would be collected using an inflatable boat. All
chemical variables measured for Alternative 1 would also be measured under this
alternative, but NSWS sampling protocols would be modified in that samples would be
filtered and processed for transport at the site of collection to reduce time
constraints. A pilot study to determine comparability of data gathered by ground vs
by helicopter would be completed for this alternative. Samples would be transported
to the field base laboratory.
Alternative 3 would involve horse or foot access to lakes within wilderness
areas from which samples could be transported to a helicopter landing site within
seven hours. Samples would be collected from an inflatable boat as in Alternative 2,
but would then be transported immediately to a landing site so that they would arrive
at the field base laboratory in time to be processed within a 12 h time limit (i.e.,
samples would have to be transported to a helicopter landing site within 7 h; a
transport time in the helicopter of 1 h is assumed; processing time in the field base
laboratory would take 4 h). All chemical variables would be measured as in
Alternative 1. Helicopters would be used for gaining access to all lakes where
distance or difficulty of access by other means would prevent samples from being
transported to a helicopter landing site within the required 7 h. Helicopters might
also be used as a last resort for some closer lakes if weather prevented ground access.
Alternative 4 is the no action alternative. No lakes would be sampled within
wilderness area boundaries. Helicopters could be used to sample randomly selected
lakes outside wilderness areas as was done in the eastern and midwestern portions of
the NSWS, but results would not be applicable to wilderness areas because a
significant portion of the West and areas of greatest susceptibility would not be
sampled.
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AFFECTED ENVIRONMENT
Of the 888 lakes randomly selected for sampling in the West, approximately 425
are located in federally designated wilderness areas and 73 are located within
national park areas that are not presently designated as wilderness. Nine additional
lakes are located in a roadless area on the Wind River Indian Reservation in Wyoming.
Large portions of the national parks included in the survey are currently
proposed wilderness and are managed as wilderness until a final decision is reached on
their designation. Because entry into wilderness areas on Indian Reservations is
controlled by Native Americans (25 CFR 265), any entry onto tribal lands for the
purposes of this study must be approved by the appropriate tribe.
Wilderness areas have been established under the Wilderness Act of 1964
(P. L. 88-577) and related legislation as part of a National Wilderness Preservation
System. The primary reason the National Wilderness Preservation System was
established was to preserve an enduring wilderness resource characterized by
naturalness and outstanding opportunities for solitude. While permitted, primitive
recreation is constrained by the primary purpose of wilderness preservation. These
areas are to be devoted "to public purposes of recreational, scenic, scientific,
educational, conservation, and historical use." Wilderness values related to
preservation of wilderness character and its solitude are of great importance.
Wilderness uses include backpacking, fishing, hunting, and other activities.
Biological resources in wilderness areas and national parks include a wide
variety of plant and animal life. Typical wildlife includes large mammals such as the
black bear, cougar, elk, deer, moose, mountain goat, and mountain sheep, and smaller
mammals such as the bobcat, mink, and raccoon. Sport fish such as the rainbow,
golden, brook, and cutthroat trout, and chinook salmon are present in certain areas.
Endangered species that may be present in or near these areas include the
woodland caribou, gray wolf, bald eagle, whooping crane, American peregrine falcon,
and Kendall Warm Springs dace. Threatened species include the Arctic peregrine
falcon, grizzly bear, Paiute cutthroat trout, Greenback cutthroat trout, and Little
Kern golden trout.
ENVIRONMENTAL CONSEQUENCES
Environmental consequences of the four alternatives are considered in terms of
(1) potential environmental impacts on the existing wilderness environment and (2)
potential effects on the objectives of the NSWS, which have been developed to obtain
data for evaluating the impacts of present and potential future acidic deposition.
Environmental Impacts
Alternative 1 (Helicopter access only)
Wilderness values. Impacts on wilderness values are assessed from three
perspectives: experiential, mental and moral restoration, and scientific. Only the
first two (experiential and mental and moral restoration) are likely to be affected if
Alternative 1 were selected.
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In terms of experiential values, the chief impacts associated with the various
western wilderness areas would likely accrue from a public more concerned with the
fact of an intrusion than with the specifics of the reasons for the intrusion. The
enjoyment of nature is the primary value in the wilderness experience. The aesthetic
benefit believed to be derived from enjoying nature is the highest benefit identified
in psychological studies of the motivations people have for visiting wilderness areas.
That the visual and audible presence of a helicopter would be incompatible with
visitors' expectations of the aesthetic quality of a wilderness is clear.
The proposed use of helicopters as EPA's preferred sampling access technique
(Alternative 1), or in combination with ground-access sampling (Alternative 3), is
predicated on the concept that long-term wilderness values are sufficiently
threatened by acidic deposition (to natural ecosystems) to justify the temporary
intrusion into wilderness by mechanized equipment. Exemptions of normal
restrictions on mechanized equipment could be made so that at a later date
wilderness values could be protected and enhanced in a totally natural way. Further,
use of helicopters would be in the fall, after the peak usage period.
In terms of mental and moral restoration, the proposed use of helicopters would
cause impacts, generally transitory, to the sense of solitude and the opportunities it
affords for restoration. Besides the noise, sight, and possibly, the blade blast of the
helicopter, the occurrence of an activity (which was believed to be unauthorized)
could be most disconcerting.
Wilderness' lack of discrepant and distracting influences is one of the principal
reasons for its remarkable capacity to support the restorative experience. A
temporary helicopter intrusion would have a negative effect on the sense of
tranquility and compatibility with wilderness expectations. This experience could
destroy the opportunity for reflection and integration.
To the majority of wilderness users who can visit for only a brief time (1-2 d),
the intrusion of a helicopter could be more of an irritant than a threat to a deeper
psychological experience. The two types of impact, while different in kind, could be
comparable in the degree of negative effect on the wilderness experience.
Potential scientific values would remain unchanged because the proposed action
would in all probability leave no physical changes to the wilderness (landing only on
water) and would have only a transitory impact on wildlife due to the helicopters'
noise and appearance. In terms of scientific values, the proposed survey is in keeping
with the spirit of the Wilderness Act in that it would use the wilderness as a
barometer, or yardstick, to further understanding of the threats of acidic deposition.
The survey would contribute baseline data for the management of wilderness areas.
The foremost value in wilderness management is taking those actions that preserve
wilderness character, and that maintain the integrity of the wilderness. To the
extent that other alternatives cannot meet the timing needs and quality guidelines of
the lake survey, Alternative 1 could be in keeping with the spirit of the Wilderness
Act.
EPA recognizes that the NSWS request could be considered as a precedent for
using helicopters for planned research in wilderness areas. If the FS and NPS allow
helicopter use, their decision will clearly document the criteria, thus limiting any
interpretation of precedence.
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Wilderness use. All recreational uses of wilderness areas will be affected by
the noise of the helicopters used in the proposed action. Helicopters are comparable
in sound level to heavy trucks and city buses. Helicopter sounds are different in
character, however, from other modes of transportation. Takeoff, landing, and
flyover each have a different combination and intensity of sound. A typical
wilderness might have ambient noise levels in the range of 10 to 30 dBA. The loudest
noise from the proposed helicopter use would be approximately 90 dBA at landing on
the lake surface at about 500 ft. from an observer on shore. A typical wilderness
visitor at a lakeshore would first hear the sounds of a helicopter approaching from a
level flyover altitude of 2000 ft. Exact data are unavailable on the intensity of this
sound, but it would likely be in the vicinity of 40 dBA. As the helicopter lands, the
sound intensity to an observer located 500 ft. from the deepest point of the lake
would increase to approximately 80-90 dBA. While on the water during the sampling
(15-20 min), helicopter sound intensities would range from 56-66 dBA if a reduced
engine-idle speed could be maintained or 66-74 dBA if full engine idle speed were
necessary. Takeoff sound intensities would decrease with ascent from 83 dBA to the
intensities of the level flyover (40 dBA and less) as the helicopter flew from the area.
The dominant impacts of the proposed helicopter sampling associated with
recreational activities would be the sight and sound of the helicopters either landing
and doing the sampling or flying overhead (or both). The impact on those who make
the effort to get off the formal trail system and "away" would presumably be
substantially greater than to those who follow established trails. Those wilderness
visitors who have chosen a time of the week and time of the year when one might
expect more solitude and tranquility could also experience a substantial sense of
intrusion. The flightpaths of the helicopter overflights could be sensitively planned in
many areas to avoid many wilderness users. Recreational users may frequently be
present at camp sites which are highly clustered near lakes. The helicopters would
unavoidably encounter recreational users because lakes are EPA's focus of interest.
Impacts at campsites would be more disruptive than on trails, and impacts in remote.
internal locations could be the greatest, despite their location. To some visitors the
mere awareness of helicopter noise, no matter at what distance, would be a negative
wilderness experience.
The most serious impact to fishing as a recreational activity would be the
impact on the aesthetic dimension of the fishing experience. The proposed helicopter
use involves sampling away from the shoreline at the deepest point in each lake and
would have minimal impact on fishing potential on a given day.
Hunting for some species (such as bighorn sheep or mountain goats) is
essentially wilderness-dependent because these species are found generally only in
such areas. For other species, such as deer or elk, that are not so
wilderness-dependent, hunters may nevertheless seek out wilderness settings as being
most desirable for their activity. Popular big game species such as bighorn sheep and
mountain goats are creatures of quite predictable habits. If they are startled by the
sight and sounds of the proposed helicopter use, the fright response would be
temporary. Studies show that such animals can be readily tracked (by experienced
hunters) after such a disruption; presumably, therefore, the hunt could be resumed in
a timely way. In addition, it is anticipated that reduced visitation in the fall would
result in fewer users being affected by the helicopters than during more popular
hiking and camping seasons. On the other hand, for those people visiting wilderness
specifically for more solitude and remoteness, the helicopter's presence would be a
significant intrusion.
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Wildlife. The only likely adverse impact on wildlife associated with the use of
helicopters would be the effects of noise. Most noise effects, however, have to do
with long-term exposure to relatively high levels and the consequent permanent
effects on health, physiology, or behavior. In the present case, the only probable
effect of one or, at most, several overflights by helicopters would be a startle or
fright response. Except in the relatively unlikely event of an accident suffered by a
frightened animal, such impacts would be minor and transitory.
Endangered and threatened species. Potential impacts of helicopter use on
endangered and threatened species are the same as for other wildlife, but are of
greater concern because populations of these species may be particularly susceptible
to damage. Thus, noise from helicopters during nesting seasons of bald eagles or
staging of whooping cranes, for example, could disrupt these critical reproductive
activities and contribute to threats to the species' continued existence. The timing
and nature of the proposed activity under this alternative, however, make significant
impacts to endangered species very unlikely. Possible exceptions are where lakes are
near eagle or falcon sites. Ground access would be preferable in these situations
because juveniles may remain in the nest area during the postfledging period. Close
coordination with wildlife officials would help minimize any problems.
Even though four endangered or threatened fish species (a dace and three trout
species) may be found in or near wilderness areas to be sampled in the NSWS, no
adverse effects would be expected except in the unlikely event of a large accidental
fuel spill into a small water body containing the species.
Water bodies. The major potential source of environmental impact to water
bodies would be a spill or leak of fuel from the helicopters into the lakes being
sampled. Leaks of hydraulic fluid and spills of other materials (e.g., pH standard
solutions, freeze-gel packs) could also occur. For all but the smallest water bodies
that could be encountered, no significant toxic effects would be expected, but a
temporary visible sheen might result from any hydrocarbon spill or leak.
Human safety. The major safety concern with using helicopters would be an
accident that resulted in death or serious injury to a member of the helicopter crew.
The high altitudes and mountainous terrain associated with the proposed helicopter
use involve dangerous flying conditions. Unpredictable downdrafts or tailwinds can
be caused by sharp changes in the terrain and sudden changes in weather. Takeoffs
and landings become much more demanding than in level-terrain, low-altitude
flying. In the unlikely event of an accident during the proposed NSWS survey, a chain
of other impacts involving search and rescue and salvage operations would begin and
could involve dangerous mountain rescues by helicopters and/or climbers; there is
also the possibility of a forest fire caused by a crash. Using an estimated total flight
exposure for Alternative 1 of less than 1000 h, data suggests that the chance of an
accident occurring during the survey would be 0.1 accident per 1000 h.
An additional consideration in regard to human safety is the potential for a
helicopter to scare a horse and injure a rider, although a vigorous program of
notification can minimize this potential problem.
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Mitigation measures. To ensure that impacts to wilderness areas are
minimized, EPA Base Coordinators would work closely with local FS, NFS, and Indian
tribal land managers to identify lake-specific concerns. Specific mitigation measures
would be developed in consultation with the land managers. These would include, but
not be limited to, informing the public about NSWS activities in wilderness areas,
using pilots experienced in flying in high altitude, mountainous terrain, adopting the
"Fly Neighborly" program to reduce noise impacts, adjusting flight schedules to avoid
times of the week (e.g., weekends) or day when high visitor use is anticipated,
planning and scheduling flights to avoid sensitive wildlife habitat or activities (e.g.,
staging areas of whooping cranes), and avoiding areas during scheduled special hunts.
Notification about the possibility of helicopter noise intrusion would be given to users
to minimize the degree to which users are surprised by the noise and to reduce
annoyance impact. The training of survey and helicopter crews immediately prior to
the survey would include instruction on sensitive resources and implementation of
mitigation measures, as well as training on safety procedures and survival techniques.
Alternative 2 (Ground access)
Wilderness values. Wilderness values would be minimally affected by
conducting the survey under this alternative. Making national air quality decisions
without sufficiently representative or accurate data could result in more severe,
rapid, and extensive impacts of acidic deposition on given individual wilderness areas,
the wilderness system in general, and/or similar areas throughout the country.
Wilderness use. This alternative would increase trail and campsite use during a
time of year when wilderness visitors might reasonably expect more solitude and
tranquility. The size of each survey crew would generally be compatible with the
size of other parties visiting wilderness areas. Wilderness visitors could be negatively
impacted by the survey crew camping near them at lakes, but presumably no more so
than by other ordinary visitors. Using horses would contribute in a minor way to the
damage to trails and camping sites by trampling and feeding on surrounding
vegetation, expanding the trail width, increasing the trail's depth and erosion
potential, and increasing soil compaction in tethering areas.
Because reduced levels of visitation by general users occur during the fall
period when the survey would take place (although special uses such as hunting may
peak during this period), conflicts of the EPA survey crews with other wilderness
visitors for backcountry permits would be unlikely. In those wilderness areas where
hunting season would be under way, a potential for conflict exists.
Wildlife and endangered/threatened species. Under this alternative, the effects
of noise on wildlife would be eliminated. Although the possibility of human contact
with wildlife would increase, its nature would be no different from that already
occurring and no significant impacts to wildlife would be likely. Proper coordination
with local wildlife officials will ensure that survey teams are aware of potential
interactions with endangered and threatened species and of the proper responses to
take in the event of an encounter.
Water bodies. Because sampling of lakes would be done from an inflatable boat,
no impacts on water bodies would be expected. Any chemical reagents or standards
needed in the field could be left onshore rather than carried in the boat.
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Human safety. This alternative involves having many more people sampling
high altitude lakes during the fall when weather conditions are very uncertain.
Sampling teams could be isolated by early fall blizzards and be subjected to severe
weather conditions. Using inflatable boats for sampling extremely cold, alpine lakes
would be dangerous. In extremely cold lakes, the human body can tolerate less than
ten minutes immersion before severe hypothermia conditions interfere with judgment
and physical performance. An accident in the middle of a lake could, therefore,
cause serious problems.
Accidents involving horses being ridden or led through rocky, mountainous
terrain are not common, but are a possibility. Accidents involving backpackers could
also occur. EPA would use personnel experienced in backcountry packing operations
and would train less experienced members of the survey crew to minimize the
likelihood of accidents.
Mitigation measures. EPA Base Coordinators would work closely with local FS,
NPS, and Indian tribal land managers in identifying sensitive resources and developing
appropriate mitigation measures. Experienced personnel would be used to handle
stock and comply with regulations within wilderness areas. Training of survey crews
would include instruction on safety procedures, wilderness values, and survival
techniques. Radios would be provided for emergency communications and
coordination of sample pick ups outside wilderness areas. Landing sites outside
wilderness areas would be selected to avoid creating disturbances within these areas.
Alternative 3 (Helicopter and ground access)
Wilderness values and use. Impacts for this alternative would be intermediate
between Alternatives 1 and 2, and would depend on the proportion of lakes sampled
via helicopter vs ground.
Wildlife and endangered/threatened species. This alternative would involve
some minor impacts from aircraft noise, but the overall incidence would be less than
for Alternative 1 because a portion of the lakes would be sampled by ground crews.
Significant effects could be avoided by proper coordination with local wildlife
officials.
Water bodies. Potential effects (potential spills or leaks) on water bodies under
this alternative would be unlikely and would only pertain to those lakes sampled via
helicopter. For those lakes to be accessed with pack horses, the probability of
impact is slight.
Human safety. Potential impacts would involve both the limited possibility of
death or serious injury in a helicopter accident and the possibilities of accident in
sampling cold, alpine lakes from a small rubber boat and in traveling by horse or foot
in remote areas over difficult terrain.
Mitigation measures. Mitigation measures described for Alternatives 1 and 2
would be applicable to this alternative depending on the access mode chosen for a
particular lake. EPA would work closely with the FS, NPS, and other land managers
to determine which access mode would be used for which lakes. In addition to the
criterion of 7 h in which to transport the sample from the lake to a pick up site
outside the wilderness area, factors to be considered will include, but not be limited
to, presence of sensitive resources within the specific areas, areas of high visitor use,
schedules of special hunts, and safety considerations.
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Alternative 4 (No action)
Wilderness values. This alternative would produce no data from wilderness
areas that could be used specifically for identifying potential or realized acidic
deposition problems inside the areas. Data collected for potentially sensitive lakes
that do not include wilderness areas are likely to be biased at a regional level by
underrepresenting the number of sensitive lakes. Control strategies based upon such
a data base are, therefore, unlikely to place sufficient emphasis on the most sensitive
areas. The present approach of wilderness area land managers is to conduct research
on individual areas. The data developed from such efforts can be used to identify
local situations where acidification may be taking place, but they are of limited value
in dealing with the regional problems, inherent in acidic deposition, of evaluating
trends throughout an entire region (i.e., including the western wilderness system) and
developing regional solutions that would control emissions at their source. A
potential long-term indirect impact to wilderness character could be severe if acidic
deposition were to damage aquatic ecosystems and/or forest within the wilderness
system. Because the western lake survey would be based only on non-wilderness
lakes, the resulting data would likely be biased towards characterizing the less
sensitive lakes and would contain no information on wilderness area lakes.
Wilderness use. There would be no direct impacts to wilderness users under this
alternative. Indirect impacts may result from the absence of data generated by the
survey that could be used to protect the areas from the effects of acidic deposition.
Long-term degradation of wilderness characteristics could cause a diminished fishery
resource, fewer and less vigorous game species, and loss of aesthetic quality of the
natural setting.
Wildlife and endangered/threatened species. Because there will be no activities,
associated with the NSWS survey within wilderness areas under this alternative, there
should be no direct, short-term impacts of the survey on human or ecological
resources within these areas.
Human safety. This alternative would involve no impacts to human safety in
wilderness areas because these areas would not be sampled.
Mitigation measures. Because no wilderness areas will be sampled, there is no
need for mitigation measures to avoid or minimize impacts on these areas.
CONSEQUENCES FOR THE NSWS OBJECTIVES
The NSWS lake survey is designed to provide a high quality data base for
assessing the nature and extent of lakes sensitive to and affected by acidic deposition
throughout the United States. The development of these data will enable EPA to
respond to a Congressional mandate to assess the sensitivity of water bodies to acidic
deposition and to develop emission control policies to prevent further environmental
degradation. The consequences of adopting each of the four alternatives on meeting
these objectives are summarized below.
Alternative 1 (Helicopter access only)
Alternative 1 would enable EPA to meet the objectives of the NSWS as has been
demonstrated with the Eastern Survey. The majority of lakes selected for sampling
in the high mountains of the West would be sampled during a six-week period between
xvi
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mid-September and late October when a representative random sample can be
obtained. Sampling protocols developed and proven during 1984 sampling in the
midwestern and eastern portions of the NSWS, would be used. All critical chemical
parameters needed for the survey could be measured. The data so obtained would be
of similar quality and directly comparable to data from the other regions. In
addition, there would be no difference between the sampling protocols used within
and outside of wilderness areas. Logistical problems have been addressed in the 1984
fall surveys, and the experience gained in addressing these problems could be directly
applied to the western survey.
Of the 21 chemical variables being measured, the analyses for extractable
aluminum, pH, and dissolved inorganic carbon (DIG) are considered the most critical
by EPA in terms of the requirements for sampling by helicopter to meet the
maximum specified holding times. Information on these variables is needed to
characterize the chemistry of the lakes so that data collected from detailed studies
in Phase II and III can be extrapolated to a regional level, including wilderness area
lakes. In the NSWS, pH will be used not only as an indicator of acidification status of
lakes (first primary objective of the survey) but also as a quality assurance check on a
number of other measured variables.
Dissolved inorganic carbon (DIC) consists of carbon dioxide, bicarbonate, and
carbonate, the relative proportions of which are a function of pH. These chemical
species contribute to alkalinity, which is a measure of the ability of water to absorb
acidic inputs without changing pH, the measurement of which is the second primary
objective of the survey. The DIC data collected in the NSWS will be used to quantify
the contribution of inorganic carbon to alkalinity and acidity, and to calculate total
anion concentration and verify pH measurements, both of which are
quality-assurance measures.
The Western Survey will establish a baseline for monitoring aluminum in high
altitude lakes. High levels of aluminum are considered to be a probable explanation
for observed toxic effects (such as loss of fish populations) in acidified waters. A
number of researchers have observed that low-pH (i.e., acidic) waters are associated
with high concentrations of aluminum. Monomeric aluminum (species such as Al 3+
and the various aluminum hydroxides) appears to be the aluminum species of concern
from the standpoint of toxicity to fish, rather than total aluminum (which also
includes polymeric, colloidal, extremely stable organic, and hydroxy organic
complexes). By providing statistically valid characterizations of water quality, the
survey will provide data useful for interpreting the complex interaction of variables
such as pH and extractable (i.e., monomeric) aluminum on aquatic biota.
It is desirable to analyze (or, in the case of aluminum, extract) the samples as
soon as possible because of possible sample degradation. DIC and pH can change with
time as a result of chemical/biological processes within the sample and as a result of
exchange of COZ with the atmosphere. Aluminum speciation (forms of the element)
can change with time as polynuclear species are formed from monomeric species
present at the time of collection (potentially causing an underestimate of the true
concentration of monomeric aluminum); aluminum concentrations and speciation may
also change as a result of changes in DIC, pH, and temperature, and as a result of
absorbance onto container surfaces. In addition to these three parameters, filtration,
aliquot preparation, and sample preservation, must be completed for the other
parameters within 12 hours.
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The extensive Quality Assurance (QA) approach has been defined, documented
and implemented in the NSWS to provide the best possible data to support the
objectives of the NSWS. Thirty percent of the total samples were blanks, duplicates,
and audits. Redundant measures and checks are calculated for all primary
parameters. The utility of the approach has been demonstrated in the eastern portion
of the NSWS. The QA approach for the NSWS involves the following steps to ensure
that adequate data are provided:
1. Standardization of sampling and analytical methods and procedures.
2. Simplification of the field operations as much as practical.
3. Thorough training of all personnel involved.
4. Use of Quality Assurance/Quality Control (QA/QC) samples and
procedures to allow verification of the data.
5. Field and laboratory audits to assure that all activities are properly
implemented and performed.
6. Daily QA contact with the field and laboratory activities to assure
that they are properly performed and that any problems are
identified and resolved.
7. Thorough evaluation of the reported data and verification of data
quality.
All of these steps must be performed to assure that adequate data are provided
to support the objectives of the NSWS, and ensure the quality of the data collected
will not be questioned.
Alternative 2 (Ground access)
The number of lakes that could be sampled under Alternative 2 is smaller than
those under Alternative 1. The exact number of lakes that could not be reached is
unknown at this time, but a preliminary analysis of five wilderness areas suggests
that as many as 20% of the lakes would be inaccessible by horse and some unknown
number are likely to be totally inaccessible. This could lead to a serious compromise
of the sampling design and failure to meet the objectives of the survey. Lakes
deleted because they are inaccessible reduces the population from which conclusions
can be drawn by an equal percentage. Adoption of Alternative 2 requires EPA to
develop a new set of sampling protocols so that samples could be filtered and
processed at the site of collection. This could not be done in time for fall 1985
sampling. The new protocols would introduce additional sources of variation that
include: (1) the possibility of sample contamination during filtration and processing at
the collection site, (2) increased numbers of sampling crews, and (3) more variable
transport time to the field base laboratory because of differing distances and
difficulties of access. An additional equivalency study of lakes would be needed in
which samples would be collected from the same lakes by helicopter and by ground
access so that the comparability of data from the two approaches could be
ascertained. To perform these tests, and to pilot the complex logistics associated
with ground crews coordinating with helicopters outside wilderness areas, a one year
delay of the western survey would be necessary. Even with this additional set of
studies, the data might be of less quality than required by EPA data quality
objectives. The following QA problems could occur:
xviii
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1. Data across sampling teams, field base stations, and subregions
might not be comparable. Thus, key objectives of the NSWS might
not be achieved.
2. More complicated logistics would likely reduce or eliminate the
ability of the survey to provide comparable data of acceptable
quality or to complete sampling of all the lakes.
3. More personnel would be involved in the sampling process and there
would be a higher probability that problems would arise of data not
being comparable or being of unacceptable quality.
4. Unsystematic sample contamination would be much more likely to
occur as the number of sampling teams and forms of access
increase. This would result in invalid data and result in key survey
objectives being unfulfilled.
5. Holding times that have been established for the NSWS, and must be
met, would likely be exceeded. Anyone opposed to the conclusions
of the survey or subsequent regulatory actions could use the
exceedence of established holding times in a court action to
challenge data quality and comparability.
6. Calibrating equipment such as a Hydro lab in the field, rather than in
a heated field base laboratory, would be difficult, even under the
best of conditions.
If different sampling or analytical methods or means of access were used
in the West, calibration of the methods with the Eastern lake survey protocols
must be done. It is expected in any comparison that two different methods will
not be in perfect agreement. As a consequence, there may be random or
systematic bias between methods. It is then important to determine whether
the differences between methods impact the characterization of chemical
distributions and the confidence intervals around the values for the primary
objectives.
Since Alternative 2 involves a combination of sampling methods, a
calibration between these methods must be done in order to make regional
extrapolations. The extent to which the two sampling methods correlate will
affect the certainty associated with the regional extrapolation estimates.
These extrapolations will take the form of frequency curves. These
curves are designed to predict what percent of lakes in a region are below a
critical value for a certain parameter (i.e. pH 5). The NSWS data objectives
focus on those values at the low end of the curve, (e.g. pH 5.0 or acid
neutralizing capacity (ANC) 50 microequivalents/liter). Most wilderness lakes
are expected to fall in this category. In this range even close correlations
between methods can lead to significant increases in the error associated with
an estimate. The higher the error, the more uncertain the estimate is.
xix
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This can be seen by considering those 2% of all lakes with either the
lowest pH or ANC. The number of lakes in this category will be very important
from the perspective of estimating present or potential damage from acidic
deposition. If the correlation between Alternative 2 sampling methods is 0.95
(a high level of correlation), the error associated with the estimated number of
lakes could be as high as 17%. If the correlation between methods decreases to
0.50, the error could rise to 205%. It is impossible to predict beforehand how
close the two sampling methods will correlate. It is likely that the correlations
will be between 0.95 and 0.5.
The survey objectives call for less than a 12% level of error associated
with each estimate. The results of the Eastern lake survey indicate that the
protocols will generate data within that error limit. Using the combined
method approach in Alternative 2 could increase the error to the point where
the ability of the survey to generate regional estimates would be seriously
impacted.
In addition, to properly calibrate the ground sampling method, the
comparison study would need to include helicopter sampling on lakes that are
accessible by ground in wilderness areas. Since the values for parameters like
ANC and pH are likely different in wilderness areas than outside them, it would
bias the regional estimates if the comparison study were conducted outside of
wilderness areas (See Appendix E.I for further discussion).
In summary, adoption of Alternative 2 would delay the western survey one
year to perform required comparability testing and pilot studies, and jeopardize
the data quality. Completion of sampling an adequate number of lakes for each
area needed to meet NSWS objectives would also be uncertain.
Alternative 3 (Helicopter and ground access)
Alternative 3 would differ from Alternative 2 in that every effort would
be made to maintain NSWS sampling protocols. Samples from lakes accessed
via horseback or on foot would be collected from inflatable boats but would
then be returned to the field base laboratories within 7-8 h so that operational
holding times could be met for critical parameters. Roughly 60% of the lakes
could be accessed on the ground within 7-8 h (see Appendix E.4).
Quality Assurance problems discussed above for Alternative 2 would also
be likely to occur for this alternative. Although the objectives of this
alternative would be to maintain NSWS protocols as closely as possible, there
would be greater uncertainties and possibilities for error than for
Alternative 1. These would result from increased numbers of samplers, less
control of sample conditions during transport, and a greater chance of not
sampling the necessary number of lakes due to adverse weather conditions.
Unknown sources of variation associated with differences in sampling and
transport would need to be evaluated. An additional study of lakes inside and
outside wilderness areas and a year delay, as described for Alternative 2, would
also be needed to determine the comparability of data.
Problems of logistics would be similar to those described for
Alternative 2, although fewer sampling crews and less equipment would be
needed. The risk of obtaining inadequate data to meet the survey objectives is
still high for this alternative because of the additional risk to data quality
associated with collecting samples via horseback or foot.
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Alternative 4 (No action)
The principal consequence to NSWS objectives under Alternative 4 would
be that more than half of the lakes randomly selected for sampling in the West
would be omitted from the study. Although a data base could be developed, it
would have limited meaning because many of the most sensitive lakes in high
mountain situations would not be represented (e.g., 82% of alkalinity Class I
(the most susceptible) lakes selected are in wilderness areas; Table 4.4-1). The
data could not be used to make any evaluation of the situation in wilderness
areas and would be of very limited use for wilderness management. Attempts
to extrapolate the data to a regional level as a basis for developing and/or
evaluating possible emission control strategies would be questionable. As a
consequence, sampling in the West may not be done.
CONCLUSIONS
Wilderness area lakes must be included in the western survey. The
preferred means of access is using helicopters to sample all lakes (i.e.,
Alternative 1). The conclusions of EPA scientists are based on the findings that
(1) the environmental impacts of using helicopters would be transitory and
would not be significant, and (2) their use is the only alternative which will
clearly result (as demonstrated by the Eastern lake survey) in the acquisition of
data necessary to meet the national need for evaluating the nature and extent
of acidic deposition.
Alternative 1 involves a one-time request for mechanized access to
wilderness areas to carry out the survey. The following unique features of the
survey should severely limit the ability of others to use the survey as
precedence for justifying additional entries into the wilderness system:
o The purpose of sampling lakes in wilderness areas is to protect
individual wilderness areas and the entire wilderness system from
long-term damage due to acidic deposition; a problem of regional,
national and international importance.
o The need for helicopter use is based on data quality and
comparability, not on efficiency, convenience or economy. The
survey uses peer-reviewed, state-of-the-art methods, and a unique
and comprehensive QA program to ensure the completion of a data
base of known high quality for regulatory decisions.
o The survey will provide information on AQRVs and establish baseline
conditions for sensitive receptors in areas classified as Class 1 under
the Clean Air Act. These areas include federally designated
wilderness areas. This information will allow the Federal Land
Manager (i.e. the FS or NFS) to carry out an affirmative
responsibility under the Clean Air Act to protect these values,
which include lake quality. At present, there is limited comparable
data on lake damage and sensitivity for western wilderness area
lakes.
o The survey will provide a statistically valid representative data base
for managing individual wilderness areas and also the wilderness
system as a whole.
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o The survey will allow land managers to select representative lakes
for continued long term monitoring of acidic deposition effects.
o Under the Acidic Precipitation Act of 1980, the Interagency Task
Force on Acidic Deposition is required to present regional
assessmemts on acidic deposition damage and sensitivity. The
information obtained from the western portion of the NSWS will be
used in a 1987 report to Congress that is also mandated by the Act.
o The difficulty of ground access for a significant number of
wilderness lakes, the impact on data quality of alternative analysis
methods, and the increased error that will result from using
different sampling methods will seriously compromise the ability of
the survey to meet its data quality objectives if either of the ground
access alternatives are selected.
Tables S-l and S-2 present summary comparisons of the four alternatives
considered in this EA. Table S-l indicates that Alternative 1 should have greater
environmental impacts on wilderness areas than Alternatives 2 and 4, but all of these
potential impacts are of a minor and transitory nature. Table S-2 clearly shows that
only Alternative 1 provides the type of high-quality data for the most representative
set of lakes with the minimum set of logistic problems that will permit the survey
objectives to be obtained. A more detailed discussion of this comparison is given in
EPA's opinion is that the data collected in the NSWS are needed for
administration of wilderness areas. There is increasing evidence and concern that
acidic deposition is occurring in the West. Wilderness areas, because of their Location
in high mountainous areas, are particularly susceptible to acidic deposition. The FS is
currently conducting research on this problem, but most of its efforts are focused on
specific wilderness areas. Phase I of the NSWS will provide a statistically valid data
base that will enable the results of extensive studies of lakes within and outside and
wilderness areas to be extrapolated to a regional perspective as well as provide
information for the management of individual wilderness areas. Because the acidic
deposition problem is regional in scope and origin, the only way wilderness areas can
be managed for this problem is to have access to a regionally consistent and high
quality data base. Clearly, the FS has a mandate under the Wilderness Act to protect
wilderness resources from man-caused degradation, such as could be or is occuring
from acidic deposition. The NSWS would provide a management tool to help the FS
manage AQRVs.
Under requirements of the Wilderness Act [Sect. 4(c)], the FS believes that EPA .
must demonstrate that permission to use helicopters in wilderness areas is "necessary
to meet minimum requirements for administration of the area for purposes of
wilderness. EPA concludes that the acquisition of high quality data is of paramount
importance to meet the objectives of the NSWS and that the NSWS is critical to
preservation and protection of long-term wilderness values. The NSWS would
contribute baseline data for management of wilderness areas: (1) the wilderness
system as a whole and also individual areas because of the ability to extrapolate using
the NSWS design and (2) the representative sampling within individual wilderness
units (e.g.. Bridger-Teton, High Uintas). Use of ground access would introduce
additional risks for obtaining the quality of data needed. A data set could be
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obtained using ground access, but it would require modification of sampling protocols,
reduction of the number of lakes that could be sampled, and introduction of
additional sources of variation. These problems create major uncertainties about the
data to be collected using other methods for meeting survey objectives. Therefore,
EPA believes the use of helicopters, a proven access mode for meeting survey
objectives, is the minimum requirement for collecting data of the necessary quality.
Finally, EPA believes that helicopter operations, in this unique and one-time
sampling effort, can be used to gather data on certain resources in a manner which is
compatible with the preservation of the wilderness environment (Section 4(d)(2) of
the Wilderness Act). The mitigation measures which EPA would undertake In
protecting wilderness values and wilderness uses would include: (1) scheduling
operations to avoid peak user periods; and (2) planning flight paths to avoid heavily
used areas (such as trails), specific activities (such as hunting), and environmentally
sensitive areas (critical habitats of threatened and endangered species.) EPA will
coordinate its activities with the land managers prior to sampling each lake in order
to identify the actions which should be taken in the helicopter operations.
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Table S-l. Comparison of Environmental Consequences for the Alternatives
a
H-
Alternative 1
(helicopters)
Alternative 2
(horses)
Alternative 3
(horses and
helicopters)
1. Wilderness Values
o Wilderness Character
- Long-term preservation
- Precedent setting
o Wilderness solitude
o Wilderness uses
- Hunting and other
recreation
- Scientific study
2. Biota (including E/T species)
3. Human safety (probability
of serious Injury or death)
4. Cumulative effects
Alternative 4
(no action)
0
0
0
0
0
0
V Indicates a positive effect; "0" indicates no effect; "-" indicates a negative effect.
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Table S-2. Summary Comparison of Consequences to the NSWS Primary Objectives for the Alternatives
Primary Objective
Alternative 1
(helicopter
access)
Alternative 2
(horses/
foot access)
Alternative 3
horseback/foot
and helicopter
access)
Alternative 4
(no action)
1. Quantification of
acidification status
(pH) of lakes
2. Quantification of
susceptibility to
acidification (alkalinity)
of lakes
3. Characterization of
lake chemistry
4. Selection of regionally
representative lakes for
Phase II and Phase II
_7
V indicates a positive effect, the expected satisfactory meeting of the NSWS primary objective;
"-" indicates a negative effect, the expected failure to meet the NSWS primary orjectlve;
"?" indicates considerable uncertainty related to quality assurance, an uncertainty that can only
be resolved by the comparability studies discussed In the draft EA.
Expected failure to meet the primary objective Is due largely to bias resulting from deletion of
most Inaccessible lakes.
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E-l
APPENDIX E
SUPPLEMENTARY INFORMATION AND ANALYSIS
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E-2
E.I. AN EVALUATION OF THE POTENTIAL FOR TWO ALTERNATIVE METHODS
OF SAMPLING/CHEMICAL ANALYSIS TO BE "SIMILAR"
In Comment #119, the FS calls for a quantification of the effects that changing
sampling protocols would have. In further discussions with FS staff, the request has
been restated as the need to present a quantitative analysis of how data quality would
be affected if sampling protocols were changed as described for Alternatives 2
and 3. EPA has prepared the following evaluation in response to these comments.
BACKGROUND
Approximately 82% of the most potentially sensitive lakes in the Western U.S.
are within wilderness areas. As such, this wilderness resource clearly represents a
potentially unique one from a regulatory perspective, and one undeniably essential to
making appropriate protection decisions. To exclude these areas in a Western Lake
Survey would clearly bias the results of the study and result in an underestimate of
low and neutralizing capacity systems. Obviously, extrapolations to the population of
concern could not include the wilderness area without the samples for that area.
There is significant concern relative to allowing helicopter access to the
wilderness areas of the U.S. Generally, to test "comparability" between alternative
methods, paired sampling (using both methods on the same sample) is required. The
issue subsequently reduces to one of calibration; it is expected in any comparison that
two methods will not be in perfect agreement. Thus, calibration of one method
against another allows for adjusting one data set to more closely align with the
method of choice.
In the case of ground vs. helicopter sampling of lakes, (Alternative 2 or 3) a test
of comparability of methods would include sampling the same lake, at approximately
the same location within the lake, and at the same time by both methods.
Subsequently, the data collected for any parameter is compared (using regression
techniques) and the ground sampling data are adjusted as necessary so that the
resultant data have a one-to-one correspondence in the final data set. All lakes not
sampled by helicopter are then adjusted using the regression equation to force
comparability within the limits of error associated with the computed regression
equation. The adjustment to the ground data, rather than the helicopter data is done
primarily because the helicopter data base is larger than the other data bases
(considering East and West). It is the "limits of error" then which are of primary
concern.
The reasons why alternate lakes cannot be substituted in the study which
employs equally allocated sample sizes within a stratified sampling design are
discussed in the Environmental Assessment. The concerns over logistics and holding
times are also covered in that document. Assuming, however, that all logistics and
holding times are not of concern for the purpose of this examination, a calibration
test between two methods cannot exclude a population of interest. Therefore, the
risk of a methods comparison which excludes a large percentage of the population of
interest could result in a seriously flawed calibration test.
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E-3
PURPOSE
The purpose of this evaluation is to conceptually examine the problems
associated with using two methods for data collection, including collections of sample
size from a large, potentially diverse population (in this case, a population of lakes),
expected regional and subregional variation, and bias resulting from error, if two
methods are not found to be identical. Although no data are available which actually
allow direct comparisons of backpacker vs. helicopter sampling, examples of bias
introduced by using calibration techniques can be developed from the Eastern Lake
Survey (ELS) data set.
To use another method of field collection for acquiring lake water samples, we
must be certain that both are equivalent and/or that there is a known quantitative
relationship of the bias introduced by an alternative method. Only paired
comparisons can be used in such a calibration approach. The ELS has paired data for
examining relationships between methods of analysis for chemical parameters that
serve to illustrate potential problems arising from calibration testing. These will be
used as examples in this evaluation.
It is first important to recognize that since the wilderness lakes are of interest,
the test cannot exclude them. These lakes may be unique and their exclusion would
undoubtedly bias the results and the predictive power of the study design. The range
of chemistry they represent is probably quite different than for those lakes not in the
wilderness. To use data from lakes expected to be chemically similar increases the
risk of failure, and as a result helicopter access to the wilderness would be required
in the test.
The experiment required to calibrate the methods would need to include five
assumably different subregions. (three areas of the Rockies, the Cascades, and the
Sierras). Unfortunately, the appropriate number of samples for the test cannot be
confidently determined at present, thus further adding to the risk.
CALIBRATION
Calibration is a technique that can be used to adjust one methodology to
another. Calibration procedures commonly utilize the relationship derived from a
regression analyses.
COMPARISON OF pH METHODS
The ELS assumed that in situ pH and field base lab pH were the same. Since
there was considerable skepticism in the scientific community over this point, the
field lab pH was identified as the method of choice. However, because there was a
chance that an error could be made in the field laboratory, the in situ measurement
was taken as a suitable backup. If the in situ and field lab measurements did not
agree, both numbers were flagged until other checks could be performed to identify
the correct value.
The rz values for plots of in situ vs field lab pH represent a measure of the
variability explained by the relationship and are essentially equal. About 92-94% of
the variability can be explained by the regression. Six to eight percent of the
variability remains unexplained and contributes to the prediction error introduced if
one attempts to adjust one method to the others.
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E-4
Although this is an excellent r2 (subjectively) for field data, predicting a pH for
one method from the other for any single point can be grossly in error. It is not at all
unlikely that backpacker vs. helicopter data would look similar. The significance of
the remaining 6 to 8 percent of unexplained variability in predicting lake population
below a critical pH value will be discussed in the Estimation of Bias section.
COMPARISON OF ALUMINUM METHODS
Monomeric aluminum is quantitatively related to total aluminum. Therefore,
these two paired measurements are used as an example similar to that discussed in
the Comparison of pH Methods.
For these parameters, a poor relationship is expected (r2 values from .11 to .32).
Monomeric aluminum is known to be affected by, at a minimum, pH and dissolved
organic carbon. If these variables are added to the regression model as covariables,
undoubtedly the variability explained by the model could be greatly improved.
However, if the backpacker and helicopter data were similar, major errors would be
introduced in the final analyses of predicting what percent of the population has
aluminum concentration below or above some critical value. Unlike this example,
however, we would not know what factors to introduce to the calibration to improve
the predictive data adjustment power.
ESTIMATION OF BIAS
The previous examples illustrate the potential results of using two different
methods. As noted earlier, the real issue is what does the variability introduced in
the calibration of two methods do to the confidence of the results? The purpose of
the Western Lake Survey is to characterize the population of lake chemistries. Thus,
we are not as interested in the mean of the population (the average lake so to speak),
but to the cumulative distribution function (CDF). The CDF is the probability of
obtaining a particular value for a variable (Z) equal to or less than an observed value
(see Fig. E-l.l).
Fig. E.l-1 shows the changes in a CDF diagram for various levels of
measurement error. To the left of the center point (the mean of the population) lies
the critical values we are most interested in, e.g., if we wanted to know how many
lakes might be below a selected critical value. The point where these lines cross
might be, e.g., pH 6.59 (the population mean for pH in the Northeast). If we wanted
to show how many lakes are below pH 5.5, this point might be, e.g., around -1.8 on
the X axis (this axis is the standard deviation from the mean). The population
percentage below pH 5.5 (or -1.8 on the graph) varies significantly on the X axis
(representing 0 to 100% of the population) depending on the line used to intersect the
X axis. For our examples, assuming no measurement error, lines labeled A, B, C, and
D apply. These lines represent the theoretical bias introduced when r2 is 1, .99, .50,
and 0, respectively.
At one standard deviation from the mean, when r2 is .95, the absolute bias to our
predictions is only .36%. At r2 equals .50 the absolute bias is 3.5%. However, the
relative bias at this point for the two r2 values is 9.9% and 97%. The latter would
seriously jeopardize the ability to predict accurately the population of lakes below
the critical value. If the critical value was at -2.4 on the X axis (2.4 standard
deviations from the mean), the relative bias introduced from the model error if r2
was .95 and .50 is 17% and 205% respectively.
-------
E-5
To assume that two field methods would compare better than an r2 of .95 would
be unwise. The data quality objectives state we would like to predict the population
below critical values within 12%. For the ELS we were well within these guidelines.
To add 9.9% bias due to calibration error using two different methods may be an
unacceptable risk.
-------
Normal CDF With Measurement Error
u.
a
u
1.0
a.t • •
O.S
0.7 • •
0.0
0.9
0.4 • •
0.1 • •
0.2 • •
0.10 •
0.0
Line A: d2 = 1
Line B: d2 = 1
LineC: d2 = 1
Line D: d2 =
01
-9.0
•4.4
l.t
2.4
9.0
Fig. E.l-1. CDFs for Z (Normal (0,1)) with various normally distributed measurement errors.
-------
E-7
E.2 RANDOMNESS OF SAMPLING
The FS has raised the concern (Comment #132) that the analysis in the EA "does
not dispel the latent belief that lake selection was aimed at wilderness areas ...".
EPA developed a random sample design as described in the EA (pp. 10 and 14) and
selected the lakes for sampling without knowing the location of wilderness areas
within the sampling universe. Therefore, no targeting of wilderness areas in lake
selection could have occurred.
The following analysis has been prepared to describe the random process that
was used for selecting lakes in the NSWS. Fig. E.2-1 has been prepared as an
example for one Subregion to show graphically the relationship of alkalinity classes
and wilderness area boundaries. EPA believes that if another random sample of equal
size were taken, the number of lakes that would occur in wilderness areas would have
an equal probability of occurring in the same proportion as in the original sample.
Because it would take several months to rerun the sample to demonstrate this point,
no attempt has been made to include such a re-analysis here.
The basic sampling approach is a stratified design with equal allocation of
samples, randomly chosen within strata. The objective of stratification was to
minimize the confidence intervals of the various estimates by maximizing use of
existing information relevant to the survey objectives. Regions of the United States
were defined as major physiographic provinces distinguished by both distance and
characteristics of the aquatic resources. Within these regions there were two
stratification criteria: subregion and alkalinity class. Sufficient existing water
quality data were available to suggest that some areas within each major region have
similar physiographic and land use characteristics. To ensure that a regionally valid
sample was drawn from each apparently similar portion of regions, they were further
divided into Subregions.
Within each subregion there were some lakes known to have different
alkalinities. These alkalinities were mapped for the nation, as classes, by EPA in
1982 using existing data. They have been further refined by creating regional
alkalinity maps, which depict areas of suspected similar alkalinity based on alkalinity
data and related information. Alkalinity was chosen as a third major stratification
criterion based on these existing alkalinity maps. The alkalinity classes were ranked
in decreasing order of expected importance to the project as follows: less than or
equal to 100, 101-200 and greater than 200 ueqLT1. Each alkalinity class was a
stratum within a subregion of a region.
From each stratum of the mapped population, a random sample was drawn. No
lakes or areas within strata were specifically targeted for drawing of the sample.
The fact that a relatively high proportion of lakes chosen for sampling turned out to
be in wilderness areas is a consequence of the correlation of both wilderness location
and low alkalinity with high altitude, remote, mountainous areas in the West. The
correspondence between wilderness and low alkalinity class is illustrated graphically
for Region IVD in Fig. E.2-1. Another random sample drawn from the same mapped
population would very likely have a similar proportion of lakes in wilderness. An
approximately equal sample size (about 50 lakes) was maintained per stratum. The
nature of the sample design provided a statistically representative sample of each
stratum population and allows for rigorous estimation and comparison of the various
populations. This sample also provides a sound basis for selection of representative
lakes for subsequent (Phase II and III) studies.
-------
E-8
The population of lakes represented on the 1:250,000 maps, and defined as the
"map population," generally represents lakes over 2 ha in size. The selected lakes
were examined on larger scale maps (7.5' and 15') and identified for field visiting and
sampling. Several kinds of lakes have been or will be classed as "non-target" lakes,
either from the large scale maps, or at the time of field visitation. Non-target lakes
include those sites that are actually not lakes, those lakes that cannot be sampled
according to the established protocol, and several other similar classes. The
remaining sample lakes are considered as belonging to the target population, and all
descriptions apply to that population.
-------
E-9
ORNL-DWG 85-1759
DTD
2 MONTANA
t •-•••-i WILDERNESS AREA
Fig. E.2-1. Relationship of wilderness areas and alkalinity classes in
Subregion IVO.
-------
E-10
E.3 SAMPLING SCHEDULE FOR EACH SUBREGION
EPA has evaluated existing information on lake overturn in the five
subregions that would be sampled in the West. The following schedule shows the
tentative schedule for sampling that is currently being used for planning the
western survey. Changes may be made to this schedule as additional information
becomes available during latter stages of planning.
Subregion Sampling Window
IVA September 23 to November 15
IVB September 25 to November 8
IVC September 9 to October 21
IVD September 16 to October 20
IVE September 16 to October 11
-------
E-ll
E.4 ACCESSIBILITY OF LAKES UNDER ALTERNATIVE 3
EPA Base Coordinators have developed additional information since the draft EA
was published on the accessibility of lakes selected for sampling in the five
subregions of the West. The coordinators worked with FS staff who had experience
and knowledge of the specific lake locations and terrain. Accessibility was evaluated
in terms of the 7 h time constraint for transporting a sample from a lake to a
helicopter pick-up point as described in the EA for Alternative 3. The data obtained
by the coordinators are as follows:
Western Lake Survey Accessibility of Surface Mode Wilderness Lakes
Subregion Accessible Not Total %
Accessible
4A 56 48 104 53%
4B 46 28 74 62%
4C 48 32 80 60%
4D 61 43 104 58%
4E 50 20 70 71%
TOTAL 261 171 432 60%
The data show that an average of 60% of the selected lakes are accessible by
horseback within the 7 h time constraint. Although the analysis was based on
accessibility by horseback, the data would also reflect accessibility by foot, in most
cases.
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E-12
E.5 ATMOSPHERIC EMISSIONS OF HELICOPTER ENGINES
The presence of helicopters in wilderness areas would result in emissions of
pollutants from their engines. Table E.5-1 gives the amount of various pollutants
that would be emitted by a large turbine helicopter (e.g., Bell Huey) while idling on
the lake surface for 20-minutes. Except for carbon monoxide and hydrocarbons,
emission rates during climbout and approach would be higher, with total quantities
dependent on the times involved. Compared to an automobile travelling at 88 Km/hr
for 20 minutes, these emissions range from about 1.5 to 34 times that emitted by
automobile. These values are far below pollutants produced by an average car in a
year. It is expected that the emitted pollutants would be rapidly dispersed to
negligible (immeasurable) concentrations.
Table E.5-1. Total pollutants emitted in 20 minutes by large helicopters under
idling conditions.
Pollutant Emissions (Kg)
Carbon monoxide 4.4
Nitrogen oxides 0.13
Total hydrocarbons 1.9
Sulfur oxides 0.02
Particulates 0.016
Source: EPA. 1980. Compilation of Air Pollutant Emission Factors.
3rd Edition, AP-42.
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E-13
E.6. COORDINATION AND PLANNING ACTIVITIES
As discussed in Sects. 4.1.6, 4.2.6, and 4.3.6 of the EA, EPA would plan to
minimize conflicts with wilderness area users and sensitive wilderness resources
under Alternatives 1, 2, and 3. Detailed plans on specific mitigative measures will be
developed by EPA Base Coordinators, working closely with local staff of the FS, NPS,
and other land managers.
If Alternative 1 were selected, mitigative measures would primarily be aimed at
scheduling helicopter operations (1) to avoid planned activities (e.g., special hunts),
heavy use periods (e.g., weekends), and sensitive resources (e.g., staging areas of
whooping cranes) and (2) to route helicopter flights away from high-use areas and
sensitive resources. In a few very sensitive areas where the land managers identify
lakes where no helicopter access can be permitted because of a sensitive resource,
elimination of lakes from the sample program will be considered to avoid disruption.
Decisions to eliminate lakes would be greatly limited and would involve the NSWS
statistician so that the integrity of the random sample can be maintained- Specific
evaluation of any sensitive resources or uses identified would be made during
planning. Training of Base Coordinators, survey teams, and helicopter crews would
involve instruction on sensitivity and appreciation of wilderness values and resources
and means of minimizing the effects of helicopter intrusion (e.g., the use of the Try
Neighborly" Program).
Under Alternative 2, detailed planning by the Base Coordinator and local land
managers would involve evaluating each lake to be visited, the accessibility of the
lake by horse or foot, and the location of camping areas and routes to be used in
moving from lake to lake within a particular wilderness. Survey crews would be
instructed on procedures to follow when working in wilderness areas (e.g., removal of
any waste materials, such as packaging materials or extra solutions, from the
wilderness area) and on appropriate camping techniques to be used within wilderness.
Crews would also receive instruction on how to interact with concerned members of
the public they might encounter during their trips.
Under Alternative 3, Base Coordinators and local land managers would conduct
detailed planning on the appropriate mode of access for each lake (Le., by foot,
helicopter, or horse). In general, all lakes which are more than 7 h transport time by
foot or horse would be sampled by helicopter, and mitigative measures as described
for Alternative 1 and in Sect. 4.1.6 of the EA would be implemented. In limited
cases, lakes may be dropped from the sample if the uses or resources are considered
to be too sensitive to permit helicopter sampling. For lakes within 7 h transport
time, decisions whether to use horse or foot access would be made by Base
Coordinators and local land managers. These decisions would be based, at least in
part, on the ruggedness of the terrain, types of trails, availability of experienced
personnel, and numbers of lakes to be sampled on each trip into the wilderness.
Survey crews would be trained as described above for Alternative 2 and in Sect. 4.2.6
of the EA. It is probable that some decisions would be needed on using helicopters to
reach some of the lakes located within the 7 h transport time limit. This situation
would be a last resort, but it is probable that weather might limit ground access to at
least some lakes. In such circumstances, Base Coordinators would attempt to
schedule ground access at least two to three times. If none of these attempts were
successful, then helicopter access would be considered. Base Coordinators would
inform the local land managers about each such situation and solicit their advice on
ways to limit the helicopter use.
-------
E-14
Under Alternative 4, the only mitigative measures that would be developed
would be to avoid flying helicopters over wilderness areas in any manner that would
violate local restrictions on air space.
-------
E-15
E.7 ALTERNATIVES CONSIDERED BUT NOT ANALYZED
This Appendix has been developed in response to Comment #130 from the FS. In
this comment the FS identifies the following alternatives that it feels should be
considered to show that EPA is concerned with protecting wilderness values:
(1) changes in sample design; (2) choosing kikes close to wilderness boundaries to
reduce ground transport time to a helicopter outside the wilderness; (3) limiting the
chemical parameters analyzed to only those needed to identify acid lakes outside
wilderness, conducting any more detailed analyses on nonwilderness lakes; and (4)
sampling the most critical "short holding time" variables outside wilderness areas to
accommodate wilderness values not discussed.
EPA has evaluated the possibility of changing the sampling design to limit the
number of lakes that would be sampled in wilderness areas. Eliminating wilderness
areas from the sample is considered unacceptable because a large proportion of the
lakes most sensitive to acidic deposition are found in wilderness areas (Appendix
E.2). The assessment of Alternative 4 addresses the consequences of such a change in
sample design. Other approaches to limiting the number of wilderness lakes that
would be sampled would result in a non-random design, which would not serve the
objectives of the survey of being able to statistically estimate the number of lakes
potentially sensitive to acidic deposition. EPA's proposed design includes a
reasonable number of lakes to satisfy the NSWS objectives and maintain a margin for
unf orseen problems in sampling.
Selection of lakes close to wilderness area boundaries presents two problems.
Such selection would violate the randomness of the sample and would statistically
invalidate the data collected. Secondly, any such sample taken would not represent
the lakes that are remote from wilderness boundaries. There is a reasonable
probability that these remote lakes may be among the most sensitive lakes present,
and their elimination from the sample would create a strong bias in the resulting
estimates.
EPA has defined a set of chemical parameters which are considered essential in
identifying sensitivity of lakes to acidic deposition and trends in acidity. Some of
these parameters (e.g., monomeric aluminum) must be included because the results of
detailed studies on biota conducted during Phases n and m will be extrapolated to
subregions and regions. Unless these data are available for each of the Phase I lakes,
the ability to regionalize the data will be limited and the data would not be
representative of conditions in wilderness areas.
Sampling short holding time parameters outside wilderness areas and not within
the areas presents the same problems as discussed in the preceding paragraph. High
quality data on pH, monomeric aluminum, and DIC are needed to accomplish the
NSWS objectives of characterizing the lakes and providing a basis for selecting
regionally representative lakes for Phase I and Q studies.
Also, while the Draft EA was being reviewed, a comment was received that EPA
use pigeons to sample the wilderness lakes. Under this scheme, pigeons would be
carried in to the wilderness and then would be used to fly the samples out. In
evaluating this alternative, EPA attended a demonstration at Rattlesnake Lake,
Washington on 3/1/85. During that demonstration pigeons carried 10 ml samples back
to their home base. However, the sample size required for the survey is 4 liters,
which is 400 times the amount of water that the pigeons could each carry. It was not
felt that a pigeon could carry this sample size. To break the sample up into small
enough aliquots that the pigeons could carry was also not considered feasible.
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E-16
E.8 ERRATA TO DRAFT EA
p. 4 (2nd parag., 6th line). Eliminate "occurs."
p. 7 (1st parag., after list, 3rd line). Delete "of at end of line.
p. 10 "Alternative" is misspelled on the first line of the first paragraph.
p. 16 (3rd parag.). The MIBK aluminum extraction is done on the four liter
sample, not on the syringe samples, so it is not isolated from the
atmosphere.
p. 21 (2nd parag., 4th line). The period should directly follow the previous word.
p. 21 (last parag., 2nd line and 5th line). Change "(DOQ)" to "(DQO)".
p. 23 (4th parag., 3rd line). Insert "that is" before "maximum"; insert after
"blanks" "should be."
p. 24 (last parag., lines 5 and 6). Change the explanation in parentheses to read
as follows (i.e., 60% more sampling time will be needed due to bad
weather, mechanical problems, etc.)
p. 25 (last parag., 2nd line). Change USEPA 1984d to USEPA 1984f.
p. 26 (2nd parag., 3rd). Insert "(to verify the pH adjustment before addition of
MIBK)" after "pH meters."
p. 27 (1st parag. last sentence). Add to the end of the sentence ", and to assess
comparability with data collected by helicopters outside wilderness areas
in the West."
p. 27 (4th parag., 1st sentence). Add "when possible" after "day."
p. 27 (4th parag.). Add a last sentence "Coordination of air and ground crews
will be needed to pick up samples for transport to field base laboratories.
p. 29 (2nd parag., 1st line). Delete phrase "in at least some cases,".
p. 38 (Legend). Add "* indicates national parks which have both wilderness and
non wilderness lakes that would be sampled; the first number indicates the
total number of lakes that would be sampled in the park; the second
number indicates those that are in areas designated as wilderness."
p. 41 The number of lakes for the Selway Bitterroot Wilderness should be
changed from "15" to "16"
p. 45 The number of lakes for Grand Teton National Park should be changed
from "2" to "3"
p. 47 (2nd parag.). Change "menziessi" to "menziesu."
p. 47 (3rd parag., 6th line). Change "crooki" to "h. columbianus". Change
"Elaphus sp." to "Cervus elaphus."
-------
E-17
p. 48 (1st parag., 4th line). Change "Haliaaetus" to "Haliaeetus."
p. 49 (2nd parag., 9th line). Change "visitor's" to "visitors'."
p. 51 (2nd parag., 4th line). Delete comma after "to."
P. 63 (3rd parag., 2nd line). Change "Huge and difficult-to-see" to
"Unpredictable."
p. 65 (last parag., 5th line). Change "grow" to "gross."
p. 86 (2nd parag., last line). Change "accidential" to "accidental."
p. 91 (5th entry). Change "Steinborne" to "Steinborn."
p. 91 The following individuals should be added to the List of Preparers:
Sharon league, EPA, Corvallis, Oregon, Technical Assistant for the
NSWS.
Dan Michaels, Radian/EPA, Washington, D.C.
Judith Troast, EPA, Washington, D.C., Office of Federal Activities.
Sharon Clarke, Northrop Services, Inc./EPA, Corvallis, Oregon,
Spatial analyst.
Lee Marshall, EPA, Region 10, Seattle, Washington; Regional
Coordination and Operation.
Ray McCord. Scientific Applications Inc./ORNL; data management.
p. 106 (8th entry, 2nd line). Change "Pacaific" to "Pacific."
p. xxv Make the following change and additions:
Change "U.S. Geological Service" to "U.S. Geological Survey."
Add: NEPA - National Environmental Policy Act
USC - U.S. Code.
AQRV - Air Quality Related Values.
LAC - Levels of Acceptable Change
NTSB - National Transportation Safety Board
p. A-12 The Lake designated 4B2-046 (Lake No. 2) should be removed from the
Glacier Peak Wilderness. References to the number of lakes in this
wilderness area should all be reduced by one (i.e., on the Washington map,
p. 49, and in Table 3.2-1, p. 46). The total number of wilderness area lakes
should also be reduced by one.
-------
F-l
APPENDIX F
RESPONSIVENESS SUMMARY
-------
F-2
F.I. LIST OF COMMENT LETTERS
The comments submitted on the draft EA included 42 letters from state and
federal agencies, environmental groups, and citizens. Nearly all commenters agreed
the wilderness areas should be sampled. One half of the letters (21 out of 42)
strongly preferred Alternative 2 (ground access only) or. Alternative 3 (combined
helicopter and ground access) over Alternative 1 (helicopter access only), which is
EPA's preferred alternative. The majority of those letters objecting to Alternative 1
(13 out of 21) may accept EPA's preferred alternative if additional infromation were
provided (e.g., lake by lake justification). This Appendix provides a list of comment
letters, copies of the letters submitted with specific comments numbered, and EPA
responses to each comment.
1. State of Washington,
Department of Game
2. Bridgerland Audubon Society
3. Bureau of Indian Affairs,
Wind River Indian Agency
4. Bureau of Indian Affairs,
Phoenix Area Office
5. Idaho Department of Fish and Game
6. State of Utah Natural Resources
7. National Audubon Society
8. State of Idaho, Department
of Health and Welfare
9. Wm. A. "Bill" Worf
10. American Wilderness Alliance
11. The National Outdoor
Leadership School
12. Wyoming Recreation Council
13. Environmental Testing
and Balancing
14. Oregon Department of
Environmental Quality
15. U.S. Fish and Wildlife Service,
Helena, Montana
16. North Cascades Conservation
Council
17. Sierra Club
18. The Wilderness Society
19. National Audubon Society,
Rocky Mountain Regional Office
20. Gary Paull
21. Washington Wilderness Coalition
22. Denver Audubon Society
23. Sierra Club, Rocky Mountain
Chapter
24. Michael Lee Wilson
25. Sierra Club, Oregon Chapter
26. State of Washington,
Department of Ecology
27. Wyoming Outdoor Council
28. Bob Oset
29. Robert V. Walker
30. The Colorado Mountain Club
31. U.S. Forest Service
32. The National Park Service
33. State of Wyoming, Game and
Fish Department
34. Wyoming Outfitters
35. State of California, Air
Resources Board
36. Montana Audubon Council
37. Laurie Ellen Scheer
38. Dennis Austin
39. League of Women Voters,
California
40. State of Wyoming, Office of
the Governor and State
Engineer's Office
41. State of Colorado, Division
of Wildlife
42. Environmental Defense Fund
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LETTER Hi
LETTER #2
M vii i n vv Viiiise.ioN
Dll'AKIMlNT OF CAME
(.III • IKiiifiu \\.iJuiylnll 'Hliimwil • IMi) 75J-S7IW
Marr.n 6, 1985
Wayne D. Elson
EA Projoi-t Officer, M/S443
U.S. Environmental Protection Agency
1200 Six Hi Avenue
Seattle, Washington 98101
Dear Mr. Elson:
The major concern 1 have with the alternatives outlined in the draft en-
vironmental assessment report for the National Surface Water Survey—Western
Wilderness Area Lakes is the inadequate documentation of the specific timing
of the surveys. After searching through the report I finally found reference
suggesting the surveys will be conducted during hunting season (page VI,
second paragraph). The statement is made that helicopter visitation in
the fall would "result in fewer users being affected by helicopters than
during more popular hiking and camping seasons" (page VII, first paragraph).
The report does not document vtstor use days according to season. Given
that sampling 'juld not be done during winter when lakes are frozen, I
am Inclined to think that sampling during spring-early summer may result
in less distrubance to recreationists than sampling during fall. If this
kind of information is available It should be clearly spelled out In the
report.
Unfortunately we do not have an estimate of the number of sportsmen that
use the wilderness areas you are proposing to sample in Washington State.
Albeii we do know that sportsmens use of these areas Is greatest from
mid-Sor/teniber through the end of October, excluding the first 2 weeks
nf (Vrnhpr. If you decide that surveys should be conducted concurrent
with Ijll huntlr.g seasons I encourage you to avoid sampling during these
peak periods of use.
10 March, 1935
Wayne D. Elaon
EA Project Officer, M/S 44-3
US EPA
1200 Sixth Ave.
Seattle, WA 96101
Dear Mr. Elson,
We appreciate the opportunity to examine the draft EA for the
Western Wilderness Area Lakes - National Surface Water Survey.
Our primary concern was the possibility of setting a precedent
for increased helicopter activity in wilderness areas. The draft EA
addressed this issue well and we see no problem. •
We are aleo pleased to see you have included a plan to alert
wilderness uaere to the helicopter activity. This is probably
essential to avoid misunderstanding and resentment from
wilderness users.
Sincerely,
StephariD. Flint,
Conservation Chairman
copy i Robert it. Reed
D. '[John Pierce, Manager
Big Gume Investigations
-------
LETTER #3
United States Department of the Interior
BUREAU OF INDIAN AFFAIRS
UNITED STATES GOVERNMENT
memorandum
MftlA^
IN Ht.fLV Ht»H 1\J
Land Operations
WIND RIVER INDIAN AGENCV
FORT WASHAKIE. WYOMING 82514
March 14, 1985
Mr. Wayne D. Elson, tPA Project Officer, H/S 443
U.S. Environmental Protection Agency, Region X
1200 Sixth Avenue
Seattle, WA VfllUl
Subject: NSUS Western Wilderness Area Lakes Draft EA
Dear Mr. bison:
As Identified in the subject document, 9 lakes included in the
study area are located in the Wind River Roadless Area on the Wind
River Indian Reservation. Due to a misunderstanding we did not
identify these lakes in our previous communications. Prior to
sampling these lakes, you should contact the Joint Business
Council of the Shoshone and Arapahoe Tribes to obtain their Inputs
and concerns.
The Wind River Indian Reservation is the home of the Shoshone and
Arapahoe Tribes and their government should be consulted
concerning any aclion contemplated to occur on, or affect, the
reservation. I have provided the Tribes with a copy of the Draft
EA for study. Since the Tribal government has not yet been
consulted, an extension of the March 22 deadline for comments may
be necessary to allow the Tribes ample time to study the Draft EA.
You may contact the Tribal Government directly at:
Joint business Council
Tribal Complex
fort Washakie, UY 82514
We have no fuither comments about the Draft EA, but wish to have a
copy of the final EA when available.
Thank you for the opportunity to comment. If you need more
information, contact Charlie Dillahunty at (307) 255-8306.
Sincerely,
LETTER #4
MftR l \ 1985
"T" ACIIME
VTO Phoenix Area Director
JICT, Draft EA for National Surface Water Survey
Western Wilderness Area Lakes
TOI Wayne D. Elson
EA Project Officer, M/X 443
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
We have reviewed the draft document (EPA 910/9-85-125), None of the
proposed lakes are on Indian lands under our jurisdiction and there
will apparently be no resultant impacts within our jurisdictional
responsibilities.
UNITED STATES
DEPARTMENT OF THE INTERIOR
BUREAU OF INDIAN AFFAIRS
PHOENIX AREA OFFICE
P. O DQX 7 DOT
PHOENIX, ARIZONA 65011
Superintendent
ft U, I. Q.P.O, I HI 1-111'HI/* 401
-------
LETTER
IDAHO DEPARTMENT OF FISH AND GAME
600 South Walnut • Box 25
[Joist- • Idaho • S3707
LETTER #6
STATE OF UTAH
NATURAL RESOURCES
Wildlila Reiouicei
1596 West North Temple • Soil Lake Cily. UT 64116 • 801-533-9333
March 13, 1985
Scott M Moinc'jOn, Govomoi
Temple A Reynolds Executive Duocloi
Douglas F Day. Divmon Director
March 15, 1985
Mr. Wayne D. Elson
EA Project Officer, MS 443
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Re: EPA 910/9-85-125
Dear Mr. Elson:
My staff has reviewed referenced document. We believe the sampling
proposed in Idaho is essential. Maintaining these pristine waters and
understanding what is happening to them is very important.'
We have no objection to your proposal to use helicopters to obtsin the
necessary samples. We would, however, recommend selecting times when
visitor use is minimal to avoid "degrading" the wilderness experience
of any more people than absolutely necessary.
Thank you for the opportunity to comment on this proposed action.
Sincerely,
JMC:CHN:tlv
cc: Robert Reed
Oak Ridge national Lab
M
ty
Jerry M. Conley
Director
Mr. Wayne D. Elson
EA Project Officer, H/S 443
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Dear Mr. Elson:
We have reviewed the Draft Environmental Assessment of the Hatlonal
Surface Water Survey for Western Wilderness Area Lakes, and offer the
following comment!;.
We are concerned that the overall scope of the proposed atudy nay be too
limited. Reduced to Its simplest terms, the acidification potential of a
lake Is determined by two factors: Its buffering capacity, and the
occurrence of acid deposition In the watershed. We are concerned that
the study may not adequately address the first factor, and the second
factor not at all.
Considerable evidence suggests that the spring period Immediately follow-
ing (oowmelt may be the moat critical with recpect to acidification. If
acid deposition has occurred In an area, the spring thaw could release a
"pulse" of acid water Into aquatic systems. Sampling lakes In the fall
will Bias this critical period. The Western Lakes Pilot Survey conducted
last fall ID the High Ulnta Wilderness (Utah) by EPA showed that 25
percent of 20 sampled lakea are very sensitive to acidification
(alkalinity between 76 and 100 ueq/1), and 65 percent of the lakes are
ultra-sensitive (alkalinity less than 75 ueq/1). Since the High Ulnta
Lakea are downwind from Salt Lake City (a non-attainable air quality
area) and other Industrialized areas along the Uasatch Front, the
potential for spring!lie flushes of low-ph runoff Bay be high. The High
Ulnta Wilderness Area In Utah may prove to be the most acld-sensltlve
region In the nation. A comprehensive companion atudy to the lakes
survey would be an air quality/snovj.nck quality survey to Identify
locations near wilderness areas where acid deposition la taking place.
With regard to the environmental concerns pertaining to helicopter use In
the wilderness areaa, we generally anticipate no significant Impacts by
this action provided that protocols are adhered to. We feel that using
hellcoptera provides the beet meene to achieve the objectives of the
study In a reasonable time frame. However, a few specific concerns that
we li«ve are identified below.
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Kr • Wayue 1). Elsoa
March 13, 19Bi
PUJ.C Two
Mr. Wayne D. Elson
March 13, 1985
Page Three
1. Iti-ai 3.4, Lndanpi-red and Threatened Species, p. 48, and
Item 4.1.3., Impacts to Wildlife oncl Threatened and Endangered
Slice 1 us, p. 01.
The federally listed endangered whooping crane (Cms americana)
it mentioned In the narrative of both sections relative only to
Die area near Cray's Lake, Idaho. We would point out that
wl,coping cranes are occasionally observed among sandhill cranes
i>l£rating from Cray's Lake National Wildlife Refuge (Idaho) to
Bosque del Apache Refuge (New Mexico) from about September 20
to October 10, over die Uinlu Mountains Wilderness Area In
Utah. The cranes fly at relatively low altitudes, typically in
flocks of 10 to 50 birds. Although most of the cranes migrating
through Utah are sandhills, whooping cranes are also observed.
Migrating cranes are seldom encountered west of the Yellowstone
River drainage In Utah, but are particularly common In the
White-rocks River, Ashley Creek, Sheep Creek, and Carter Creek
drainages. Disturbance of, and even collision with, cranes is
a ixjiisiblllty, so helicopter pilots should be aware of this
potential problem.
2. Item 4.1.2, Impacts to Recreation: Hunting, p. 60.
We do not feel the issue of hunter-helicopter conflicts was
adequately considered in the Environmental Assessment. While
it may be true that some types of hunting (e.g. for certain
species) may not be wilderness-dependent activities, a hunter's
choosing to hunt in a wilderness area reinforces the argument
that lie desires a high quality experience with minimal chance
of outside Interference. Although we do not oppose the use of
helicopters for the sampling effort, we feel that a protocol
needs to be established to deal with hunter-helicopter
conflicts. We suggest that flying high above the terrain on
approaches to lakes, avoiding observed big game animals and
hui.terb, and staying away from known trails and campsites will
go u long v.uy toward alleviating this potential problem. We
ali-o recommend that uaupllng be discontinued on weekends from
September 14 through October 13, 1985, to minimize interactions
with hunters.
3. Item 1.5. Alternatives and Issues Considered But not Analyzed,
p. tl-'J.
The h,:,ue of spring vs. fall sampling should be reanalyzed. If
acid deposition has occurred in an area, spring snowmclt may
llubti larf;e amounts of low pll water Into aquatic systems. The
acid "pulse" so produced may exceed the buffering capacity of a
#7
lake at that time, with aquatic communities affected as the
result. As mentioned before, this is perhaps the critical time
for determining the true acidification potential of many of
Utah's high mountain lakes. We feel the benefits to be gained
from Information collected In the sprlngtlce would far outweigh
the potential Impacts on nesting and calving wildlife in the
spring-summer period.
We appreciate the opportunity to comment on the Draft Environmental
Assessment. Please provide us with a copy of the final assessment. We
also request that EPA contact the Division of Wildlife Resources prior to
sampling so that we may coordinate our activities. If we can assist your
project further In any way, please contact us accordingly.
Sincerely,
(coNir,
William H. Ceer-^Dlrector
DIVISION OP WIEDLIFE RESOURCES
cc: Oak Ridge National Laboratory - Robert Reed
#9
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LETTER #7
National Audubon Society
ll'tslern Regional Offii:t
iSS AUDUBON PLACE, SACRAMENTO. CA 9SS2S (9161 4H-H31
March 15, 1985
Mr. Wayne D. Elson
EA Project Officer. M/S 443
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, VIA 98101
Dear Mr. Elson:
Thank you for the opportunity to review and evaluate the Environmental
Assessment for the National Surface Water Survey, Western Wilderness Area
takes. Our interests in your proposed survey are the lakes located in
wilderness areas in the states of California, Oregon, and Washington.
The National Audubon Society is deeply concerned with the nationwide
threat to fish and wildlife posed by acid rain. Therefore, wa support
strongly your agency's work to develop a scientifically accurate assessment of
acid rain impacts on a wide range of waters throughout the United States.
We view your effort as being important both nationally and regionally. It
is our belief that the impacts of acid rain are already occurring in the
Western United States to an extent largely misunderstood by the general
public. If, as we fear, this study demonstrates considerable damage has
already occurred or is likely to occur, then hopefully the acid rain issue
will truly be perceived as a national environmental concern.
While we strongly support the goals and objectives of this study wa ar«
concerned with the heavy reliance on helicopters for data gathering in the
preferred alternative. We understand that administrative provisions exist for
allowing the use of motorized vehicles in wilderness areas for specific
purposes. However, we are troubled with the possibilities that this program
with its worthy goals could be cited as a precedent for future program* which
may not bo in the Interest of maintaining a healthy and productive wilderness
resource.
#10
He. Wayne D. Elson
March 15, 1985
Page 2
Ue urge the EPA to proceed by using the least obtrusive method of access
which meets all scientific objectives of this important study. Selection of
the helicopter alternative should be made only on the basis of scientific
need. Convenience or economy are not adequate reasons to select this
alternative.
It is our understanding that a comprehensive proposal to access the lakes
by ground is being prepared by the National Outdoor Leadership School in
Wyoming. Please consider this and similar proposals carefully in choosing
your method of access.
It is not our position to oppose this study strictly on the question of
access. However, in keeping with the Intent of the Wilderness Act, it is
clear non-motorized access should be chosen if such methods are suitable and
available.
If It la determined that helicopter access la the only method available,
we would urge you to coordinate the visits to minimize conflicts with wildlife
and recreational users of wilderness areas. Helicopter visits should be
scheduled to avoid breeding periods by wildlife species such as the Bald
Eagle, Peregrine Falcon, migratory waterfowl, and big game.
We would also urge caution in the operation of aircraft and the management
of fuel and reagents while In the vicinity of the sample lakes. Ecologically
fragile wilderness waters, slow to recover from disturbance, deserve your
great care In Implementation of the study.
Under no circumstances should our reluctant acceptance of helicopter use
as a final alternative be seen as a change in our general belief about
motorized activities in wilderness areas. Me view this proposal as a one-time
exception, limited in scope and necessary for the long-term health of our
wilderness resource.
Thank you foe your consideration of our views. We look forward to
following with interest the progress of this important study.
Sincerely,
DT/cr
#10
#11
#.'12
#13
#14
DANIEL TAYLOR
Regional Representative
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UTTER #8
i STATE OIF
DEPARTMENT OF HEALTH
AND WELFARE
DIVISION OF ENVIRONMENT
SlaiflhouM
Boiu. Idaho 83720
March 15, 1985
Ronald A. Lee
Environmental Evaluation Branch
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Dear Mr. Lee:
Thank you for the opportunity to comment on the National Surface
Water Survey Environmental Assessment for Western Wilderness Area
Lakes. The Division of Environment concurs with EPA's selected al-
ternative which employs helicopters as the means of access to wilder-
ness area lakes. Given: 1) the data quality requirements to meet
the project objectives, 2} the fastidious logistics involved in con-
ducting field activities, and 3) the relative low and transitory
anticipated environmental impacts, helicopter use appears to be the
only feasible means of conducting the study.
Please keep us informed as you finalize this assessment and begin
work on the project.
Sincerely,
Lee_W. Stokes, Ph.D.
Administrator
LWS:par
cc:
Susan Martin
Gwen Burr
& ••»$ *ffi;.( • Wm. A. "Bill" Worf
;'; 585 Kootenai Cr. Rd. .|•<-; :\ Environmental Consultant
., Stevensville,MonL59870 ''V , ... ,. r|arch ]8 1985
Phone (406) 777-5450
!'• "'-'•' • r- '
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[.•-'-,,;. './•";. 1200 Sixth Avenue ••''i'tr ,•''. v. ,-; . . v:'
v*1.-'*?';':'-?•-•• Seattle,WA98101 "-'•:::-: VrK*'.'.'•.';.•; •'•'". ' . '-'\ - •:•
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»"-^^^--- Dear.rir.EIson;y;^rx:'v./*; "C*.-^ <''-:-' ' . <••'"(..• "
This is to comment on your draft Environmental Assessment on the National Surface Water.'
Survey of Western Wilderness Lakes.' Following are my credentials for these comments: • £ -
- I've served since 1978 as en active member of the Commission On Ecology for the
International Union for the Conservation of Nature (IUCN). COE recognises acrid deposition as
one of the most urgent of global environmental issues.
- I was closely Involved In the developement and administration of Forest Service wilderness
management policies from Sept. 1964 through 1981. I served on a special task force
Immediately after the Wilderness Act passed to make a first draft of the implementing
' regulations and policy. I headed the Forest Service wilderness Progam from 1965 to 1969.
During that time most of the policies now governing administration of National Forest
Wildernesses were developed. From 1969 through 1981 I headed the Recreation, Wilderness ;
. and Lands Progams in the Forest Service Northern Region.
. - Nearly 31 years as a Forest Service officer.. This Involved extensive experince In organizing
and implementing back country projects using pack stock to meet difficult logistic problems.
; . •.<' ;
!'- I've been on at least one overnight horse or back-pack trip In 26 of the Wl Idernesses you
propose to sample. These include numerous horse pack trips lasting from 3-14 days in two of
them • the High Uintas in Utah and the Bridger in Wyoming.
ollowinQaremycomineritsontIie;(lrBftEA.:-,V'^;-l'' o,. ;->*>•',^>.:: ,; , ;, .. •
Is there a leoal basts for conducting the NSWS within the Wilderness System?
' Absolutely! Section 4(d)(2) says "Nothing In this Act shallpreyent within national
5; forest wilderness areas any activity, including prospecting, for the purpose of
.' ;:;!-"v;" l»;
if ;..;^. .^j
f '"/••'.' f/,.
'' .-'.i-iv ' •• .--;
EQUAL OPPORTUNITY EMPLOYER
#15
.'.''•SIWTS'^ Does the Chief of the Forest Service have
;f\.^;te.thBNSWS? _-,,. .,• .., . „ ....
...,
legal authority to approve the landing of aircraft for
I1'-',. '•:. ••' Maybel Sec. 4(c) pwmltstheapp'rovolof aircraft landings,structures, Installations,
'• . u ">, •<• .';>" ,7'_ I-'-. •;'•',„': .., Sensitli* Cart of Wild Hacu and Cviumiallon willi Dtvebpmmt
#16
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temporary roads, and the use of motor vehicles, motorized equipment, motorboats, or other
forms of mechanical transport if they are"... necessary to meet the minimum
requirements lor administration of the area for the purposes of this Act... " The
first question - Is USWS a 'minimum requiremenr to meet a purpose of the Wilderness
Act"? If the answer Is yes we must ask - Is the helicopter really 'necessary! I'll try to
answer both of these questions later.
Does the EA adequately treat wilderness? • •
No! A number of authors and individuals are quoted and referenced . however the way this
material was assembled missed key points. This is not surprising since none of the Preparers
I Isted on pages 90 and 91 indicate experlies In this very complex subject Followlngare .
comments concerning my most Important concerns;
/; . . ,
I. The document fails to Identify the purpose for which the Wilderness System was ' '•<
established. In the Summary on top of page v It Is noted that wildernesses are to be devoted
to the 'public purposes of recreation, scenic, scientific, educational, ••'•••
conservation, and historical use. "The draft alludes to this phrase in several other
places and seems to imply that these are the purposes for the Wilderness Act. In actuality
these are uses recognized as consistent with wilderness. The purpose the Act was passed Is
simply"... to assure that an increasing population, accompanied oy expanding
settlement and growing mechanization, does not occupy end modify a/1 areas
within the United States... '.
2. The draft fails to recognize the wilderness resource. Even though the words are used on ;
page 33, the authors apparently missed the significance. It was not even listed as a value '
when assessing environmental impacts (Pages v, 32,49,71,854.87) The values referred
to on these pages are primarily those associated with one use- recreation. The Act declared
a national policy"... to secure for the American people of present and future
generation the benefits of an enduring resource of wilderness." The wilderness
resource once covered the entire continent. It is an aura of wlldness.e lack of evidence of
modern man, an absence of man caused noise or smells and a freely functioning ecology. Ills
analogous to older resources like water Water can be fished In, swum In, boatedon, drunk,
bathed In, used for Irrigation, etc.. The wilderness resource can be hiked In, fished In and
hunted In. It can also be used as place to stud/ nature and natural processes and the mere .
fact of It's existence can enhance peoples non-wilderness outdoor experlnces. Individual •"
users and uses can be effected by a specific activity such as the sound of a power saw or the
landing of en aircraft These have a temporny effect on the wilderness resource also bgt a j
much more significant effect on the wilderness resource Is the policy decision that '
determines whether or not to permit such activity to occur. It will determine the quality of
the resource we pass on to future generations. Thelllegal landing of a he) (copter Ineremote
wilderness to poach a Bighorn ram would have a much smaller Impact on the wilderness
resource than the decision to use a helicopter for administrative purposes If such use (J not
truely "necessary". . .'>'.'.
3. The draft gives good recognition that wildernesses serve as natural museums taut makes only
passing mention (on bottom of page 32) of one of wildernesses most Important values - that
of serving as a cultural museum not unlike Colonial Wllllamsburg In Virginia. Aldo Leopold
said" The day Is almost upon us when a peck must wind. It's way up a graveled
highway and turn out it's bell mare In the pasture oft summer hotel, When ..
that day comas the pact: train will be deed, the diamond hitch will be merely's.*'£>r
• a rope, and Kit Carson and Jim Srldgar will 6e names In e history lesson. * '•'' 'f.M.
Porttv because of Aldo Leopolds v Islon we now hove a wilderness System where each year./: .- ..<* .
Um at Uwuunctt of Americans ( recreotlontsts. Forest Service officers, scientists, livestock
#16 k'.ij'••<-:•-.';'-;:i'
(CONTD) •'; '-; i.^'^'Vi-;
#17;
#18
• ••-: •.';•;;* ^r.
\ v ^ >• V" A'** r.>. Vj.1'*,''
, people, outfllters, prospectors end students) are traveling, living and working thi Old
• fashioned way. Theyarekeeplngellvethepack train.dlamondhUch,cross-cut-saw and
' many primitive skills from Americas'heritage. These users also gain In the process by
demonstrating to themselves that they are not weaker or less resourceful than their
.. forebearers. EPA could make a significant positive contribution to this value.
4. There Is considerable reference In the draft to the Acts' provision that wildernesses ere'
"... for the use and enjoyment of the American people...'. We need also to
emphasize five words that also appear twice In Sec. 2( a) of the Act - "... use and
; enjoyment as wilderness..'. The meaning and significance of these words relate very
,. closely to the three preceding comments. Wildernesses are not to be used as recreation
> areas, wldllfe management areas, research areas, etc.. They are to be used as WltDERNESS,
I .Uses of the recreation, wildlife and scientific values may occur as long as trie use does not
V; erode the wilderness resource. The NSWS survey crews will be wilderness users and will
• be enjoying the benefits of the wilderness resource.
•'< -:'::-'.'.M;••• vi
:'V;-'-v>''-V>;''--X:v
.' m'-V '"'* >•,>:;
Following are additional Questions or concerns about the findings or conclusions of the draft
1. On page xll, It Is estimated that 20* of the selected lakes are Inaccessible by horse. I
. . certainly don't know all the lakes selected but my general knowledge of 28 wildernesses
; and experience with horses tells me that figure Is much to high. In any event it seems that
'•; . EPA could randomly select alternate lakes that would be accessible by horse without
- '.'', seriously effecting the objectivity of the study.
' '2. the draft concludes that maximum sample holding times wuld likely be exceeded under
• ' , alternative 2. I would wager a large sum that I could personally ride out to a trail head In
'.. under 7 hours from any lake accessible by horse In either the Brldger or High Ulnta
• ./'Wildernesses. This would be done safely end with a sample. There are local people better
..: ••> qualified to do tt than I. My general knowledge of the wildernesses and experience with
\, horses together with discussions with outfitters, guides, and others familiar with the
'.: situation convinces me that the required limes can be met for most if not all of the lakes
'•' accessible by horse. , , "••'•;
3. The estimated cost of All 2 ($7.000.000.) ^grossly Inflatk* With 60 crews, each crew
would have to sample only an average of 6.3 lakes. Some lakes are very close to the
. >' : '*j.'' p:•. ' •"•' J
W- , X'-- :-&'^>'. '•$*.
v'-Vj!^ '''•X^-:*:!i,f?
•" ' ./.' ;.X"J-i.;p,'- v*^f -
••'' "''•' -'' ''•''
" It seems that If we allow an average of three crew days per lake (25 days total per crew) >»•*
they would be able to do their work and still have time to do a lot of fishing. I don't know
, , the cost of Ihe sampling equipment but $ 1,000. should be a generous estimate of the cost ,4
'.. ( of putting a 4 person crew In the field with horses. In many cases the sampling team and \
,• ., lha courier could hike using pack animals to carry sampling and camp equipment. This
V •' would save expense, problems and time . . ;.>;.
4. There Is no Indicationlii the draft lhal any contact was made with any outfitler or guide
while evaluating Alt.2. Serving most wildernesses you will find a group of professionals
In the art of meeting difficult logistical problems by horse or mule.
#20
(cotmO
#21
#22
#23
r£..5. The draft Indicates the Impacts of helicopter use are all very short-term. It plays down the •
<<\ significance of precldent Yet EPA Is using precldent as an argument supporting this
;-.»?,. J request (page 49). Tho decision by the Chief of the Forest Service regarding this request
v.*V ..; will reverberate throughout the Wilderness System for years to come like the 'shot \
^.^leari/frounitM>»in>rlit-. The same provision which permits tha Chief to grant
. #25
'•>' •
•^
> #26
-L .s.
-------
permission to land aircraft also allows him to permit motorized equipment, temporary ' :.
roads, mechanical transport, mutorboats. structures and Installations. Overthepast2l •'•'•
years there have been literally hundreds of requests under that administrative provision .-.'.
ranging from a bulldozers to maintain existing dams to telephone repeaters to helicopters ;''..:
for grizzly bwr studies to a Defense Department activity that was so secret they wouldn't ("'.
tell us what it waj. Evenesl write there is a group of scientists In Colorado writing a
justification for the installation of a network of electronic instruments to help predict ' j
flooding in the Colorado River Bciln and a Forest Supervisor In Wyoming recommending \,
thehehcopter installation of Grizzly proof caches. The proponents all stress the
temporary nature of the activity or that it will be done when few people are around or It's »•.
extreme importance to wilderness or it's importance to some public program that really > .
Is much more Important than wilderness. .••'•S';
6. Related to 5. the draft assures us that the pending stream survey''- phase I - will not '.'W ;*•',
require the use of helicopters. How does the study differ so that this Is possible? Or ' •'*?!'#
would that change once perm Isslon to use copters In the lake survey Is obtained? •':'.• '•,('•••
' - '-.:•..- .. "•.'>.'•£ •*C'3a;i
7. The "public involvement" proposed on page 64 (s really "hard sell"!
8. The statement regarding proposed training of the NSWS crews on page24 Indicates a lack of •
sensitivity to wilderness. Regardless of which access alternative Is eventually employed •'
all personnel should receive intensive training on the importance and value of the '.
wilderness recource. , /"
Is the NSWS a "minimum requirement' for meeting the purpose of the Wilderness Act? • '•••";"-" • '•;''
The evidence presented in the draft dees not prove that It Is. Surely the data gathered In the '
wildernesses will help the NSWS but If the Nation undertakes programs that prevents damage '
from acid deposition to lands and waters surrounding the wildernesses the wilderness waters
should also be pretty safe. . •'
LETTER #10
#26 v .
(CONTD) , -,;/(
;-4
:'vr?
BOARD OF TOU51EES
Sally A Rannoy
i-">J .",;•'- 1 " *
'^^-""'^
' '•* 'i*?'.?i!>- ' *j(
v;#2>t^a
!•••.. vi;^«
#28 ;
-;
'#29 .•:',-.$
. f '• T
•'.., .-.".'I"
Nancy J. Borra
Ucwian. !•«««
Or. Bernard Shanks
ADVISORY COUNCIL
Dr John Oaignead
WwliM St«Kit.tl Aiftna
LW (Bill) Lane. jr.
Cixwman a >r«o booio Puoii
Francois G. Leydel
Martin Litton
Margate! Wenlwacth Owing;
Piuudtni h«nat CM In* Sim On*
Is helicopter access truelv "necessary" to completing the NSWS In Wilderness lakes? :.-••'/ ;; :'
No! Even If the NSWS Is found to be a "minimum requirement" for wilderness purposes, It can be1?;;
accomplished to an adequate standard by use of horses and mules.
• -.. -;i ^,
! Inr uiHfarnr*x liik« ' ' '\ ,
Conclusions:
I. EPA should complete the NSWS for wilderness lakes.
2. The survey should be done without the use of helicopter access in wilderness. . ' ^. '...
3. Recognizing that virtually no planning toward Implementing Alternative 2, It ma/ not be' .<. .
possible to complete the survey in 1985. If so the program should be postponed a year. '•'
ThanK you for the opportunity to comment. If EPA needs assistance in planning for horse access;
or In training of field crews on the Importance and meaning of wilderness, I would be available on
5 time and expense basis. ,
Sincerely
James A, Posewitz
Mon'ona hm VWO.M ana Pcni OWia(t,m*nl
Of. Wallace Slegner
EXECUTIVE DIRECTOR
Clifton R- Menltt
EDITORIAL OFFICES
Wild Ameiica
7600 East Arapaho* Road'Sutli 1U
Englewood, CO 80112
William A. Worf
Working Together To
Conserve Wild Ameilca
American Wilderness Alliance
7600 Easl Arapahoo RoaJISulle I M/Englewood, CO 80112/1303) 771-0380
March 14, 1985
Mr. Ranald A. Lee, toting Chief
Environnental Evaluation Branch
Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Dear Mr. Ijee:
Attention of: M/S 443
This is in regard to your agency's Environnental Assessment for
the vestern lakes portion of your national acid rain v;ater
survey.
Please mate this statement a part of tlie official record on the
subject matter.
The American Wilderness Alliance is a western-based national
non-profit organization whose members are working to conserve
ths nation's decreasing publicly owned wikilands, wildlife
habitat and free-flowing river resources. lfc have members in
all 50 states, but a little ever half of them are located in
the vestern states.
Vte have also been heavily involved in working with the U.S.
Forest Service and other wilderness resource agencies in the
proper management of established wilderness areas.
We note that you are proposing to use helicopters to take v;ater
samples from lakes in wilderness areas in connection with the
acid rain survey.
Vfe strongly support your agency in obtaining these needed data.
But W3 respectfully request that you fini non-m2chani2ed means
to get thorn.
Yours is'not the only agency, firm or individual proposing to use
notarized vehicles or ncchanical transport within America's
statutorily designated wilderness areas.
Tlie use of helicopters on such a large scale as proposed by the
EPA would set an extremely bod precedent. As you know, the 1984
Wilderness Act prohibits use of motorized vehicles orcl uochonizeJ
transport in establislicd wilderness ureas, except in a few re-
stricted instances. If such use of helicopters by tlic EPA tokos
place, all the otlcr anvncics (federal on.1 state) , firms, oixl
individuals now proposing motorized vehiclular USQ in established
#32
#33
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Mr. Kop.alU A, Loo
H,uvli 14, 1985
P;yu 2
Mr. Ronald A. Lee
March 1.4, 1985
Page 3
wilderness areas v/ill Ic ckmcring for similar consideration
ail ust!. How shall ac IB allowed and the otters denied?
Tit: f loal gate waiLl tc opened—and a wilderness designation
uuler federal lav/ would bcccr.c meaningless.
It is not so difficult to decide wlictlier a proposal to use
motorized vehicles is in the interest of the wilderness. But
with the pressures of several ojcncies, firms aid individuals,
tidy line of decision can quickly btxone fuzzy or be eliminated
altojctlur by [.olitical intervention.
For cxan;jl5, ucatlur modification agencies and forecasters are
even no;-; demand ing v/idespreal use of established national forest
willorncss for tluir motorized snowcats, snowmobiles and the
..icvi-luiJiii-'nt of i«.-n-io.ont sLnictures. These sources can exert
l>cvcriul political pressures on tie wiJdemess resource agencies
to allow such non-conforming uses.
A}ain, officials of sone state wildlife departments have continued
their demands over the years that they be allowed to use snowmobiles
to census and manage wildlife, such as big-game herds. Is this
in the interest of the wilderness?
Fran just these two situations/ I nope that EPA officials can soe
thu problems they are creating with their plan to use helicopters
in designated wilderness areas.
Wilderness areas are not primarily recreation areas. Recreation
is only arc type of public use or purpose for wilderness. But
wilderness recreation requires solitude and freedom from man-made
structures or other developments and motorized vehicles. Other
public uses or purposes, as noted in the parent Wilderness Act,
are scenic, scientific, educational, conservation and historical.
Sore EPA officials have indicated that since the helicopter flights
would take place within a relatively short period (approximately
ana month) in the fall, few if any wilderness visitors would be
iii ilx! areas. 11ns, according to tluir thinking, the planned
overflights and landings should not be objectionable.
This thinking not only misses the point as to why we hove and
must protect witlorrcss as inviolate, but it also overlooks the
fact that in the fall many hunters and other visitors do indeed
use our wilderness areas. They would have their quality wilderness
experience violated and spoiled by the presence of motorized
equipment.
Moreover, ve seriously question the "need" to usa helicopters &
tha first place. No high mountain lakes in Forest Service Region 2
#34
[contd)
#35
#36
are more than a day's (12 hours) travel, round trip, by horseback
and packstock from the edge of the wilderness and rood-ends
or possible landing fields outside the wilderness, r-tost of them
would involve nuch less time. I have war tod with saddle
and packstock virtually all my life en ranches aal in wilderness
areas and know what can be accomplished by these means.
By using the services of outfitters and guides, you would have
experienced horsenen and packers who are familiar with tte areas
and could expedite getting your technician and equipment into
the lakes, taking the sanpJes, and bringing them out. According
to tha EPA information I have, this should require a total of
only two saddle horses and a packhorse for the outfitter,
technician and equipment. Use of horses and packstock would cut
the tine to half or less over foot travel and greatly facilitate
transporting rubier raft and water testing equipment.
There would probably be extremely few, if any, lakes that tte
experienced outfitters couldn't get into and out of expoditiously.
Finally, the cost of the survey would be greatly reduced.
It should be enphasized that the Wilderness Act authorizes the
use of outfitters and guides—and their use is in harmony with •
the wilderness philosophy and concept. As a matter of fact,
outfitting and guiding is the only commercial conforming use
allowed under tha Wilderness Act in established wilderness areas.
Accordingly, the American Wilderness Alliance would hove no
objection to the use of outfitters for your water survey. Indeed,
we would support it.
The outfitting and guiding industry maintains associations of
their outfitters On a statewide basis, and I believe, their
officials would be pleased) to help you expedite this important
water study.
Accordingly, the American Wilderness Alliance strongly objects to
tha use of helicopters for the EPA water survey and strongly
supports outfitted saddle horse anl packstock vise fcr this study.
Would you please let us hear from you scon on this matter?
Sincere ly,
#37
(coin.
R. territt
Executive Director
cc—EPAi Colorado, Idaho, Montana, Oregon, Wyoming
-------
LETTER
The National Outdoor
Leadership School
H PROPOSRL TO THE ENUIROHMENTflL PROTECTION RCENCY FOR THE
NRTIOHRL GURmCE URTER SURUEY= NOH-HOTORIZED LOGISTICIU. SUPPORT
TOR SflMPLING UESTERN UILDERNESS LflKES
March 19, 1985
12 MRRCH 1985
Dr. Bernard Goldstein
Assist. Adm. for Research & Dev.
U. S. Environmental Protection Agency
401 H. Street S. H.
Washington, DC 20460
Dear Dr. Goldstein:
Enclosed please find a proposal from the National Outdoor
Leadership School (NOLS) to the Environmental Protection Agency
for the NSWS sampling of Western Wilderness Lakes.
There are four alternatives discussed in the proposal, all
detailing different levels of NOLS involvement in the study. I
air. convinced that foot access is a viable alternative for the sampling
of Western Wilderness Lakes, and hope that you will give it due
consideration.
Jim
I'.O. B..xAA
L.,nJi-i. Wy.jmini; 82520
NHTIONDL OUTDOOR LEADERSHIP SCHOOL
BOH HH
LRNDER, UYOnlNG 82520
RESPOND TO:
I look forward to your response regarding this proposal. I will
leaving town beginning the week of March 25 for several weeks.
All communications should be directed to Steven Forrest listed
on the proposal cover.
Sincerely,
be
#39
JONRTHRN P. KUSEL
EPECIHL.PROJECTS DIRECTOR
BOK nn ,,
LONGER, UVOMING 82520
307-332-6973 Ext. 77
STEUE TORREST
BOH 3759
JRCKSON, UYOHIHG 83001
307-733-9625
307-733-68E6
Jonathan Kusel
Special Projects Director
Enc.
C. Riordan
J. Huang
L. E. Coate
W. 0. Elson
R. Lee
L. Svoboda
R. K. Reed
R. Linthurst
D. Landers
-------
II PPuTOSflL 10 THE CNUlRONnCNTflL PROTECTION HGCNCY, NRT10NHL
tiURrncc UHTER SUKUCY. NonnoTORizcD LOGISTICAL SUPPORT TOR
SHrll'LIMG UCSTCKH UILUERMCSS HRCflS
INTRODUCTION
In 1557, the Environments\ Protection Agency (EPA), Office of
P.esearin and Development, initiated s national effort to estaplish
baseline iata :n «cid deposition, the National Surface Water Survey
<'.iK3<. £3n nijeo i Draft Environmental Assessment 'EPA-S10/5-35-12S) on
the °':»5 of Western Wilcerness Area Laies on 1 March 1955. In the
•i!»«;si»eri, £ri :or.»idcri four alternatives in terms of potential
envir;n»enul inpacts on the existing wilderness and potential effects
upon -.he JLjec;i.e5 of the N5W5, and tnat Alternative 1 (all wilderness
inet ia~oiea oy helicopter) is the pr*f'errea alternative.
;i5;j;:i:f- wi-.n EPA officials and resorts in the Jackson Hole Guide,
>:£-H, Center Post, Z-la-oE, and San Francisco Chronicle, 2-12-
ji* t"3t if nsii opt*rs are njt granteo access to wilderness
rvice, the 'J5W5 study will be postponed until
srt£• en a», all.
t r*«o for attelint data, this proposal
«s- 'o motcri:ec sampling uitnin wilderness ares
•:*; JIG jffers tr assistance sf the National Outdoor L*«oership
IIi
'."•;'-z ~f
PRODuEM STfiTEHENT
nl'.-.:,;r ;i;ic-.ives of the overall EFA study are almost universally
4r='-jc.53. >.r* i/Jr- is currer/tly denying helicopter access to survey
•,i'.-i'-r.»',* '.*,<:• iinet nctcrized access is clearly not in keeping with
•ri :-••.':•: trv i(.t«»t of th* Jildern**!, Act. ns nited in the EA, the
-.i.sr'fti. 'ct :f-'5;-S77 Ssct. 41 ano th* Fs Recreation Manual (USOA
'>r;ytv.j. j«ct. "">3'i, dllou far authorized aircraft use
•o '-42! nininum ••equirewents for protection and administration
jf tr« jr-i, -o .-.«*•. th* surpo*es o/ the act, for tont fida
•-•/--:r Vj. ;;5s invcivi
'.04 ires. Tie uie ?
iistts »s.-,e r.a/ at
,
tn< neeltn and safety of persons within
eaulpntnt, !trj:tur»», gr activities
»itOi d) (Uhenl either an
t i
In
a*\e<-p".r>}<. ir.r, of wn»i is r»ason*Bl<, there must be a showing
>n>i -.n« need is Dated upon more tn«n efficiency) convenience!
ar*d *
page 2
There Is considerable question by the FS and concerned outside
groups regarding the EPA position that the study cannot be reasonably
accomplished by nonmechanical means. A failure to resolve this issue in a
timely manner could result In postponement or cancellation of the survey
within the wilderness system. Since many potentially sensitive lace's
occur inside wilderness boundaries, and because baseline data is urgently
needed in some cases, postponement or deletion of sampling within the
wilderness system may only create data voids which ultimately could prove
detrimental to management and maintenance, of wilderness values.
OBJECTIVE
This proposal provides a meant to avoid potential mission conflicts
between the NSUS and USFS execution of the Wilderness Act. NOtS will
supply logistical and ground support for nonmotcri:ed sampling of western
uildernest areas while maintaining the integrity end consistency of the
sampling effort,
Ue propose that the National Outdoor Leadership School, a non-profit
outdoor educational Institution baaed in Lanoer, Wyoming, provide such
support necessary to insure completion of the NSuS within wilderness
areas in nine western states utthin the 1SES time freme.
BACKGROUND
The National Outdoor Leadership School was estaolished in 1965 ano
offers international programs in all areas of outdoor education. Tne
school conducts nearly one hundred and fifty courses annually in seven
wettern states, Alaska, Mexico and Africa, maintaining branch scnools in
Wyoming and Washington in the west. NOLS maintains its own transportation
staff and horsepacli ing outfitters, end is currently permitted to outfit
in over seventeen National Forests and numerous National Pards end
Monuments. Instructors ere hignly trained in wilderness travel and
mountaineering and are responsible fdr rationing, bacxcountry emergency
meoical oare end leeching technical ano non-technical wilderness i^illi
to over IBOB students throughout the year on courses ranging fron two
weels to three months. The consistent record of e»cellinct in teicnin;
outdoor skills and safety in the wilderness has given NOLS the reputation
of one of the finest outdoor schools ("NOLS, the Harvard of wilderness
Schools,* honey Magaeine, 1977, See Appendix I end II).
Alternative 2 of the EA (use of ground accost only) did not cU-tels
e-amine the use of foot access, slating in Sect. 1.6 that thit
alternative "...hai not been fully evaluated in the EA...', and nucn af
the relevant discussion involves the impacts of only none-led sampling
eM&rts. NOLS experience suggests that distances inoi:iiec in Tjiale -.:-!
•it the EA as "probable" (0-14 iilm) can oe traveler «»«!>•. by a runner
on feet from a sampled lai.e to a trailneeo or an aerial piol-up paint
outside the wilderness boundary uilhin NSUS time constraints. Longer
distences would require close examination of the terrain traveled to
determine whether a runner can meet the NSUS deadline of seven hours from
-------
page 3
sapling line to helicopter pic I-up, and if horse transport or a
cent) injt ion of runner ana horse transport of a samp le is necessary.
DESCRIPTION OF SERVICES
Fjur alternative levels of ser
acove conflagrations are suggested1
ce provided by NOUS based on the
AIt erndlive
NOLS pi
of u i 1 c e r r e ;
five zer mcc
q ja i 11' i ed gr
E - -^ 11:r,n ic i
c ; r j i •. i ,: o i \
I
dns
b 1
lie
D *: car^iea o
w l I Jer n^; 5 s b
la- -s 1 , i«-g
- i * idni 1 a i e
f : : i -2"a r.o--
c : :>r r i r a t e ".
a - c r 3. c : o 5 ,
wnich r e Q --I i r
n-aintain p*~e
p i: t up . I-.3L 5
transport stt.
1 3. ea. NOLS
p-cc:s-l is f
f-ny i amp 1 ing
i r,e a_»C5£ i i s
P""" c eaure de t
: -r f ace Jdie-"
n ? . 5 3-u j-321-?
and manages all logistics for the western region sampling
ands. NOi_S organises ana supplies 25 field study teams,
lao unit, consisting of two NQLS instructors and four
a t es of NuLS baclpacl-ing expeditions. They ulll escort two
--who mus t be physically prepared for demanding field
3 will outfitj--inio wilderness laK.es, carrying all study
cipacKs. EPA technicians will collect samples that uill
vjnners to the nearest helicopter landing area beyond the
aary. Runners will return to the group or be replaced by
carry study equipment) if the runners are traveling from
p uiiihin wilderness boundaries. Samples gathered at
ay recuire norse transport and possibly a combination of
transport to insure the seven hour lake to helicopter
is met. NGL5 will coordinate all of these efforts, and
ropter pickups of samples. NOL5 field logistic protocols
ner employing F3 repeating stations, or radiotelephones
o direct line of sight to communicate, will be used to
e coordination with sanple transport and helicopter
nicies ano contracted helicopters uill be used to
teams to op t i "ii urn wilderness entry points to access study
11 coordinate this effort, The budget included with this
our preferred Alternative 1. Tne budget does not include
uipment or field radios supplied by the EPA, and we feel
rzurat e with our present understanding of the testing
led in the En and the Methods Manual for the National
urvey Project-Phase 1, EPA, Las Uegas, Nevada, contract
page 1
Alternative 3
NOLS instructorB uill accompany sampling teams to coordinate field
activities, providing backcountry expertiso and safety assistance. NOLS
will not bo involved with the planning and logistics, except in the
field, and then only as dictated by EPA coordinators. This Is a minimum
NOLS involvement In the NSWS effort end will cost only Instructor time
and travel expenses, plus a minimal administrative fee for contracting
NOLS Instructors.
Alternative 4
NOLS trains individuals who will be working in the field on the
NSUS. Field workers uill travel to NOLS Uyomng for training in
badcountry travel, camping and safety. This alternative is possible on
a space and permit availability only, and snould begin immediately prior
to the NSWS sampling. Cost will be similar to standard NOLS student
prices, actual cost determined primarily by length of field time and the
particular educational demands by the EPA.
SUMMARY
Because of the immediate need for baseline data, NOLS does not wish
to see the NSUS in the west postponed or cancelled. NOLS is confident of
its ability to escort EPA tecnnicians to study laces in wilderness areas,
and meet NSUS protocols of holding and transport times when evacuatin.-
sanples from the field to the helicopter pickup site. We are also
confident, that foilowing proper training, our instructors can learn and
perform required field sampling procedures. !
There may be several advantages to nonmotonzea sampling. Extracting
aluminum in the field may prevent rapid speciation ana preserve Al
concentrations (personal communication, Charles Driscoll and Chris
Kronen, aluminum sampling experts), as opposed to isolating and
refrigerating samples that are extracted in up to 12 hours, as is
proposed in the EPA assessment (Or. Kronen has stated that samples may
begin to degrade in as little as one-half hour).
There may be an increase in the overall safety of the western survey
by using bad-pad-era and limited horse use rather than the proposed
action of helicopters. As stated in the EA, high altitude and mountainous
terrain, characteristic of many of the wilderness study la^es, involve
aangerous flying conditions, quite unlike conditions experienced in all
other regions of the NSWS. With the proposed sampling schedule there is a
one in ten chance of d helicopter accident. Detailed in the EA, this
estimate is considered conservative, but ooes not ta>-e into account the
high altitude nature of the proposed action, thus increasing the chance
of an accidsnt.
Baclpacling is a routine activity at NOLS, with little rist- even in
tht most inclement weather. While there remains a possiblity of injury to
bacKpacfers, the chance of a serious injury is mininjl. Due to the ratio
of NOLS instructors to other team memoers, the use of NOLS graduates in
our alternatives, and the overall outstanding safety record of NOLS,
there la considerably less hazard with the backpacking op lion than the
EPA helicopter option.
-------
page 5
page £
BUDGET
C. TRAVEL AND TRANSPORTATION
fl. STflFF PAYROLL
DAYS
RATE/DAY
1 .
ni£ trst i ve
Project Leader
Ass't Project Leader
165
145
SuD-Segion Ccorainators<5 ) 145
fiS3't S-R Ccoro:nator5(5)
SecretaryU)
Food PacK£3ers<4)
Ejj.jipr.ent Staff(2)
$240
200
175
70 75
135 36
($1,000 for period)
(SI,780 for period)
:. Fieio Staff
Regional Drivers(5i 55
Instruct ors
St^ay Team Leaderet-V) 55
".si't Le3a=r3(Z7) E5
Sub-total Payroll
Fa.rc-11 Ta*es (8.SS)
TOTnL PflYROLL
B. FIELD EXPENSES
1. Instruct ~r Medical Insurance
2. Rations' fcr 40 Field Days
Outfitting Supplies
= ^eciaiire3 tents fsr HyarolibsdB /
First flid Pacts, flaps, Misc.
TOTAL EQUIPMENT
•Tiiais include two EPfl
*6chnicidns per study lean
4. Prj.ne Services
<-r5igl-;rs r'or 3-4«pie Transport
'Jrtngitrt far field rationing of study team*
Evacuation c-p«r.;e
TOTAL PRIVATE SERVICES
50
EO
50
TOTAL
139,BB3
29,000
126,875
26,252
4860
4000
2560
13,750
69,108
74.353
410,245
36.102
1446,347
TOTAL *S,37S
TOTAL 131,800
138,312
8,190
4. =00
351,532
szs.soa
30,750
1525
•57,826
1. Administration
DAYS
PER DIEM
Sub-Region Coordinators 65 $25 per diem
E5 $35 per hotel
Asa't S-R Coordinators 60 *2S per diem
60 $35 per hotel
Transportat ion
Project Leader and
Ass't Leader
Transportation
COORDINATORS TOTfiL
50 $25 per diem
50 $35 per hotel
PROJECT LEADER AND ASS'T TOTAL
Miscellaneous: phone: and other TOTAL
Z. Field Staff
Instructors and
Volunteers USE)
Onvers(5)
Transportation
Vehicles
(7 Uoeks)
Administrative (19.SX)
IB $25 per diem
18 $35 per hotel
TOTAL
54 $25 per diem
$35 per hotel
!
DRIVER TOTAL
20 Vans
5 Station yacjons
VEHICLE TOTnL
PROJECT SUB TOTAL
TOTAL
$8125
11,375
10,500
8. 750
$4E,250
2S20
3580
-9375
S15.S7E
$3603
70,200
38.230
$163,480
5753
3450
2500
$18,703
SIZE,000
SU5.675
153.367
PROJECT TOTAL *l,184,995
-------
flPPENOIX I
KEY NOLS PARTICIPANTS FOR NSUS
: Jonathan Kusel, M.F.S. 1332, Vale School of Forestry and
Environmental Studies; currently, Special Projects Director, The National
Outdoor Leadership School, Research Associate, National Park Service,
Cooperative Park Stuaies Unit, University of Idaho, 1932-83; NOLS
Instructor seven years, Senior Staff, Instructor Trainer.
Assist.-"'! Fr-?|grt Lec-der- Douglas Frisbie, Ph.D., Political Science and
Research Methods, University of Minnesota; currently, Director, Frisbie
an] Associates. Executive Director Minnesota Crime Prevent ion Center.
1S73-31. Project Director Statewide Crime Research Program, head of
c'-cfessionai staff of 10, 1975-76. Director, evaluative research efforts
state of Minnesota, staff of 15, 1973-75; Research Methods Instructor-
Miami University 1563-73; NOLS Instructor, 3 years.
Pi :•
Ie; Project Director Colorado Outuard Bound School (COBS) si nee.
l^Ej. winter Program Director at COBS 1S32; Course Director CCBS 1979-80;
Cirecisr NOLS Northwest Branch School 1975-78; NOLS Instructor, 6 years,
Se1" lor Staff.
LJuise Forrest - M.F.S. 1980, Yale School of Forestry and Environmental
StuCies. currently, Research Associate, Black-Footed Ferret Conservation
Studies population status, winter ecology and data analysis, Research
n^socijiie, Thcrne Ecological Unit, 1931; NOLS Instructor 6 years, Senior
Staff, Instructor trainer
' j o cI i n' Staff Sargent United States Marine Reserves; Coordinator
Wn'-j winter iraining film for USfIC, 1985; Company Training Officer for a
<~2;^nnai^sdnte company' plans annua1 training schedules and supervises
insirjci. iinsi staff, Battalion Conmanoer western field manuevers, NOLS
Irs true t or 4 years, Senior Staff vIncomplete, individual is in the
fielj).
ii «• -en -rr^-r-c r : M.F.S. 1SS2, Yale School of Forestry and Environmental
3 t uGi &* , current i'y. Researcn Associate Biota Research and Consulting;
FielJ Coorainit cr CnNUSA Spruce Buduorm project with the University of
I_3fo -ana tne USF5 Forestry Sciences Laboratory in Corvallis, 1979-80.
£>'.. -.-; ^ 4P n t -;r. ftaninistrali»e Assistant, NOLS , 1935. Director of Raptor
S*;te3*"cn Program, Snosnone National Forest, USFS, 1978; Research
Aiejciaie Rochy Mountain Timber Uolf Recovery Stuaies, 1976; Uilderness
Pans-a", USFS Region 4, 1971-73. Wildlife Biologist, Alasta Department of
Fisn and Gane, 1967-71, NOLS Instructor, 13 years, Senior Staff,
In-. » fuc t or frjiner Aias^a Branch School Director 1974.
NOLS-Project Safety Officer:
Tod SchimelpfeniQ: 12 years with NOLS; Certified and practicing Emergency
Medical Technician
-------
LETTER #12
» ,.
IHt STATE "'Cj^pjJjX OF WYOMING
ED HERSCHUR
UUVtHNOH
WYOMING KEP.KEATIOX COMMISSION
122 WEST 2bT«-HEhSCHLER EtOG CHEYENNE. WYOMING 82002
ALVIN F BASTHON. PE
Dirtiw
777 7695
March 18, 1985
Wayne D. Elson
EA Project Officer, M/S 443
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
RE: §Draft Environmental Assessment: National Surface Water Survey, Western
Wilderness Area Lakes
Dear Mr. Elson:
Alter review and evaluation of the four alternatives presented in the Draft
EA, the Wyoming State Historic Preservation Officer has determined that the use
of helicopters for sampling lakes in the wilderness areas of Wyoming would have
no impact on cultural resources. Indeed, the absence of shoreline contact and
the avoidance of camping activities likely to be associated with other alter-
natives virtually guarantee that surface cultural resources will not be
disturbed or adversely effected. We support EPA in this preferred alternative.
Sincerely,
!,
Thomas E. Marceau
Reviex & Compliance Section Head
TEM:klin
cc: Robert M. Reed
LETTER #13
^" "A Better World -^
^Through A Better Environment"
Environmental Testing & Balancing Inc.
P.O. Box 594
Snoqualmie, WA 98065
(206)643-1666 '- :
(206) 454-5450
19 March 1985
Wayne D. El son
EA Project Officer M/S 443
U.S. Environmental Protection Agency ,.
1200 Sixth Avenue
Seattle, MA 98101 ,
Dear Mr. El son:
J- - ... '. ... .- I'. •'-•.. 'v"-V>- -. _;.--•-'-•'•'; -..-..
The attached correspondence contains comments on 1) the National Surface Water Survey
Western Wilderness Area Lakes Environmental Assessment Draft, 2) Methods Manual for
the National Surface Water Survey Project - Phase I, and 3) Scoping Document.
Environmental Testing and Balancing 1s responding to the above documents due to con-
cerns about apparent Inconsistencies, inaccuracies, omissions, and unknowns found in
them. This additional letter is being written to express the frustration we have en-
countered in attempting to give constructive input regarding this project.
Subsequent to reading reports in the media of the EPA's plans to sample western wilder-
ness area lakes using helicopters, our company attempted to contact the EPA to discuss
an alternative method for transporting lake water samples. Our efforts were to no
avail. Our letters to the EPA went unanswered and several phone calls received little
or no response. In an attempt to show the EPA a sample delivery method that we feel
deserves serious consideration, our company planned, organized, and funded a demonstra-
tion using carrier/homing pigeons to transport water samples from a lake site to a pre-
set destination. In our estimation, and substantiated by media observers, the test
was a total success. However, as reported in one newspaper, EPA officials were "unim-
pressed". If this 1s true. It is both disappointing and hard to accept. There has been
much publicity about the problems the EPA has encountered in attempting to obtain per-
mission to use helicopters in the wilderness areas and the obvious desirability of long-
• term monitoring of acidic deposition effects on wilderness lakes. It appears the EPA
«i should welcome, or. at least be willing to consider, what could be a relatively simple
solution to what has become a complex problem. If a solution to a problem seems easy
and less costly, Is that a good enough reason to discount it without due consideration?
As an added note, to.confirm the abilities and dependability of carrier/homing pigeons,
contact the U.S. Army Signal Corps.
Sincerely,
ENVIRONMENTAL TESING & BALANCING, INC.
Robert L. Brooke
President
RLB:bh
M. Rnd. Oak Rtdg* Notional L«bor«eor-.x
-------
•"A Belter World ~
^ Through A Better Environment"
Environmental Testing & Balancing Inc.
P O Box 594
Snoqoalmie. WA 98065
(206) 643-1666
(206) 454-5450
19 March 1985
Wayne D. El son
EA Project Officer, M/S 443
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle. WA 98101
cc to: / '
Robert M. Reed _ -: /..., , -..•.'_[, _- . \.t
Environmental Sciences Division "" --*•-' —-*— *^*~* * r>,--. ~-.., y*. .'-".t-^
Bldg. 1505 i,
Oak Ridge National Laboratory
Oak Ridge. TN 37831 |
Dear Mr. Elson: '
Enclosed are our comments on the "National Surface Water Survey - Western Wilderness
Area Lakes, Environmental Assessment". Our comments are separated into two sections.
Section I deals with apparent incongruities and omissions by the EPA in their prepa-
ration of the EA. Section II deals with our proposed alternative to the use of heli-
copters for water sample delivery from wilderness lakes. Our proposal to use homing/
carrier pigeons as an alternative to helicopters was made to the EPA prior to publi-
cation of the EA but was not addressed in the document. Considerable research and
planning went in to the pigeon proposal and we feel it is a workable plan and possibly
the only viable alternative to using helicopters that has been proposed. Therefore,
we are submitting it to the EPA and a concerned Public once again for consideration.
Sincerely,
ENVIRONMENTAL TESTING & BALANCING, INC. - , :
Robert L. Brooke
President
RLB:bh
encl
.Airflow and hydronlc balanclng'HVAC ayslem analysis and troubleshootlng'mechenlcal system documentation — <
• "A Belter World>~
^^Through A Better Environment"
Environmental Testing & Balancing Inc.
P.O. Box 594
Snoqualmie, WA 98065
(206) 643-1666
(206) 454-5450
19 March 1985
COMMENTS ON "NATIONAL SURFACE WATER SURVEY
WESTERN WILDERNESS AREA LAKES
ENVIRONMENTAL ASSESSMENT"
dtd MARCH 1985
I. Incongruities and Omissions in the Environmental Assessment
A. Setting a Precedent
Environmental Testing & Balancing has reviewed the Environmental Assessment (EA)
•for the National Surface Water Survey - Western Wilderness Area Lakes (NSWS).
There appears to be a fundamental incongruity concerning the CPA's expressed need
for the use of helicopters to deliver water samples in an expedient manner during
Phase I of the NSWS but not finding it necessary to use them during Phases II or III
of the NSWS.
In the EA, under SUMMARY AND CONCLUSIONS, Environmental Impacts (p v), it states,
"Alternative 1 involves a one-time request for motorized access which is unlikely
to serve as a precedent for granting other requests. Few, if any future requests
would meet the following unique research and administrative objectives and the
methodolgical (sic) constraints of the NSWS survey:..." ,
#tjO ^ne P'"i|'ia'"y 9081 of the NSWS is to collect baseline data which will assist regula-
tory agencies in setting up long-term monitoring programs to track Acid Rain de-
position. Phase III of the NSWS will address this need. If continued monitoring
is to be conducted on selected representative lakes under Phase III, the EPA would
need to select those lakes which exhibit the greatest threat of Acid Rain deposi-
tion (i.e. wilderness lakes exhibiting low alkalinity).
In Section 1.2 PURPOSE OF THE ACTION (p 2 para 3).it states, ...(2) helicopters
will not be used to gain access to wilderness areas during Phases II and III;
(3) in most, if not all cases, lakes to be sampled during Phases II and III can
be selected outside of wilderness areas;..." The request for helicopter access
by the EPA for Phase I has been reasoned on a basis of utility in sample transport.
During Phase III, however, it is stated that in "most, if not all" cases helicop-
ters will not be needed. If the EPA does not plan to monitor wilderness lakes
during Phase III for Acid Rain deposition, what relevance is there in the data
collected from these lakes in Phase I as far as it concerns meeting the main goal
of the NSWS. If the EPA DOES choose to monitor wilderness lakes during Phase III -
and logic is that this might be both desirable and necessary - then the same logis-
tical constraints for sample delivery will exist and helicopters will be needed
again (under present Analytical Protocols).
B. Random Sampling
The EPA has stated in the Scoping Document titled "LAKE SURVEY SUMMARY" (undated)
that "...we have chosen a sampling technique called random sampling. This allows
us to sample far less lakes than we normally would have to, and then extrapolate
the results of this sample to the area as a whole. One drawback is that after the
random sample of lakes has been selected, we cannot delete lakes from that list
• Airflow and hydronlc balanclng'HVAC ayslem analysis and Uoubleshoo1lng*mechanlcal system documentation —<
-------
X- "A Belter World
'^Through A Better Environment"
Environmental Testing & Balancing Inc.
P.O Box 594
Snoqualmie. WA 98065
(206) 643-1666
(206) 454 5450
3/19/85 Comments on NSWS - EA - page two
IB. Random Sampling (contd"
without invalidating the entire sampling scheme. This would make It Impossible
to come up with regional assessments from the lakes we do sample"
In the EA Section 4.1.7 Consequences to the Survey Objectives (p 68), It states
"Alternative 1 in this EA is identical to the survey protocol used successfully
in the East and Midwest in 1984. In the East and Midwest, most of the lakes to
be sampled were in fact sampled;..." The use of the word "most" Indicates that /
NOT ALL of the lakes in the random sample were actually analyzed. According to''1"' '"
cont the scoping document, this invalidates the entire sampling scheme.
The EPA is presently proposing the same random sampling for the western U.S. If
it will come under the same stringent guidelines set down in the East and Midwest
study, then serious doubt exists as to whether the EPA can accomplish their goals.
Our concern is that if early winter snow storms or inclement weather should pre-
vent the sampling of even one lake In a given random sample then, according to
the Scoping Document, the entire effort would be Invalidated. It is common know-
ledge that in the western U.S. early winter snow storms are common occurrences at
higher elevations.
C. Wildlife
1. Elk
In the EA Section 4.1.3 "Impacts to Wildlife and Endangered Species - Wildlife"
(p 61) it states, "Lakes to be sampled In Olympic National Park are In areas used
by elk during the mid-September rutting season (NPS 1985). It Is highly desireable
to avoid disturbing these animals during this time. The fact that effects are in
most cases relatively minor is supported by the widespread use of helicopters to
enumerate big game, including bears, mountain sheep and goats, caribou, and wolves
(Chapman and Feldhamer 1982)."
The Game Department does commonly use helicopters to disband elk herds for protec-
tion from hunters. This proves that a helicopters presence is effective In dis-
turbing or scattering herds of elk. And, a helicopter on a water sample retrieval
mission in September could not help but disturb the elk during their rutting season.
It appears there is an incongruity here and we feel this potential problem needs to
be given more consideration. '
2. Migratory Water Fowl
The impact on migratory water fowl was not discussed at all In the EA. Tha EPA
should address this important Issue and consider the following: 1) Many species
of migratory water fowl (i.e. Canadian Geese) use lakes located in wilderness areas
as temporary resting stops during migration; 2) If the EPA encounters flocks of
these birds on lakes to be sampled, on what criteria will they base their decision
on "if" and "where" to land?; 3) What precaution* will be taken to protect the birdf
if the decision it made to land?; 4) If a large flock of gee*e were (tartled and
«•» Into M«t«a p»rt» of th« aircraft, could tlH« cau» Che craft to malfunction .
S~ "A Better World^
^Through A Better Environment
Environmental Testing & Balancing Inc.
P.O. Box 594
Snoqualmie, WA 98065
(206) 643-1666
(206) 454-5450 • 3/19/85 Comments on NSWS - EA
0. Impacts on Bodies of Water
- page three
In the EA Section 4.V.4 ''Impacts to Water Bodies (p 62), the discussion on the
possibility of a fuel, spill does not address the potential toxic effects to the
lake's surface biological populations. Certain lake surface organisms are part
of the food chain of fresh water fish. A fuel spill could also render lake
sampling Invalid If aircraft rotors have an opportunity to mix the spill with lake
water to be sampled.
'E. Nolse'Criteria' '•-••*•
II.
A.
Noise criteria data referenced in the EA addresses only piston-powered rotorcraft
even though the probable craft of choice would be a turbine-powered rotorcraft.
As stated In the EA, there are many unknown factors with regard to sound levels
generated. It stands to reason that under certain conditions sound levels could
exceed those which are acceptable.
There are other potential sound level problems that the EPA has not addressed,
such as 1) sound-generated avalanches, 2) hearing damage to wilderness users in
close proximity to turbine rotorcraft, and 3) hearing damage to sound-sensitive
animals (I.e. bats).
Proposed Alternative to Use of Helicopters'
Sample Transport by Carrier/Homing Pigeons
Carrier/homing pigeons can be used to transport water samples'from wilderness area
lakes In the time-critical manner stated in the Draft Analytical Protocol (DAP)
with one slight modification. The DAP (also titled METHODS MANUAL FOR THE NSWS
PROJECT - PHASE I) specifies 60-ml syringes for sample gathering. Two 30-ml syringes
1n place of one 60-ml,syringe would need to be used to accommodate the bird's maxi-
mum carrying capacity.
This method Is simple, workable, technologically appropriate and carries minimal to
zero environmental consequences. A demonstration to prove the workability of this
method was conducted on 1 March 1985. With USFS, EPA, and media representatives
as observers, water samples were taken from a King County lake and transported via
carrier/homing pigeons to a pre-determlned site. It is estimated that maximum elapsed
time from sample retrieval at wilderness lake to delivery at analyzing lab with
transport via carrier/homing pigeon would be five hours. There 1s flexibility In
this method in that mobile rpoits can be established at trail heads and sample deliv-
ery time to a mobile lab can be cut down to thirty minutes If necessary.
Long-term monitoring (Phase III) using this method continues to have minimal to
zero environmental Impact.
-------
• "A Belief World ,~
^ Thfouflh A Better Environment'
Environmental Testing & Balancing Inc.
P O Box 594
Snoqualmie. WA 98065
(206) 643 1666
(206) 454 5450
3/19/85 Comments on NSWS - EA - page four
#45
cont
B. Pilot Study Proposal
To substantiate the ability of carrier/homing pigeons to deliver water samples
within the guidelines set in the DAP and to dispel the skepticism that accom-
panies new ideas, we propose a ten (10) lake pilot program. This pilot program,
financed by the EPA, would entail a comprehensive evaluation of all parameters
associated with meeting the goals of the NSWS. We would encourage close scrutiny
by members of the scientific community to evaluate the results and findings of the
pilot study. r •.,....
The relatively minor costs of running this pilot program would seem to be justi-
fied when compared with the larger financial and environmental consequences of
taking helicopters into the wilderness areas.
We hope the EPA will give careful consideration to this proposal to use carrier/
homing pigeons instead of helicopters for the NSWS Project.
END OF COMMENTS
.Airflo
and hydronlc bal«nclng-HVAC system analysis and Iroubleshoollnfl-mechanlcal system documentation—
MAR.31 '85,16:32 EPA OREGON OPERATIONS OFTKE
T E L E P H 0 N_E USE REPORT
LETTER w!4 T0 BE USEo ON Ai_L LONG DISTANCE
TELEPHONE CALLS, INCOMING C/R OUTGOING,
AMD ANY LOCAL CALLS MERITING RECORDING
PREPARE IMMEDIATELY - Sl'UMtT DAILY
KUUTirC,
II
He
.l /S>;lMst,V
r I ihy _
File
Or i^irut or
CALL FROM:
Gearheard
PREPAID
COLLECT £7
TITLE i
LOCATION &
CALL TOi
Director,
PHONE NO. i
Wayne
Oregon
Elson
Operations Office
TITLEr Environmental Evaluation Branch
LOCATION 1
PHONE NO. I
FTS
399-1828
DATE OF
CALL
TIME OF
CALL
DURATION
OF CALL
Check one
3/21/85
Completed
fl:03 pm
Par t 1 a^J
Tine
SUMMARY OF CALL:
I reported DEQ's position on the IISWS Wilderness Lakes CA. The1r position is:
DEQ recognizes the need to gather data on acid deposition in Western
lakes. DEQ supports efforts to characterize baseline
water qjality
and lake susceptibility to acidification. However, the use of
helicopters to collect samples in wilderness areas will violdtt State
rules at OAR 340-13-020. A variance from the rules will be needed to
allow the proposed use of helicopters. DEQ will have to be convinced
of the need for such/testing before recorrending that the :QC grail a
variance.
tm?
(Signature)
(Dote)
-------
LETTER
•11 Hilt tO:
W.ll i M.I 1
UNITED STATES
DEPARTMENT OF THE INTERIOR
FISH AND WILDLIFE SERVICE
Endangered Spt'des, Field Office
Federal Bldg., U.S. Courthouse
301 South Park
P.O. Box 10023
Helena, Montana 59626
March 19, 1985
Mr. Wayne I). Elson
KA i'rojoct Officer, MS 443
U.S. Krw i roninental Protection Agency
12HI) sixth Avenue
Kuattli?, WA 9R101
Dear Mr. Elson:
We have reviewed the Draft Environmental Assessment for the
National Surface Water Survey of Western Wilderness Area Lakes.
We wish to add the following comment to those we provided in
previous correspondence.
If an alternative involving horse and/or backpack access Is
selected by EPA for certain highly sensitive areas we recommend
that proi/er guidelines foe followed for back country use in
grizzly occupied areas. Since a variety of land management
agencif/s (Forest Service, Park Service, Tribal Lands) may be
involved under this alternative, we are willing to work with
you and these agencies to provide specific grizzly guidelines
appropriate for all areas of occupied grizzly habitat. If these
agencies wish to provide you with guidelines for areas under their
management we wish to review these guidelines to assure that they
.provide reasonable safety precautions in grizzly habitats and to
satisfy our joint responsibilities under the Endangered Species
Act.
We have no further comments on the EA or this project at this
time. Please contact us whenever necossary during further
planning and operation of this program.
Sincerely,
r
i\
Hillings, MT
Chayonno. MY
I ?&../•>•- •
Dale Harms
Acting Field Supervisor
Endangered Bpocioa '
LETTER #16
SEATTLE. WASHINGTON
STATEMENT OF
NORTH CASCADES CONSERVATION COUNCIL
Seattle, Washington
on
DRAFT ENVIRONMENTAL ASSESSMENT
of
NATIONAL SURFACE WATER SURVEY
WESTERN WILDERNESS LAKES
March 22, 1985
''-WI10NMENTH EVALUATION
BRANCH
-------
The Norili Cascades Conservation Council Is a membership organization,
founded In 1957 and dedicated to the protection of wild lands In the Cascade
Mountain range, from the Columbia River to the Canadian-U.S. border. The NCCC
has worked hard, for over 25 years, to establish Wildernesses and National
Park units in the Washington Cascades.
The NCrC appreciates this opportunity to comment on the Draft Environmental
Assessment of the National Surface Water Survey, Western Wilderness Lakes. We
aie deeply concerned about the impact of Increasing acidic precipitation on
the high mountain lake ecosystems, as veil as on the forest productivity and
regeneration on exposed ridge-line areas in marginal sites vhere logging has
or will occur. We are also very concerned about the proposed use of helicopters
to perform the water sampling from lakes in wildernesses, National Parks, and
other wilderness areas. Herein we have restricted our comments to the impacts
of the proposed sampling on the Washington Cascades,
1. Helicopters should not be utilized as the sole means of access to all
lakes to he sampled. This form of transportation should be justified
only in those specific instances where the analytical data obtained from
the water samples would be adversely affected by non-mechanical transpor-
tation. We urge the use of foot and/or horse transportation to all lakes
to be studied except in those specific instances where helicopter use can
be demonstrated to be essential. A lake-by-lake Justification for the
form of transportation selected should be prepared.
2. Each lake has specific environmental components of affluent leachate, •
adjacent vegetation, and submerged organic residue. The variations in
the magnitudes and proportions of these components would necessitate each
lake having its own control baseline analysis, to be compared with its
own subsequent monitoring analyses. Thus, access either by foot or
horseback or helicopter can be specified for each lake, based on the
necessity, not convenience, of using the selected transportation mode,
both for baseline sample collection and subsequent monitoring.
3. For the baseline, initial, control assessment of acidity in the lakes to
he significant, all subsequent monitoring assessments must follow the iden-
tical procedures of sample collection, transportation and analyses as used
for the baseline samples. Thus, if helicopters are employed initially at
a given lake, due to demonstrated necessity, they also would have to be
used each time that specific lake was monitored. Therefore, the frequency,
tiir.es, and duration of the sampling program must be designated before the
program starts. Once helicopter use is started on a given lake it may
well turn out that this will continue for years as the monitoring proceeds.
A. The spurious statement that the wilderness user is unaffected by the
intrusion of the helicopter on his wilderness experience is absurd.
Many of our members have complained about such intrusions at any time
during their wilderness trip.
5. We question whether the samples to be taken would be affected by the prop-
wash from the helicopter. According to our understanding, the helicopter
would land on the lake and would remain with its engine running for ap-
proximately twenty mlnutus while samples were taken. Prop-wash would
radically alter surface waters and possibly resuspend sediments in shallow
lakes. Helicopter exhaust gases may contaminate ourface watera producing
false results.
6. All the above concerns we have expressed apply to all lakes considered
for study. What is the specific justlfcatlon for each lake selected or
were they chosen at random?
Respectfully submitted,
Patrick D. Goldsworthy
Chairman of the Board
North Cascades Conservation Council
2514 Crestmont Place West
Seattle, Washington 98199
#54
#49
#50
#51
#52
#53
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SIERRA
CLUB
530 flush Socci, San Francisco, Califotnu 94108 (4IS) 981-8634
LETTER i.
22 March 1985
Vayr.e D. Slson •
SA Project Officer, X/S 443 LJ"
U.S. Environsental Protection Ager.cy
13CO Sixth Avenue f5 RAH 22
Seattle, Vs. S310!
K3: SATI03AL SUB?ACS VATSE SZJBVEY
VES72KI WILE3H53SS AH2A LAK2S
EHYTHOriJGZITAL 133353X231
DRA3T
EPA 91C/9-85-125
E«er Mr. Elacn:
?hank you for tte opportunity to connect on the draft SEvirociental
Asaesaxect concerning the prepczed Saticnal Surface Water Surrey as it affects
certain lakes in western wilderness areas.
0??ICIAL COXXZST3 C? THE SIS3SA CLKS
The draft document UBS aent by the EPA to nuxerous Individual leaders and
state acd local units cf the Sierra Club. I an sure that you have received
soissideraole coa=»«t frca Sierra Club leaders. These a&y express a variety of
viewpoints, all of which ve trust you will take under cocsideration.
However, as your proposal deals with a national study and has implications
for hundreds cf wilderness lakes asrcsa the entire Vest — as well as for funda-
aictel legal issues pertaining to the Satieaal Wilderness Preservation Systea —
tiiis letter is the official eteteoect o* the views, policies and legal
concerns ef the Sierra Club.
3IBHBA C18B
TS ACID 5AI3 E2S2ABCH -- AMP ACTI03!
•«jB
The Sierra Club Jus long been a leader in both the preservation of wilder-
neas and In tte effort to curtail pollution which contributes to acid rain. Ve
strongly supjson continued research oa the causes and effects of acid rain.
However, w« strongly disagree with the position of th* Beagsn Addinlatration and
the Environmental Protection Agtncy that additional research is prerequisite to
asy national progran to ccntrol sulphur dioxide sad nitrogen oxide ealasi-ins. Th»
wilderness lakes — acd the total wilderness enviroftaent — wbish are affected
ty acid deposition voisld te in better snap* today had the fteagan Adoio*»tration
not blocked acid rain control legislation for the past four years. TfcJU contin-
toature of intraiuiiaeace Vy tie Adoinistratlon haa rtaultei i» and will
result In serious, emulative iaaa*. ~ wilderness lakes, th.
*«n»r«li7 ana huan. heaitc.
J gA- *3 TH3 VROBO AGS3CY
![ £0 ASSESS ITS CVII PHOF03AL Ig Ag
A33ESSM3aT
Turning to the specific proposal you are advancing, ve oust iznediately
note that the approach being taken in the analysis of this proposal ia fur.da-
sintally flayed. It la HOT the responsibility of the Environmental Protection
igsicy to judge aad decide the Issues of appropriate access to federally-desig-
nated wilderness areas aad national parks. Sor is the SPA toe right agency to
formulate and judge aziong alternative Beans of access to federal wilderness areas.
In this regard, we are concerned that the EPA document — despite brief
allusions to the role of the land aanaging agencies — o&y seriously zisleed the
public.
To the degree that you needed to specify'the nature and requirements of
your proposal, this would best have been done directly with the laad reneging
agencies involved. It is those agencies which are required to evaluate your
proposal, consider alternatives, and provide for public involvecent ir. their
decision about whether to grant your request. In fact, the SPA in this xattar
is in exactly the sane position as any other applicant or permittee seeking a
particular special or ncn-conforzing use of the public lends. The curden of
satisfying both the national Environmental Policy Act end the Vlldemess Act
lies with the land oanaging agencies, not with the applicant.
tar exaople, a alnlng company seeking eotorlzed access to wilderness for
aineral developaent does not prepare the 2A or decide whether or not the
proposed action merits an E1S as opposed to en EA. Had toe US-3S proposed a
scientific study of mineral core sample3 free several hundred locations within
acores of wilderness areas in every western state, we would not accept tee 'JS3S
preparing the aeaessnent, or deciding whether or not this was a aajor federal
action. Frankly, this sketchy SA would not be considered adequate.
3ZPA STAIIDAHPS ARE TOT THE TEST SOB VTUERaESS ACCESS
The Environmental Aaaeasnent purports to asses* tha environmental icpacts
aesociated with the proposal for helicopter access to hundreds of vilderzeaa
lakes spread across tha entire Vest. It is written in s style which suggests
that EPA considers the aajor legal laaua'hare to be one arising under the
national Environnental Policy Act.
In affect, this analysis purports to ooepare the ESY1R03XZ3IAI. IXFAC7S
of alternative Deans of access to wilderness lakes. In aiuoarizing ita
rationale for preferring tha all-helicopter alternative (!lo. O, the EPA
uses standard SZPA language (p. 31, final paragraph): [*'
"Bo Irretrievable or irreversible comitneat of reaources would occur. j
Tha tenporary and largely nitigable impacte are not considered to be |
'significant' iapacts to the 'hunan anvironnact' under the National |
Environmental Policy let ...." I
Even aaauoing all the above-quoted EPA oonclualona to be true, they ara basically',
irrelevant to the decisions required If helicopter aoceaa ia to ta penitted. j
•or ia it up to tha EPA to "consider" whether theae lupacta exiat cr an "signif-l
leant." That declaiou nets with the Secretary of Agriculture or the Secretary j
of th» Interior, dapendinc on «!>• particular vlldanun; or park Inrolnd j
-------
Th« Issue to be decidad ia HO? vhether the proposal involves
apacts" to the "huaan environnsnt." 3or whether those ispacts
no-, with SPA.
"significant lnpacts~ to the 'huaan environnsnt." SOT whether those ispacts are
"•Veaporsry" or "cltigable," or are "irretrievable" or "irreversible." Under
"Affected Environment," the SA treats authorization for motorized estry only as
i j.hilo*ophic»l discussion of wilderness values. It is not. It ia en interpre-
tation of law — the Wilderness Act.
Wilderness areas have been designated, in the Wilderness Act and in indivi-
dual statutes, "for preservation sni protection in their natural condition..."
[Vilderneaa Act, Sec. 2(a)]. The lav ia clear: the introduction of cechanical
acd =otorited contrivances is antithetical to this purpose.
The Vildercess Act does provide for effective aanageaect of wilderness areas
The Secretary cf Agriculture and the Secretary of the Interior have certain nar-
rowly drawn authority to perait ineiapatible activities or installations within
wilderness areas. The whole thrust of the lav is, however, to assure that these
izccipa:ible intrusions are allowed only ic extraordinary circuits tances. In such
£C3£s — which clearly aust be weighad on a site-specific, case-by-case basis —
It aust te detercined by the appropriate Secretary that any such proposed intru-
sion is "neceaaary to rest niriauj reauirexents for the administration of the
srsa for the purpose cf this Act..." [wilderness Act, Sec. 4(c) eephasis added],
This dual teat of both necessity and rinimua intrusion is Epecified in
Diction 4c) of the Wilderness Act- It haa been reinforced by repeated congres-
sional directives, set forth in conaittee reports fron toth the House end the
That decision has to do with whether — on a lake-by-lake basis — the sam-
pling proposed by EPA is necessary and, if it is, whether helicopter access is
ths ciniaua neaas cf access in tens of intrusion oa the wilderness. The-
iffir=ative duty to Bake the decisions lies upon these officials, not the SPA.
The statute which aust be applied is the Wilderness Act (read in the light cf
the additional requiresnta of SIFi) , not JiE?A itself.
As it stands , the EPA document does not persuade toe Lay reader that
helicopter access is necessary these nearly 5CO wilderness
isjces. Sor does it persuade the reader that the alternative of horae-party
icceas ia incompatible with the SPA e ar.pl i^g protocols.
In fact, on the basia of a careful reading of the SPA document, ve are
persuaded that the use of helicopters — as opposed to hcrsecack or other non-
ECtorized access — ia net essential and is baaed alaost entirely upon effi-
ciency, convenience and purported cost savings. Tneae ere factors not permitted
to affect the land caoageaent egency'a decision required by the Wilderness Act.
However, the issue ia not whether thia SPA document is persuasive. Without
regard to SPA1 a assertions, it will be up to the Secretary of Agriculture and
the Secretary of the Interior, and the land managing agencies reporting to then,
to arrive at their cwn conclusions on these points in asking the tests required
by the Wilderness Act.
LAKE XAMASISC AGEiCIZS MUST ASSS33 VnETHSR TKS S?A
"FEOFO'SAI. rs"'T:i7csssA?.Y" A:JB "SI:;IX-JM." JICT E?A
#56
'cont]
Ve assert that the proposed access by SPA ia in no way different from any
other request for an inccapatible use or installation within a vilderneaa area.
your proposal involves a core worthy purpose (scientific research on acid
rain) than others does not aak« it subject to any different, leaa stringent
standard of decision for the Secretary involved. The Wilderness Act creates no
euch "superior" class of nonccnpetible uses.
The Forest Servio and the national Perk Service nuat treat your proposal
jest as they would any other request for introduction of a nonccapatible uee
into a wilderness area. They oust satisfy theaaelves — on the record, not by
sorely accepting SPA's assertions — that the proposed use is Indeed necessary.
for exeaple, they oust ascertain whether the aaaclingprotocols do indeed
the kind of turn-around tines for access you assert. Their cwn experts
in water analysis can help, and they have available disinterested consultants
(for exaaple, the national Acadeay of Sciences).
They oust also consider whether, if neceasary, your requireaect for access
can te net in a more "ainiaum* vay, that ia less inccEF^tifcls with the wilder-:
SSS3 character (not just environment) than your proposal. They say not, under
the lav, nerely accept your assertions in thia regard. 3or aay they accept a
svaeping generalization that all of nearly 5CO lakes nust be accessed in the
aa=e fashion.
The Forest Service Manual cited on page 36 of the EAatatea that aircraft ney
bs used when "either an administrative or a cooperative activity essential to
tea management cf the wilderness cannot reasonably be accomplished with prini-
tiva methods or by mechanical Deans. In determination of what ia reasonable,
there must be a showing that the need is based upon cere than the efficiency,
convenience, and econoay..."
SPA (leaonatrates precisely the opposite in its environmental assessment:
that ia, that the use of helicopter landings in every lake is cot essential to
the aanageaent of wilderness and th« selection of helicopters over other alter-
-ptivea for every lake is based almost entirely on efficiency, convenience', and
economy.
TgI3 DECISIOa HAY OSLY BE MAIS 03 A
••1L3E;Ul£SS-BY-WIU)5H;i£SS. CASS-Bt-CASE BASIS
It ia a fundamental error for the Environmental Protection Agency to pro-
pose that the land managing agencies consider this isttar of helicopter access
on a Meat-wide basis. That is not how the lav ccanar.ds the Secretary to reach
his decision. Each intrusion into each individual lake in each wilderness area
— for however worthy a cause — sust be considered and decided on its own
=erita, in the site-specific circuitstances of that particular area.
The courts have consistently ruled that broad, generalized analysis and
evaluation of wilderness qualities ie unacceptable. The courts have held — and
been affinaed on appeal — that such analysis must provide site-specific con-
sideration [State of CA_ vs. Block, 690 ?.2d "53(9th Cir. 1932). The Cocgress
has, en nunerous occasions, expressed its strong support for this view.
The parallel to your propoaal is exact. If the qualities of proposed
wilderness areas oust b» given site-specific evaluation by the agency studying
their possible designation, then certainly proposals for inconpatible intrusions
oust have equally site-specific evaluation. It is this iasue on which the
Sierra Club haa grane concerns as to the precedent involved in your proposal —
not the ioine of helicopter access p«r s«.
-------
Helicopters hov» been perait^ed to enter wilderness areas in the past,
ecd for a variety of reasons consistent with the Vilderneas Act. Ye are not
f.36*rting that helicopter access per ae is barred by law in every instance for
*','ery lake is which it is being proposed. But it nay be tarred by law in cany
--• even zoet -- instances.
Whether helicopter access is to t« allowed to the specific lakes you pro-
pose is a satter to be decided on a case-by-case basis, lake-by-loke by the
Secretary involved, in view af the particular circumstances and alternatives
-^atch cay be applicable and practicable in each case.
Weighing against this clear legal requirement are the needs you assert for
access which assures adherence tc the saipiir.g protocols of your study. These
=rs importance concerns -- but cct ones on which the assertions of the applicant
can be takao by the appropriate Secretary as definitive. If an applicant for a
Ejnccr:forming use within a wilderness area aay siaply assert conditions which
sake only one fon of access practical, we will have allowed a most dangerous
precedent.
?tia EA is clearlj inadequate to the task of evaluating each individual
Iske, each assessment of standards. An EA could be produced for each lake or
perhaps for each wilderness so long as it is understood that within a single
vildsrnesa aoce lakes jiay iset the standards for helicopter access and seme nay
not. However, if tha Forest Service should choose to assess several hundred
iiiraa in one document, it would necessitate a full Environmental Icpact State-
sent, not this sketchy Environmental Assessaent.
SUMMARY
The Sierra Club strongly supports action to stop the pollution which causes
avid rain. In this regard, we support research to identify effects of acid
deposition, including within wilderness areas and national parks. We viah it to
fee clearly understood that we dc not oppose the National Surface Vater Survey in
tz>7 way. 'lor do we oppose conducting such research within wilderness areas.
The question of what fora of access is to be permitted for such aanpling
within wilderness areas has been improperly portrayed in the EPA document. It
ii not EPA's place, as the applicant for a non-conforming use of hundreds of
wilderness areas, to define the environmental impacts nor to franc the alterna-
tives. Us regret the public confusion the EPA document nay cause in this regard.
Decisions about the fom of access into each wilderness lake must be made
irr the land sanaging agency on a case-by-cas* basis. Just as they nay not make
a blanket decision to pa nit helicopter access to all of nearly 5CO lakes
(without a finding that no other fom of access is practicable to any of those
lakes), so they cay not Bake a blanket decision that helicopter use la
inherently prescribed ia all cases.
It i* the purpose of this latter to coaaent on the EPA draft Environaental
Aasefluner.t. Ve consider th« SA to be legally inadequate on its face. Excep-
tions to the VilderMso Act are cf such significance, under tht law, that or.ly •
lite-specific analysis is adequate. However, it la the responsibility of the
3acr*tary of Agriculture and the Secretary of the Interior — not ?PA « to
prepBre aa anvlrcnaectal aaaeaaaant or full environmental iapaot atateaont on
tbiB xatteiS they, not the SPA, should evaluate the proposed nonconfomlng use
tffc1
cont
of each wilderness lake as to its necessity. They, not the E?A, should formu-
late alternatives, going well beyond .those considered in the SPA document.
They, not the EPA, must consider the legal requirements and liaitatior.s imposed
cy the Vilderneas act and other applicable lay.
The Sierra Club expects to take a vigorous role in the decisions pertaining
to access to each lake in each wilderness area, working with the responsible
land canagiag agencies. Because we believe that site-specific evaluation and
decisions oust be reached on • case-by-case basis, our individual chapters in
each western state will deal with each wilderness area, applying the national
Sierra Club policy outlined in this letter.
We appreciate the hard work evidenced in the EPA document. Ye corner.d the
SPA for vigorously pursuing inportant research on acid rain. And we appreciate
this opportunity to offer our views.
Sincerely,
Xicnele Perrault
President
SIERRA CLUB
FEDERAL GOVBRHHE3T DISTRIBUTION:
Hon. John Block, Secretary of Agriculture
Hon. Donald Kodel, Secretary of the Interior
Hon. Lee Talbot, Adnicistrator, Environaental Protection Agency
Bernard Goldstein, Assistant Adainistrator for Research and Eevelopcent, EPA
Erneeta B. Barnes, Regional Administrator, Region 10, EFA
Robert M. Reed, Environaental Sciences Division, Oak Ridge National Laboratory
Max Peterson, Chief, Forest Service
Russell Dickinson, Director, national Park Service
Regional Foresters, All Affected Regions, Forest Service
Regional Directors, All Affected Regions, National Park Service,
i
SIERRA CLUB DISTRIBUTION
Regional Vice Presidents, All Affected Regions
Regional Conservation Committee Delegates, All Affected Regions
Chapter Chairs and Chapter Conservation Chairs, All Affected Chapters
Roae Strickland, Chair, a All Meatera, Public Lands Cojeittae
Vivian Li, Chair, Air Quality Coaaittee
Field Offices
SIERRA CLUB LEGAL DEFENSE 7USD DISTRIBUTION:
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-------
LETTER #18
THE WILDERNESS SOCIETY
CHAKl.tS M CLUSEN
VU L I'KIMDLMT • LONSLKVATION
21 March, 1985
Wayne D. Elson
EA Project Officer, M/S 443
Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Elson:
The Wilderness Society has received the Environmental Asse'ss-
ment of the National Surface Water Survey (NSWS) for Western
Wilderness Area Lakes and would like to comment on the
assessment.
We are sympathetic to the goals of the NSWS and are concerned
with acid rain degradation of wilderness areas -- as well as of
non-wilderness lands. We recognize scientific research as one
of the objectives of the Wilderness Act and support the basic
intent of EPA's proposed survey. However, the preferred
alternative of helicopter access for all lakes in the survey
raises several major problems that are not answered in the
Environmental Assessment. In addition, the precedent of
allowing helicopter access into wilderness areas is ignored.
We must, therefore, oppose the Survey until and unless these
questions are adequately addressed.
in the EA, you state tnat you met with Forest Service officials
in late 1984 to discuss the Survey. Yet you had already
completed the eastern and' midwestern portions of the study
before beginning to scope the EA necessary for the western
portion of the project. Given the size and importance of this
project, it is possible that involving Forest Service officials
-- as well as state officials and other interested parties --
in determining the design of the whole project, modifications
could have minimized the number of wilderness lakes included in
the survey. Too often an environmental assessment is
considered a hurdle to be overcome rather than a helpful part
of the decision-making process. This Assessment appears to be
an example of such thinking.
I iOO EYE STREET, NW, WASHINGTON, D.C. 20005
(202} 8-12-3100
#59
#60
Wayne D. Elson
21 March 1985
Page Two
The Environmental Assessment states that the -use of helicopters
will be limited to Phase I of the survey. It does not explain
why helicopters will not be necessary in Phases II and III --
or why " regionally representative" lakes can be used in Phases
II and III but not in Phase I. Indeed, given the emphasis
placed on the proposed protocols for short holding times, the
EA does not explain how Phases II and III would work. The EA
is disingenuous in ignoring the fact that if the Environmental
Protection Agency surveys 498 lakes in wilderness areas,this
baseline information may well be included in later studies --
which could include requests for helicopter access in the
future. It may be impossible to quantify additional requests
for access, but the possibility should have been acknowledged
and discussed in the EA.
The Environmental Assessment includes a section of a USDA
regulation stating that the use of aircraft must be ' based on
more than efficiency, conveniience, and economy." Yet only 2
pages earlier,at the bottom of page 3, of the 4 reasons given
for proposing helicopter use in wilderness areas, 2 are clearly
for the convenience of the agency. And it is nard to believe
the last of the 4 reasons -- that helicopters are safer than-
access on horseback or foot. Later, on page 24, the downtime
due to bad weather or mechanical problems is identified as §0%
-- which seems to contradict the earlier listing of the bene-
fits of helicopters.
We were also concerned with the decision not to consider foot
access on the grounds that consequences would be the same as
those caused by using horses. We do not believe that this is
true. Access by foot would often create much less damage to the
wilderness than would horse access.
We respect the responsibility of federal land managers of Class
I areas to protect those areas. But this is a secondary goal
of the proposed survey and protection of wilderness lands is
sacrificed for the primary goal of the survey. As we read the
Wilderness Act, helicopter access should not be allowed for
this project because it is not essential for managing wilder-
ness areas. We would hope that the EPA modifies its proposals
to meet these concerns. We were less persuaded by the urgency
expressed by the EA than we might have been had the Administra-
tion not just proposed delaying the acid rain program of the
Forest Service.
Section 4(b) of the Wilderness Act states that "each agency
administering any area designated as wilderness shall be
responsible for preserving the wilderness character of the
area". Helicopter use in wilderness will disrupt the
-------
Wayne D. Elson
21 March 1985
Page Three
wilderness character of designated areas -- as will acid rain
deposition. Therefore, a method must be found to protect
scarce and fragile wilderness resources from both acid rain
damage and from the intrusion of helicopter use.
The EPA's proposed survey should be evaluated as other
non-conforming uses of wilderness are evaluated by federal land
managers: the Forest Service should prepare an environmental
impact statement to consider the use of helicopters in 498
lakes in designated wilderness areas, with this EA serving as
the application for a non-conforming use. The standards set
forth in the decision of the Ninth Circuit Court in State of
California V. Block provide that the EIS's "form, content, and
preparation foster both informed decision-making and informed
puDlic participation." This standard has not been met by the
EA, but we believe site-specific information prepared by the
land managers will answer many or. the questions left unanswered
by the EA.
Sincerely,
#66
(CONT)
#67
Charles M. Clusen
Arizona • Colorado • Idaho
Montana • Ulati • Wyoming
National Audubon Society
ROCKY MOUNTAIN RL(!IO\A1. OFf-'ICL
4150 BARLEY, SUITE 5. BOULDER. COLORADO SWOJ fJW; 49V 0219
March 20, 1985
Wayne D. Elson
EA Project Officer, M/5 443
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Dear Mr. Elson:
We appreciate having this opportunity to comment on the draft
Environmental Assessment for the National Surface Water Survey, Western ,
Wilderness Area Lakes. Our major concerns with the proposed action involve
lakes in Montana, Idaho, Wyoming, Colorado, and Utah, and specifically
potential impacts on the threatened grizzly bear (Ursus arctos).
A number of the lakes proposed for sampling are located in occupied
grizzly bear habitat. From reading the EA and from conversations with U.S.
Fish and Wildlife Service personnel, we conclude that the survey will, in
fact, probably not impact this species in any substantial way. The lakes
sampled are primarily at high altitudes, time of sampling would be limited
to early fall, and the sampling itself is a one-time event. Even if
helicopters were used in every case, disturbance to grizzlies by a one-time
flight would be temporary and minimal. The season of sampling is important;
in the fall, grizzlies generally move to lower elevations, seeking the food
necessary to tide them through hibernation. The bears may not be present in
the sampling areas at all.
Me have to qualify these statements, however, by noting that repeated
passes by helicopters at low elevations can substantially disturb the bears.
Thus our conclusion of minimal or no impact depends on the flights being
strictly limited as to height above ground. The machines should fly only on
the predetermined route; no low-elevation scenic touring en route to or from
the targeted lakes should occur. This would help to minimize impacts on
other sensitive species, as well.
#68
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- 2 -
- 3 -
The question of motorized access into wilderness areas also concerns us
greatly. In this case, a survey to collect desperately needed, and
crucially important, ddta on the bio-chemical characteristics of
high-altitude lakes is at issue. There can be no question that the data are
necessary to develop public consensus on strategy to deal with acid
precipitation. It's also obvious that the data must be of high quality,
comparable to those collected in other parts of the country, and legally
defensible. Wu agree with you that the eventual impacts of not collecting
such data will include long-term damage to aquatic ecosystems and forest
productivity, inside and outside wilderness areas.
There is constant pressure on wilderness managers to allow motorized
access in Wilderness for various purposes. While the Wilderness Act does
provide some flexibility on this topic, each case needs to be well explained
and justified. This is where the draft EA needs improvement.
Our suygtstions:
1. EPA should take a case-by-case approach and determine the degree of
accessibility of each lake specifically.
2. Examine other alternatives in more detail, rather than rejecting them
out-of-hand. For example, the National Outdoor Leadership School has
submitted a proposal to access the lakes on foot. This would certainly
protect wilderness values, but what are the implications for data quality?
This ana other proposals may turn out to be infeasible, but you should
carefully consider them before so deciding.
3. Above all, clearly define the terms "accessible" and
they apply to the lakes under consideration.
'inaccessible," as
#69
#70
#71
If It is determined that helicopter access is the only method
available, we urge you to plan the survey to minimize conflicts with other
wilderness resources, such as wildlife.
Again, let me stress that this case seems unique. The long-term
effects of acid precipitation threaten the very integrity of our Wilderness
system. The seriousness of the threat in this instance may well justify use
of motorized access to Wilderness. However, we view this proposal as a
one-time, limited exception to the general prohibition on motorized vehicles
in wilderness.
Thank you for considering our concerns.
#74
Sincerely,
Pauline D. Plaza
Issues Specialist
Jksus.
Dan Taylor
Jay Copeland
Chapter Presidents
We have gotten conflicting statements from scientists in this field
about the need for analysis of samples within 12 hours. Generally the
feeling seems to be "the sooner, the better." There is also evidently a
question of making the data comparable to those collected elsewhere. If the
12-hour analysis is the common standard, please say so. We would regard the
need for consistency in the data set as a valid reason for requiring a
12-hour turnover.
We believe this proposal is part of an important and needed study of
national surface water conditions; In order for the data to be useful for
national policy decisions, they must be consistent with data already
collected. However, motorized access into wilderness, even in a good cause,
remains a difficult, controversial issue. In this context, we would urge
EPA to look carefully at each case where access is necessary and determine
v,hat methods can both protect wilderness values and provide the quality of
data needed. Ue firmly believe that wilderness areas can and should serve
their valuable function as an ecological baseline in this case. However,
the case for motorized access must be clearly justified. Non-motorized
access should be chosen if it is suitable and available.
#72
#73
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LETTER #20
Ivjjue D. Elson
E.'X. Project Officer M/S 443
U.S. Environmental Protection Agency
1200 Sixth Ave.
Scuttle, KA 98101
Do-jr Mr. Elson,
March 22, 1985
I am pleascJ that the EPA is attempting to obtain baseline data on the
current level of acidification of western U.S lakes. Having lived in Wash-
ington State all my life I have seen the visual effects of metropolitan air
pollution spreading farter into the Cascade valleys and worrier how severe the
effects nay be on the forests and waterways of the Cascades and other areas.
i lave spent much of the last 16 seasons in the high country of the Cascades
ard been to many of the lakes which are proposed to be sampled. I also have
been intimately involved with the management of the wilderness areas and Nat-
ional Porks in the state and have worked to keep motorized intrusions to a
minimum in these areas.
My general impression of the EA was that it gave no reasonable alternatives
to the use of helicopters samplling to complete the survey. Instead, it
scons, the document is a strongly biased justification towards the use of
helicopters for convienience and simplicity. Long sections in the EA discuss
the noise produced by helicopters and how severely peoples "wilderness exper-
ience will be iranactaJ by Alternative 1 are examples. Another example is
table S-l which as +'s, O's, and -'s to indicate effects. Here + = "pos-
itive effect", 0 = no effect, an - = a "minor negative effect". An unbiased
EA vculd have left this as a "negative effect".
There is a definite lack of creativity in caning up with the four alternatives.
There are many intrepid hikers in this state who ccmnonnly pack rubber boats
to wilderness lakes and wilderness rangers who pack all sorts of strange objects
into the wilderness. The EPA should investigate the use of volunteer groups,
such as Volunteers for Outdoor Washington, and also investigate the possibility
of contracting some of the work out to the Porest Service.
#75
#76
#77
//78
page 2
What bothers me most about the proposed use of helicopters is that there was
no effort on the part of the EPA to comply with the spirit of the Wilderness
Act. It may not be any great disaster landing a helicopter on a remote lake,
but it is a violation of the Wilderness Act frcm which government agencies
should not be exempt. EPA should have designed its study, to begin with,
under the assumption that motorized equipment would not be allowed in the
wilderness areas.
In addition to the above comments I have the following specific Garments on
the proposed study:
1) There are no sites to be sampled in Nevada and only a few in the desert
SW. Is this due to the low precipitation in these areas or because there are
fewer sensitive lakes. Since acid precipitation nuy be ira portant in causing
soil damage should not these large areas dwonwind frcm the California metro-
politan areas and coal plants in the Four Corners area be surveyed?
2) Crews reaching the lakes in the study by foot travel may be able to
sample sane lakes during inclement weather which would be inaccessible to
helicopters.
3) Would helicopter exhaust have any effect on the surface samples?
4) On page xiii it is mentioned that a sample packed out on horse back may
shake a lot which would effect the samples quality. Why do you feel that
shaking by a horse is any different than shaking by helicopter?
5) I would like clarification on the claim made that the NSWS data would be
of use to wilderness managers. It looks like the data will be useful to law
makers, urban planners, and those legislating acid precipitation regulations.
Thank you for considering my comments and I look forward to seeing a copy of
the final E.A.
Sincerely,
Gary Paull
P.O. Box 1973
Cholan, HA 98816
#79
#80
#81
#82
#83
#81
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LETTER #21
Washington Wilderness Coalition
P.O. Box 45187, Seattle, WA 98145-0187 (206) 633-1992
22 March 1985
Wayne D. Elson
EA Project Officer, M/S 443
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Elson:
The Washington Wilderness Coalition (WWC) appreciates this
opportunity to address the .National Surface Water Survey, Western
Wilderness Area Lakes, draft environmental assessment (EA). The
WWC/ consisting of over 1000 individuals and 30 organizations, is
dedicated to the protection, preservation, conservation and sound
management of wilderness, public lands, wildlife and water
re-sources of Washington State. Our organization was deeply
involved with the establishment of the new Wilderness Areas by
the Wcishington State Wilderness Act of 1984, and is currently
participating in resource allocation and wilderness management of
these areas and other lands in the U. S. Forest Service's Forest
Planning process.
COLLECTION OF DATA
The WWC strongly supports the collection of data on the effects
of acid cain in lakes both inside and outside of Wilderness
Areas. Establishing a baseline on lake acidity is essential to
monitor the increase in acidity and thereby to assist the
Liyeticiiii; dud the public to better combat air pollution.
Despite fcorm; rumors to the contrary, acid precipitation
constitutes a serious threat to the aquatic ecosystems of
Wuf;hin'jton Stdtc-. We arc particularly concerned about the water
quality in the Alpine Lakes Wilderness Area, due to the lack of
buffering agents on the water combined with the proximity of the
area to the large industrial centers of Puget Sound.
- 1 -
USE OP HELICOPTERS
Despite our concern over the water quality of the lakes,
especially high alpine lakes in Wilderness Areas, however, we are
appalled by the notion, as described in the EA (p. 1), that
"sampling protocols established for the national survey call for
the use of helicopters to gain access to lakes for sampling."
In no way has the EPA proven within reasonable doubt that the
use of helicopters is the only way that this study can be
accomplished. The EA reads like a justification for the use of
helicopters, with page after page of discussion about why
helicopters should be allowed. The discussion is intended to
lead the reader to believe that helicopter use constitutes the
most efficient and convenient means of water sample collection.
But this is not the point.
The point is that Wilderness Areas have been established to
protect the wilderness and wildlife resources and to provide for
primitive and unconfined forms of recreation. Activities within
the Wilderness Areas must be in compliance with the Wilderness
Act. Nowhere in the Wilderness Act are allowances made for
vehicular use based on efficiency, convenience and economy.
Helicopters flying into nearly 500 lakes in the West would
constitute a major disruption on those areas. We maintain that
the proposed action is illegal, that none of the exceptions ,
listed in Sec. 4(c) of the Wilderness Act of 1964, which allows
the use of aircraft only "as necesssary to meet minimum
requirements for the administration of the area for the purposes
of this chapter (including measures required in emergencies
involving the health and safety of persons within the area),"
apply to this proposed EPA study.
ARRAY OF ALTERNATIVES
The EA is limited in its array of alternatives by discussing
only four options: helicopters, horses, helicopters and horses,
and no action. The section regarding on-the-ground access has
been severely restricted to include only discussion of access by
horses.
The EA fails to discuss the most obvious type of access, by
foot. The EA fails to address the use of volunteer teams of
hikers, which could bo organized to carry the goar in
-------
LETTE
if the use of volunteers to conduct the actual water sampling
docs not fall within the rigorous scientific procedures required
by the KPA, hikers could still provide a major contribution to
this project, namely their rausclepower.
In cases of tight timing, the strongest hiker in the party
could be loaded up with the water sample and he or she could head
for the trailhead, leaving the others to pack up the equipment
and boat and hike out more slowly. Plenty of opportunities exist
to t-nlist the aid of college students, or Eagle Scouts, or
Outward Bound, or Volunteers in Outdoor Washington, or others who
could be brought into the project. The net result would be
completion of the project in a legal manner, a stronger
cooperative effort between the EPA and the citizenry, and an
improved public image in the press.
Other methods do exist, such as that proposed by Environmental
Testing and Balancing. In the case of very remote lakes, the
syringes could be sent out separately (or flown out, in the case
of the carrier pigeons, or run out) from the rest of the sample.
Those experiments which are time-critical could then be conducted
on those water samples.
CONCLUSIONS
In conclusion, we wish to restate our strong support and'
endorsement of the acid precipitation study. The data is
essential to future monitoring and controlling of air pollution,
in addition to protecting of our alpine lakes and their
ecosystems.
At the same time, however, we are disturbed by the view
advocated by the Environmental Protection Agency that the only
way for this study to be accomplished is by use of helicopters.
We challenge the EPA to be creative in the development of this
project. Hays do exist for major sampling to take place by
primitive or non-mechanical means. Me strongly encourage the EPA
to explore and utilize those non-mechanical means in this study.
Thank you very much for this opportunity to comment.
Very truly yours,
#36
(CONT)
Executive Director
1
mm mm SOCIETY
1720 Race Street Denver. Colorado 80206
. Hare'.. 22,
Wayne' D. Klson
SA Project Officer, !:/S U3
U..". "nvironi.iental Protection Agency
1200 Sixth Avenue **" "
Seattle, HA 9U101
Dear Sir:
On behalf of Denver Audubon Society, I would like to su'aiit tho following
comments in re the Draft r.nvironaontal Assessnont for the i r.tior.r.1 Suri'r.ca l.'atc-r-
Survoy (:
relating to Western Wilderness Area T.a&-s.
I./
He fully nr;rce to the importance of II3W3 for lonj rar.jc- policy planning T.O
mitigate acid deposition iapacts, and reeojnize iu this rosvoct t:.e L-..::or LEH jo of
high altitude lakes of low alkalinity, nany of which aru ir. uiliioiT.csa ar-'as.
nevertheless, it cannot bo too strongly stressed that it is Phase II and Those
III of liSi.'S what will provide most of the inforir.ai.ion on acid deposition impacts on
individual lakes. It is only in these phases of ..'£'..'3 — which do not involve use
of helicopters— that the crucial data will bo acquired on seasonal effects, change;-
over a period of tij;e, and biological lupac-ts. Phase I without 1'hace II uould
make little sense for the study of acid deposition impacts. Soue of U;o lakes
selected for Phase II, and possibly for Phase III should be within wilderness.
On the other hand, perhaps tho strongest ar^mcni for the inpartaucc of 1-ha.so }
is that it will help to resolve questions of location of lakes of highest risk to
damage by acid deposition, and guide the selection for H.AEO II a;'.d rhasc III.
a./
With some reservations, we tend to ssree that to acquire data of the quality
needed for Phase I of !.'S'>!3, helicopter access to the lakes is needed. '..'c find
no reason to question the conclusion that tiic helicopter insult to wilderness values
would in Qonoral, barring accidents, bo limited and teaporary in nature.
At tho saiao time, thu principle of eli-Tiinatin^ notarised acioss to '..'ilderness
Areas seems to us extremely important. helicopters do not roprssor.t tiie :.iisiirju:a
tool for cottinj tho data. If alternative i.-.odos o..' aooosa are cor.s i.\cro j , the
iuaue appears to bo whoti-.cr souio dotoriorAtion in quali>.y con.rol on the data for
uildornoss lakes, and soao lojjistie incor.vonier.ccs, can co toliiraiod .wit'aout
tho objuctivoa of i:s;ir..
It should lo lucumlcnt on i!l:A for each wilderr.ess lake proposed for s^udy to
roasBoso ito importanco to tho data base for Ion,; raajo policy planr.inj, ant! to
olimlnalo uoLorizod aceuzo whorovor feasible;— for exur.iji.le, by sulstituLiit,; a lake
outside of Wilderness, or by reducing tho nusibor of lakes sampled, or usin'; teaus
on horseback. In nalcinj jud^oracnts, -FA should not lose sir;ht of the special
importance of Phase II, rather than Phase I, for louj rattle policy planning.
in l?ia. 3.S-Z and Tablo
of tlia Uraft.
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LETTER #23
•• 2 —
Uiat an extraordinarily lar-e nucber of lakes are proposed for Phase I
sar.pl i:ij in the area which includes Socky Mountain National Park, the "ever
Sunnor Ranee, and the Indian Teaks Wilderness: A total of 48 lakes, or 30"
of the total in and out of uilderness proposed for all of Colorado. In the
short tiiie "uir.dow" for access to these hi{;h altitude lakes in early fall, this
ir;pli<;s an isaact greater than just the sua of individual visits. Surely there
is reciuiidancy here I Would it truly conprosixe the study to scale back some of
this?
"'his concentration, one suspects, arose in the random selection of a
preconceived number of lakes out of the very liaited pool of high altitude lakes
of low alkalinity. It is true, to be sure, that each lake is a case by itself,
but would it not nake sense to trade a cut in the proposed nunber for Phase I
sar.plin; in this area for attention to a few nore lakes during the more meaningful
Phase II?
Sincerely yours,
1/90
con
Francip 3. Clou^n, Ph.D.
r, Conservation/Wildlife Conmittee,
Denver Audubon Society
K.I'.. I'.ecd, Invir. Sci. Div./0?.:X
Lois Webster, DAS
Karen I-iollwoj, JAS
:iiff Ilerritt, DAS
Polly Plaza, ::atl. Audubon Soc., Western Region
llv Sierra Club
Rocky Mountain Chapter
N'ilS CO.'1'.-U I'TUB
...TO EXPLORE. ENJOY AND PRESERVE THE NATIONS
FORESTS, WATERS. WILDLIFE AND WILDERNESS..."
Wayne D. Slson
EA Project Officer, M/S 443
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 90101
Dear Mr. Elson:
The Rocky Mountain Chapter of the Sierra 31ub supports the National
Surface Water Survey in an effort to establish uaseline values for
lakes in our National Wilderness preservation jyste::i. The importance
of the baseline values will allow wildaraiess managers to assess the
impacts that man is having in wilderness areas. It is. therefore,
extremely important that the acquisition of the samples that will
provide the baseline values be accomplished in the :nost sensitive
manner.
Suggestions have been made that any helicopter access to re.-note
wilderness lakes which cannot fall within the twelve hour "sa-nple-to-lab1
criteria will further widen the door for helicopter access for any one
of a number of reasons. The Rocky Mountain Chapter does not totally
subscribe to that fear. However, we strongly recommend that a full
review be made before method of access to the moot ru;note lakes is
placed into action. It is imperative that the acco;;^ procedures; main-
tain the hitfhtest regard for the wilderness rouource.
The Rocky Mountain Chapter wishes to thank the rJPA for tne opportunity
to respond to the Draft Environmental Assessment.
#91
Since
i-'artin aorensen
Chairman
29303 Spruce Canyon Drive, Golden, CO 801(03 (303)
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LETTER /,'24
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C**- •'« «JJ<^1V>« AC.'tA. renT«M;n«-7*-o>O of Aracrjc*-! u«.Ter.S. C.eptmonlr' .Sue** ^r»«r«r
LETTER #25
Hen only- after c'iJCJ arc.
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SIERRA CLUB ... Oregon Chapter
March 21, 1985
Wayne D.Elson
EA 1'roject Officer, H/S 443
U. S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, HA 98101
RESPONSE TO
NATIONAL SURFACE WATER SURVEY
WESTERN WILDERNESS AREA LAKES
ENVIRONMENTAL ASSESSMENT
Iwould like to take this opportunity, on beha
Chapter of the Sierra Club, to comment on the
Water Survey, Western Wilderness Area Lakes,
mental Assessment. The Sierra Club has set a
a high national priority, so we would of cour
NSWS successfully completed. On the other ha
created to protect and defend American wild 1
worked hard for the creation and preservation
system of designated wilderness. Because of
organization, our comments will deal specific
within the state of Oregon.
If of the Oregon
Nat ional Surface
Draft Environ-
cid rain control as
sc 1 ike to see the
nd, the Club was
ands, and has
of our splendid *
the nature of our
ally with activities
We are uncomfortable about responding to this EA, not only
because of our conflicting concerns about the problem, but
because we feel we have been backed into a corner by the
survey procedures. Here we are halfway through a major,
multi-year study and we are told that while there are four
theoretical ways to proceed, to choose any but the established
way would be to invite possible failure.
An EA should be a proposal of a variety of serious, practical,
possible alternatives, but despite the objective mentioned on
.page six, that "The EA should not be a justification of a specific
alternative", tills is precisely what we find. The description
of Alternative 1 continuously infers that this is the only way
to oet satisfactory results. The descriptions of the other
three alternatives repeatedly dwell on the reasons why they
would be unsatisfactory, always holding the veiled threat that
if the resulting data is imprecise, then (illogically) nothing
will be done about the acid prccipilation problem and the lakes
will ultimately be damaged.
#92
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' a 6 G
ll is unlort iiuat i- that the study could not have been designed
uiili moii? 1 DI-O a i ijlit, anticipating the western wilderness con-
Ilict .inJ dfbigning protocols, or even equipment, that could
make non-motorized access and on-site testing more practical.
Iv;, pit i' all of this we support the selection of Alternative
1 and are confident that acceptable data can be obtained without
subjocting wilderness to this serious level of motorized incursion
Thore is no doubt that the writers of the EA understand the value
of wilderness and the wilderness experience: some of the descrip-
tions of wilderness values (sec. 3.1.1) and uses (3.1.2) are among
the most sensitive and thoughtful that I have read. The explana-
tion of tin- subtle but profound effects of helicopter intrusions
on the spiritual backcountry experience, including the principal
that tin; most serious effect would be on the fewest, most isolated
persons, shows great depth of understanding. So because of this,
and because the sanctity of wilderness is important regardless
ol reci-ua t iona 1 use, we fuel that the EPA must follow the Forest
Survive direction that "wilderness values must be dominant, about
compr oni i so, and enduring." (p. 35) and do everything in its power
to conduct the study by moans other than helicopter access to
the wilderness lakes.
cific comments!
KA states on page 51 "...some people may see the action
setting precedent. If viewed as precedent. Alternative 1
ld be seen to lead to other exceptions that could, in
ir totality, seriously damage short- and/or.long-terra
derness character." This problem should not be minimized.
t as the EPA considers previous helicopter use as precedent
its proposed action, future proposals by agencies or
ividuals would certainly rely on the major precedent of
helicopter intrusions in a period of several weeks, if
s action were allowed. At a time when the Forest Service
attempting to tighten up its policies on helicopter use
wilderness (p. 50) Alternative 1 would serve to open the
odgates of applications for exceptions and make the Forest
vice's job of protecting the wildernss much more difficult
stated on pace 76, some measurements would actually be -
anced by changing the protocol to fit the horse sampling
cedures: "Extraction immediately. . .following collection
ld lie preferable to the existing NSWS protocol..."
gori wildernesses are small enough in size to make nearly
ry lake accessablc in the required time, including the
t that trail routes out of the wildernesses are almost
downhill. Our preliminary studies show none of the tar-
d lakes to bo more than 15 miles from a trailheald (most
in tin1 4-lU mile range) and less than 25Z include any
trail travel. This would place most in the "probable"
ge, as suggested by the chart on pages 81-84.
Wayne U. 'P.Ison
Page 3
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#93
#94
#95
#96
#97
4. It is implied on page 75 that if at least 40 of 50 lakes
in each strata were able to be sampled the results would be
statistically acceptable, and1 even less than that could still
be useful. This, and the fact that IB/, "extra" lakes arc
built into the sample (15 strata x 50 lakes = 750, sample
total 888) would make it appear that it would not invalidate
the study if a few lakes were found to be inaccessahlc with-
out aircraft.
5. The Oregon Chapter of the Sierra Club proposes to help the
EPA sampling team in any way possible (probably with hikers
and packers) to render accessable any lakos off of horse
trails, thus increasing the number of lakes tested and
improving the statistical sample.
To answer some of the objections to this plan listed on
page 8 "alternatives not analyzed";
A. The EA suggests that volunteers could not be reliably
used, but the possibility of training (the training
period is described as being only a month or so long)
or even hiring (thus ensuring responsibility) experi-
enced backpers and outdoors people is ignored. Or the
volunteers could be used as packers, accompanying El*A
technicians, under the direction of a paid coordinator.
Either way the volunteer role would be limited to only ,
a small percentage of lakes.
B. On the question of liability, the Sierra Club has .its
own liability insurance on official Club outings, -and
hiking and packing teams could be organized as part of
the continuing tradition of protecting the wilderness
through service, or work party, outings.
C. The question of whether or not the necessary equipment
could be carried on foot and over what type of terrain
is never adequately addressed in the EA. The actual
size and wieght of such items as the llydrolab or the
Van Dorn sampler is not given, only the general descrip-
tion of "bulky and heavy". So
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voliint .•• -i -a. Tin- UiL'Eon Chapter offers to participate in this
vul iniifi-r p i o i; r .1 in. Tin- tA states that Alternative 2 could take
anotiii-t yrui to imp 1 emeu t, which would ciye additional time to
iron oiii Juristical and coordination details.
lliauk you 1 u r tliu opportunity to comment.
LETTER #26
STAU <)l WAMIINC.ICIN
DEPARTMENT OF [COIOCY
AW ill)/) PV- 1 1 • (J/)/n/jJ,i
oi 'AS .iM • (-'' «.^ -I ••' l.nm
Sincerely,
/C
--fl- J /,.!
Joseph Hinton
Acting Wilderness Coordinator
Oregon Chapter, Sierra Club
3525 S. E. Hiluaukie Ave.
Portland,Or 97202
March 21, 1985
Mi1. Wayne D. Elson
EA Project Officer, M/S 443
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Dear Mr. Elson:
Thank you for the opportunity to comment on the environmental assessment
for the "National Surface Water Survey, Western Wilderness Area Lakes".
Generally, we are satisfied with the proposed analytical procedures,
however, we do have some concerns.
The issue of disruption in the wilderness areas as a result of helicopter
use may cloud over the real question of what is the present or potential
impact of acid rain in the Western United States. With public opinion
concerning the sensitivity of wilderness lake areas at a high level, all
possible methods of sampling should be carefully evaluated.
One alternative to the use of helicopters or horses would be a modified
version of Alternative 3. The lakes outside the wilderness areas could
be sampled by helicopter as originally planned, while the wilderness area
lakes could be accessed by foot. A crew of two to three people should be
able to sample two or three lakes per day within a close region. Each
lake would be sampled from a small inflatable raft which would be trans-
ported to the lake by one of the members. A location would be designated
for helicopter pick-up ut the end of each day. If the pick-up point is
on a ridgutop, the helicopter need only approach the areas for a matter
of seconds and samples could be dropped in a basket suspended from above.
With this method, the impact is minimal both from helicopters and a
human stand point. This method should also reduce the cost of sampling.
One aspect of using horses which was not considered is that numerous
lukes in the Cascades will bo dnngcrous to approach with horses. In
those caucs, all sampling equipment and bouts would have to be carried
down to the lake and back out again anyway.
#102
#103
#104
#105
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LETTER #27
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u'_,c he] icopterc
niorn?y.
ut it does indicate that sampling can be done for less I
//105
We urge you to consider the alternative outlined above. It would indeed
be unfor'urute if the positive nujnt-ntum of public awareness and interest
coiic'crnimj acid rain were to ur minimized by the necessity to justify
he 1 icupt IT u^e. IhcrL- may be- on opportunity to use the Washington
Conbcri.it ion Corps (WCC) which would definitely cost less. The WCC
program was created by the 198} teqiolature to employ young adults. The
pi .,1)1 .JIM it. iikinaijL'd by the Departinent of Lcology, and we are currently
cuiuluciinn projects in cooperat ion with other Federal, state, and local
II >uu have any question, please call Mr. David Roberts of our Air
I'riigran.si Office at (206) 459-6712, or Ms. Linda Bradford, Conservation
Corp;. Prurjram Manager at (206) 459-6131.
Sincerely,
#106
Greg Sorlie, Supervisor
Environmental Review and
Permit Management Section
cc: O.ivid Roberts
1 irida Bradford
WJ^J'H
WYOMINCi OUTDOOR. COUIVC1L
PO. Box 1184 1603 Capitol Cheyenne. WY 82003
BOARD OF DIRECTORS
March 21, 1985
PRESIDENT
John P*r(y Billow
Corj. Wyoming
VICE PRESIDENT
S*Uy Gmdon
!(*,<:•.. Wyomlno
SECRETARY
MounlalnVI.nl, Wa
L»nd«f. Wyoming
Mully Mow.
Cher*""*- Wyoming
Chflt PUnl
Rock Sprlnoi, Wyoming
L«n
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Mr. U. iviic El son
March .!], 19S5
would increase Lhc lime required Co complete the survey. The use of
helicopters would at least minimize the time required to revisit a lake.
ll" j vjliJ sample was nut collected from a lake and the lake was not revis-
ited, the statistical design of the survey would be jeopordized.
1>OC has recently learned that another proposal for accessing the lakes has
been submitted to El'A . We feel that in order for this or any other proposal
to be oflicially considered it should receive the same type of comparative
evaluat Ion as that conducted in the EA . Nevertheless, its our current opinion,
based on available informal ion, that our criticisms of alternatives 2 and 3
would apply to this Jatest proposal as well. It vould be difficult, if not
impossible, to ensure the logistical feasibility of ground access by back-
pack teams, more sampling personnel would be involved than in the helicopter
option, and the numbers of people in wilderness areas and hence the potential
for disturbance to recreational wilderness users would be increased.
WOC tinds alternative 4 totally unacceptable. Of greatest concern in the West
is the potential for acid deposition impacts in Class I areas. The Bridger
and Kitzpatrick Wilderness Areas in Wyoming's Wind River Mountains are prime
examples of susceptible Class I areas. The results of the survey must be
applicable to such areas; therefore, wilderness lakes must not be excluded
from the survey.
For all the reasons stated above, WOC supports alternative I. We are not unmind-
ful of the potential short ..erra impacts of helicopter use, however, and urge
EPA to employ all possible measures to mitigate such effects. We refer you to
our letter of January 10, 1985, to Mr. Ron Lee. We also wish to reiterate at
this time our request that EPA hold meetings in as many locations as possible
to aftord the public an opportunity to comment on the conduct of the survey in
specific areas.
One final note about helicopter usage. It should be made eminently clear to
the public that authorization of the use of helicopters for this survey, sets
no precedent, i.e., that it constitutes no implied approval for similar requests
in the future. Although authorization is the responsibility of the federal land
managers, EPA t.m help ensure the correct public perception by appropriately
designed informational compaigns. Finally, WOC urges EPA to scrupulously
review the proposed sampling protocol particularly for the criticol D1C and
ixtractab'. aluminum lests, to ensure that they will hold up under scientific
scrutiny. For example, if extracting aluminum in the field Is feasible and
would imriasf the aciuracy of the subsequent analysis, such procedure should
be adopted. Tin. additional equipment required for the extraction should be
carried in Hie I.el (ci^ter. It is essential that the data collected in this
survey be |;i ncr,< I Jy accepted by land managers, regulatory agencies, scientists,
industry, and public interest groups. It must not be disputable on the basis
oi sa/fipliii;; or analytical protocol.
In suruuary, WOC believes that the urgent need for data on the acid deposition
sensitivities ol high mountain western lakes mandates the use of helicopters
for accessing wilderness lakes, and further that the potential long t«erm ben-
efits of acquiring these data override the short term impacts of helicopter
operation in wilderneBtf ureas. It La our opinion that chu Wilderness Ace
#107
#108
#109
Mr. Wayne Elson
March 21, 1985
Page 3
authorizes such use. We do not believe that an individual wilderness area
must be threatened by acid deposition before helicopter access to that area
could be authorized. Acid deposition impacts to any wilderness area damage
the system as a whole. Furthermore, the date comparability considerations
of this study dictate that all lakes be accessed and sampled in the same
fashion. Future management decisions which may be necessary to prevent and/
or mitigate acid deposition effects, and thus preserve wilderness character,
will depend on the availability of Information obtainable only from a survey of
this type combined with more intensive followup studies.
We commend EPA and ORNL personnel for their part in preparation of this
thoughtful and thorough environmental assessment, and thank you for the oppor-
tunity to comment. If you have any questions, don't hesitate to contact us.
Please keep us informed of all future action in this matter.
Sincerely t
Debra Beck
Executive Director
DB:mw
cc: Mr. Robert M. Read
Mr. Max Peterson
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LETTER #30
5515 M3rd Ave. ME
Seattle, WA 98105
March 21, 1985
LETTER #29
Wayne D. Elson
EA Project Officer, M/S UM3
U.S. Environnental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
Dear Mr. Elson:
I'm sending comments in response to the sampling methods proposed
in the -draft Environmental Assessment of the Western Wilderness Area
Lakes Surface Water Survey. I wholeheartedly support the survey and
its coals, but do not believe violation of the Wilderness Act is
nec<=sajry to procure water samples. Alternatives to helicopter
have not been sufficiently considered.
Even "iven water volume and time constraints, on-foot delivery
of samples is feasible. Here are several possibilities:
1) Relays of hikers. This could be organized by the Mountaineers,
Sierra Club, or wilderness volunteers, such as VOW.
2) Use of fast individual hikers. I know several backcountry
rangers and friends who regularly make rapid hikes or daytrips with
light to moderate loads, at speeds of "* to 5 miles per hour. Mountain
Rescue teams could recommend individuals.
3) Use of ultramarathoners and mountain runners.. I have seen
runners on mountain trails who pass me both going and coming in an
afternoon. A running organization could supply you with names of
individuals.
Basing hiking times on guidebook estimates is inaccurate, as
these times are meant for average recreational hikers with full packs,
not organized, mission-oriented teams.
Thank you for your consideration. Helicopter sampling in wilderness
aroas could set a precedent for other motorized infringements on places
that were set aside to be free from them.
Sincerely,
#113
#115
Robert V. Walker
TL
Mountain &lu.lt
TELEPHONE
922 8315
OHCi HOUII^ MONOAV THftU FHIOAV
2530 WE SI ALAMLOA
DENVER COLORADO 60219
Wayne D. EL son
EA Project Officer. M/S 1&J
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, UA 98101
Dear llr. Elson,
llarch 21. 1905
Following arc connents from the Colorado fountain Club on the draft
Environnental Assessment for the National Jurface ;lator Survey Western
Wilderness Area Lakes.
l) CUC connents on the scoping document requested that EPA more thoroughly
explain the sampling methodology necessary to coaplete the survey arc! the
alternative logistical means of obtaining samples. :ie feel that EPA responded
to this request. It is clear that in order to obtain unifom results and results
which can stand up in court, helicopter access is the only satisfactory noans.
The CMC supports this alternative. Ue believe EPA could s'.rcr.sthcn its cacs
by explaining in more detail the safety aid logistical problems associated
with using horses.
2) Our major comments on the EA are represented by the enclosed letter fro.i
the Club to Max Peterson of the Forest Service ursine Chief Peterson to crant
the helicopter access.
3) Ihe final point HO wish to raake is that this EA has involved the user croups.
Ha appreciate the fact that EPA has cone to croat lengths to obtain public
comment. This EA and the process followed by EPA should sot a precedent for
dealing with requests for motorized access into wilderness.
Sincerely,
Enc.
Anne Vlckory
Conservation Director
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Mountain &lul>
;s Kins • LI I'uniLO
I STERN SlOI'F
TCIEI'HONE
U22 B315
2530 WEST ALAMEOA
DENVER. COLORADO 60219
Ilax Peterson, Chief
U.S.U.A. Forost Service
I'.O.Lox 241'/
Washington, 1).C. 20013
Dear Ilr. Peterson,
March l>t, 1985
I am writing as Conservation Clialr and President-Elect of the Colorado
Mountain Club to urgently request that you grant the Environmental Protection
Agency hcllcoiiter access to the wilderness areas In order to carry out the
western area l.V-.cs portion of tlio i.ational Surface Water Survey.
Vhu Colorado Mountain Club Is a Colorado recreation and conservation
organization of over 8,000 Members. '.Ve have II* groups in 12 cities and
towns across the state. Our members uso the National l/ilderness areas
extensively for hiking, backpacking, climbing and skiing. The Colorado
1'iountain Club has been a major force in the designation of Colorado Wilderness
arc'as In 1964 ard 1930. We have participated with the Forest Service In
many monl.lngo, field trips and activities designed to improve wilderness
management. :,'c- also participated extensively in the development of ihe
Colorado i'iD regulation during i.'hich proceedings no strongly supported the
role of the Forest Service as a Federal Land Manager with an affirmative
responsibility to protect Air Quality Related Values.
'./e understand the concerns of the Forest Service that granting EPA
helicopter accccs could set a precedent for general helicopter access into
wilderness. The- Colorado Mountain Club would strongly oppose any such
concept of a general, casual motorized access into the 1,'ational Wilderness
Syslc.-i. Uuucvcr, the EPA request is for a one-time entry and is for an
activity which will provide a lake-water baseline which in the future will
be essential to protecting the wilderness characteristics. We have been
assured by Ed Coat, EPA Field tianager for the Purvey, that Phase II and
Phase III of the survey will not involve helicopter access to the wilderness
but can V.e completed by backpacking or horsepacking into the lakes, camping
for a period of time and doing the necessary lab analysis on site.
As you may &-now, Colorado currently lias 24 areas in national Forests
in the ilational Wilderness System. These aro'i:; attract visitors from across
the U.lj, anil from foreign countries anil Lin;:* "ro a considerable tourist
attraction for the state. The Colorado tourism industry, nuch of which
is based on the recreational opportuni tic-s In rational forests and national
I'nrl'.s bringr-, in ever 4 billion dollars annually. One billion dollars of
this is attributed to hunting and fishing. :;one of the fishing takes place
in the high altitude wilderness lakes in drainages that are known tn be
poorly buffered and therefore sensitive to acid deposition. The acidification
of soi.ie of the wilderness lakes in the state could quickly affect the rep-
utation of the state as a prime fishing area. The El'A baseline survey is
one vital tool in the KD permitting process which requires adequate controls,
modeling and monitoring to prevent such an occurrence.'
Max 1'eterson ..
March I'l, 1905
Pago Tuo
The state of Colorado is currently awaiting approval fron El'A to take
over the P.JD program. The Colorado 1MB regulation was developed after an
extended hearing involving Industry, envlromc,ntnl, state and federal
interests. One issue was the validity of data used to determine impacts
to Air Quality Delated Values. A key Ingredient of the El'A proposal is
that the data be gathered in such a nar.ncr as to stand up in court.
During the past few years akalinlty data has been gathered from the Flattops
and lit. £irl;el i/ilderncGS Areas by backpacking and horoepicking. The
Colorado Division of Wildlife which is concerned about impacts to trout
and other aquatic life has questioned whether this data will stand up in
court because of the time delay in processing the samples. The CMC wants
the data gahtered by the EPA to be free of any such questions, ite believe
that the EPA proposal to gather the data by helicopter solves this problem.
Members of the CMC who have had extensive experience with horsepacking
support the EPA's conclusion that it is, logistically, a difficult under-
taking to sample the 424 wilderness lakes by horse within the tine fraiie
necessitated by the study. !fc feel that the elements of risk and delay are
considerably increased by using horses.
You should be aware that Colorado is not free from acid deposition
impacts. Researchers at the Rocky Mountain Biological Laboratory (the
Mexican Cut lakes above Gothic, Co. in the Cunnison national Forest) are
reporting that they observed the short-tern acidification in their study
lakes during smu-melt last summer. The pH in one lake dropped to 4.9.
This occurred at the time the salamander eggs ::ere hatching. According to
John Hartc, the principal researcher, this may explain why the salamanders
have failed to successfully reproduce for the last 2 years.
In conclusion, I feel that the practical, on-the-ground experience
of the Colorado Mountain Club as a user of the wilderness and our work with
wilderness managenent, wilderness designation and qir quality Issues
gives our organization an excellent insight into the activities and the means
of carrying out these activities which are necessary to preserve and protect
our wilderness areas in their "natural condition...unimpaired for future
use and enjoyment as wilderness".
Uo again urge that you grant EPA helicopter access for the survey.
Me believe with the proposed El'A technique the Foreut Service, the EPA,
the states and the user public will have a baseline which will stand up
in court, and, which can help the Forest Service to carry out its respon-
sibility to protect wilderness characteristics and Air Quality Related
Values.
Sincerely,
Governor Diehard Loiam
Jim Torrance
Al Ossinger,
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LETTER #
1530
:'-r. L. Eiwln Coate
Depjty Uccional AJnlnistrator
U. S. Env1ronc«ntal Protection Agency
1200 Sixth Avenue
Seattle. UA S6101
3ear i-ir. Coate:
t.'c i-jpreciatc EPA's effort In developing the Karen 1 Draft Environmental
Jsses»i.:enl (EA) concerning the national Surface Water Survey - Western
'.Mlileriiess Area Lakes. Attached Is our response to this Draft EA. Our staffs
net on Lurch 2U :r.d 23 to discuss these consents, to improve the adequacy of
this craft, ar.ii to review fie public corxients.
Sincerely,
' OAVIJ G. UliCLS
Director of .iatcrshea anii Air K
Enclosure
cc: /Ujb ic.."!, Cak K1i!.;e :iatl Lab
Wayne clson, CPA, Seattle
Roy Fcuditer, fin
Joiephlne Huancj, CPA
Rick Llntiiurst, TPA, liC
Dive K.etchar.:, EC
Comments on Draft Environmental Assessment
NSWS - Western Wilderness Area Lakes
Page 11i - First paragraph - As currently written the Summary and Conclusion
is a biased justification to use helicopters without regard to the Intent of #117
the Wilderness Act. The need for this EA In light of the Wilderness 'Act
prohibition of mechanized equipment including helicopters must be clearly
stated. Therefore, add the following as the second paragraph of the Summary
and Conclusions and the Introduction.
"The Wilderness Act of 1964 severely limits the use of mechanized equipment in
wilderness The following exceptions are the only provisions in the Wilderness
Act under which helicopters could be authorized.
1. If necessary to meet the minimum requirements for administration of
the area for purposes of wilderness, [Section 4(c)].
2. The gathering of information about resources if such activity 1s #118
carried out in a manner compatible with the preservation of the wilderness
environment, [Section 4(d)(2)].
3. As specifically provided for concerning the establishment of water
facilities when approved by the President, [Section 4(d)(4)(l)].
This assessment documents the Impact of different methods of access for
sampling on wilderness and on the objectives of the national lake survey." '
Page iii - "Sampling protocols established . . . ." The Western Lake Survey
is a distinct subset of the NSWS. The sampling protocols can be changed. #119
However, the effect this change would have on NWSW objectives needs to be
quantified.
Page 111 - Mid-page "(2) The date collected . . ." The need for this level of
precision (i.e. 0.01 of mg 1 -1 figure 2.1-4 page 18) for a national
assessment should be more fully explained. The quality assurrance and quality #120
control protocols are more precise than usual for a national assessment. The
selected protocols seem more suitable for nutrient cycling and energy flow
experiments within small watersheds.
Page 1v - The time frame criteria of 7 hours should not be the only criteria.
Some guiding philosophy concerning protecting the local wilderness values
overriding the need for economy and convience should be added. This #121
alternative could also have different sampling protocols to remove most of the
time constraints.
Page 1v - Alternative 4 (no action) needs to be a realistic way of attaining
the NSWS goal. This alternative should show the effect of not sampling £12?
wilderness lakes but still achieving the same NSWS goal by adjusting or
expanding the sampling design. As currently described Alternative 4 is not a
viable alternative for achieving the NSWS objectives.
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Page v - Next to last paragraph - Helicopters are not "1n keeping with the
spirit and letter of the Wilderness Act" when other means of access are
available and meet the need. This statement should be deleted.
Page v - Last paragraph - Disagree. This is purely an assumption and a
presumption.
Page xiil - Alternative 4, If It were a viable alternative, would show why It
Is necessary to sample lakes in western wilderness areas when there are so
many similar lakes available outside wilderness.
Page 2 - The Alternatives need to be compared against NSWS objectives stated
in the last paragraph on this page.
Page 5 - Last paragraph - All Wildernesses and National Parks are not class I
Federal Areas.
Page 6 - First paragraph - The information gathered In the survey may be
useful to a limited extent in managing wilderness areas although it probably
will not be specific enough for management decisions on Individual
wildernesses. For us to justify helicopter use for wilderness management
reasons, it must be shown that we cannot obtain the information we need by
means compatible with wilderness.
The law prohibits helicopter use except as necessary to meet minimum
requirements for administering the area for wilderness purposes. What data
does EPA plan to collect that the wilderness manager must have that requires
the use of helicopters?
Page 8 - A discussion concerning changing the sampling design, parameters to
be measured, protocols and other sampling methods considered to meet the
intent of the Wilderness Act, and the basis for their rejection should be
added here. The impact of choosing protocols without time constraints on
attaining the objective of the NSWS Is not fully discussed.
No change In sample design was considered. No change In lakes selected for
sampling was considered. The Idea of choosing lakes close to the wilderness
boundaries so that ground crews can bring samples to helicopters outside
wilderness for rapid transport of samples is not addressed. Also not
dlscussedis the option of choosing chemical sampling only needed for the basic
mission of Identifying acid lakes In wilderness and obtaining the more
detailed chemical information outside wilderness. Sampling the most critical
"short holding time" variable outside of wilderness to accommodate wilderness
values 1s not discussed. The only accommodation the NSWS has made to consider
the Intent of the Wlldernesss Act has been method of accesss. The Impact of
changing access on the objectives of the NSWS 1s not quantified (Table S-2
does not Include the objectives of the NSWS described on page 2). The reason
for this seeming lack of concern for wilderness must be explained 1n
relationhlp with the objectives of the survey by any sampling design.
Page 9 - The evaluation criteria used In selecting the current sampling
protocols plus peer review of the selected sampling design and protocols
should be discussed. The peer group review process and response to the draft
NSWS study plan should be referenced or Included 1n the appendix.
#123'
#125 •'
#126 '•
#127'
#128',
#130J
Page 13 - The percent of lakes Inside and outside wilderness and the percent
of sampling planned for each category by subregions and alkalinity class
should be added to Table 2.1-1 to display the randomization and objectivity of
the lake selection process. The document does not dispell the latent belief
that lake selection was aimed at wilderness areas to reduce other unmentloned
Influences or variables.
Page 16 - The Importance of the measurement of monocnerlc aluminum In
relationship to objectives of NSWS described on page 2 1s not addressed. It
appears that the main argument for using helicopters is the need to preserve
samples for measuring monomerlc aluminum within 12 hours after samples are
collected. We hear conflicting reports from the scientific community on
this. Alternative field protocols are used by numerous researchers.
Monomerlc aluminum Is time, temperature, DIG, and pH dependent. Western lakes
seldom have less than 6 pH. The sample season will be cold enough to inhibit
chemical reaction. The final EA must display strong evidence that data on
monomeric aluminum is needed, that the time constraints are real and there are
not realistic alternatives other than motorized access.
Questions concerning the lack of scientific consensus on the chosen protocols,
the belief by some that the preferred protocol may be too precise for a
national background survey, the suggestion that the preferred protocol for
monomerlc aluminum can be revised to eliminate the need for helicopters and
the effect of lakeshore protocols for monomerlc aluminum on the objectives qf
the NSWS need to addressed and quantified in the final EA.
Page 27 - The process and criteria for selecting which lakes would be accessed
by helicopters should be established. Appropriate criteria are discussed
throughout the document for wildlife sensitivity, hunting seasons, visitor-use
patterns, safety considerations, and others, but these need to be specified as
part of the alternative In the final EA so both EPA and the wilderness manger
have guidance. A guiding thought to include would be for the local situation
concerning protecting wilderness values will take presidence over statistical
considerations of the survey including economics and conviences.
Page .37 - Add a paragraph (3.1.4) to highlight the steps considered and those
Included In the NSWS sampling design to preserve the wilderness environment
and to protect the wilderness values of natural conditions and outstanding
opportunities for solitude.
Page 47 - First paragraph - Problems with weather, icing, sudden storms,
etc., that would hinder different types of access and Impact human safety
should be included here.
Page 49 - The EA recognizes the need to tailor the sampling activities to each
site. However, guidelines and criteria concerning when and how this tailoring
will occur with the local land manager, need to be detailed in this
programmatic level analysis. The effects of the alternatives cannot be fully
displayed until something is known about these site-specific procedures.
#13i
-------
Page 68-69 - This clearly states that sampling will not be sufficient to
understand (characterize) an Individual lake. This means the data Is not
satisfactory for wilderness management of specific lakes and yet the EA
alludes to meeting the need of the wilderness management. The concept of
protecting the wilderness system must be based on protecting each wilderness
area. Wilderness Act prohibits use of aircraft Including helicopters 1f such
use Is beyond the minimum needed for management Including emergencies.
Page 69 - The proposed sampling design was selected to give a statistical
picture of the nation's lakes and not wilderness lakes by subreglon and
alkalinity class. The expected error In data for wilderness lakes by
subreglon and alkalinity class should be Included to support the concept of
providing data needed for wilderness management. The need to gather this data
by helicopter Is still In question.
Page 74 - The EA falls to establish the need to collect data using helicopters
except for convenience and economy. The problem of QA/QC of the resulting
statistics for regulatory purposes should be quantified. This may be the real
reason for the need for helicopters. The problem with historical data In
confrontation with different polluters and the need for this precise data for
writing new legislation needs to be clearly described.
The public Involvement process used during the development of the EA should be
described. [Please note: EPA's purposeful failure to highlight the conflict
with the Wilderness Act in the Draft EA's Summary and Conclusion, may have
Invalidated the public Involvement effort since the real reason for this EA
was masked by the furor over acid rain.]
ER 85/321
DRAFT
#138
0139
Wayne D. Elson
EA Project Officer, M/S 443
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, Washington 98101
Dear Mr. Elson:
The Department of the Interior has reviewed the draft environmental assessment for the
National Surface Water Survey - Western Wilderness Area Lakes and has the following
comments.
There appears to be some inconsistency in the summary data provided in table S-l. For
example, table S-l now indicates that Alternative 4 (no sampling) would have only
"minor" negative Impacts on long-term wilderness protection but arguments presented on
page 87 suggest that falling to collect samples in wilderness areas could lead to severe,
long-term Indirect impacts. Perhaps table S-l should reflect only positive versus
negative Impacts without making reference to the magnitude of those Impacts.
The final assessment should note that entry Into wilderness areas on Indian Reservations"] ^
is controlled by the tribe (25 CFR 265). Any entry, therefore onto tribal land for the! RM(l
purposes of this itudy must be approved by the tribe.
We support the proposed sampling effort since we believe it is important to understand
the acid deposition problem In wilderness areas. However, we have concerns about Die
use of helicopters to carry out this effort in specific areas of the National Park System
Included In this study. Large portions of the parks noted In Appendix 3 are now "proposed
wilderness" and should be so Identified In the assessment. These areas that are proposed
are managed as wilderness until a final decision Is reached. The final assessment should
recognize these limitations.
We also want to emphasize the Importance of closely coordinating sampling efforts In
unlta of the National Park System with Park Superintendents and the need to obtain
-------
clearance from them prior to sampling any lake within a park area. We also request that
all sampling activities take into consideration sensitive areas and the timing of sampling
to minimize impacts to visitors and natural resources. Careful consideration should also
be given to other water quality studies and investigations related to the proposed
sampling effort in order to avoid duplication. Contacts for regional offices are included
in the attachment to this letter. '
In addition, on a technical 'basis, the National Park Service (NPS) reviewed and
commented on February 11, 1985, on the preliminary draft of the assessment. We note
that the concerns raised in that letter were not addressed in the draft assessment.
Therefore the final assessment should consider the comments sent to you previously
(copy attached).
Specific Comments
Olympic National Park
At Olympic National Park, the alternative preferred by EPA (Alternative 1) is the least
acceptable to the NPS. The analysis of wilderness impact in the assessment centering
primarily on horses versus helicopters, does not correspond to the analysis of the
situation at this particular park by the NPS. More specifically, NPS believes that in
some instances, the impact of using horses to carry out the sampling effort at Olympic
National Park can be less than the use of helicopters. This issue should be resolved. —
Another alternative which was not considered in the assessment is foot access only.
While this may not represent a practical alternative in other wilderness areas, we believe
that at Olympic National Park, three of the four lakes proposed to be sampled are easily
accessible on foot within the time constraints described in the assessment. •*
r/1
Lake 4B3-032 is not located in Olympic National Park: it is located in the Buckhorn
Wilderness of Olympic National Forest.
Mount Ranier National Park
Both lakes proposed to be sampled by EPA in Mount Ranier National Park are known to
have goat populations nearby. Therefore helicopter crews sampling these lakes should
contact the Park Superintendent before entering the park so that park staff may instruct
the pilot regarding preferred routes and approaches to these lakes. We believe that this
consultation will permit the proposed sampling activity to be accomplished with
minimum disruption to nearby goat herds. '
We hope these comments will be helpful to you.
Sincerely,
Bruce Blanchard, Director
Environmental Project Review
Enclosure
cc: Robert M. Reed, Oak Ridge National Laboratory
Olympic National Park would be willing to furnish the necessary logistical support with
backpacking "Sherpas" (or with park-owned horses and mules if necessary) to sample the
three accessible lakes (Boulder Lake, Hoh Lake, and Lunch Lake). However, the fourth
lake (Lake 4U3-05G), an unnamed lake in the Rustler drainage, is in an inaccessible,
remote, and totally undeveloped area where foot access is difficult, horse access
impossible, and helicopter access inappropriate. We prefer that this lake be deleted from
the survey (us long as such deletion docs not invalidate the entire sampling process). /
150
-------
ATTACHMENT I
»ebru«ry 11, 1»»5
L34 (479)
KR-bi/132
DRAFT
Hr. Wayne Llaon
£1S and inctfcy KevlaW Section, H/S 443
U.S. iPA, ItigluD 10
liOU Sixth Avenue
Seattle, VA yaiui
Dear Mr. k-lton:
The National Patk Sorvic* (kPS) naa retivwud the environmental Pcoucnoo
At=ncy'i l£PA'a) prtllBinacy Bcsit CnvlruoncDtji A«fiu»*n«nt mr Froi'baud
Sanpilnz al VtHttn UliiUriiuaa Arc* Lakea Uelnj Hellcoptcra during Vhaa* 1 of
the National Surface Water Survuy. W« oif.r to« cousmits ludlcetod Lulow anu
In the cocloaurut to thla letter un a ucoDlcal •niatance baili.
MPS euppoctt the propoeed eeapllns tfturt (locc we bulleve It la Important to
uoc'enunil tbe aulu tl«potltlon problca In wllderoeta ereee. Hov«v«r, we Uivo
concern! about tho uae ol htllcoptera to carry out thta effort lu apecific
areaa of tut National Park Syatvi Included In title itudy. We have luentltled
Uxte apeclflc concero* lu tncloaurei to thle latter,
1 would like to ••phailKe the Inportance of cloxly coordinating aaHiillng
cttortf In unlta of tne National Park Syate* with our Park SuperlnteBd«ut> and
tn« need to obtain clearance iron Uttm prior to »a*illnfc
ftlatt la order to evolJ duplication.
If you have quattloiti related to tlieae to»Buot«, I augi«et tuat you eootnct t»o
(ollowlOi; InJlvlduala In our Regional Otiicoe (or li you iiave K«ct to a particular park unit, PAVIC contact the iiui>drluteuat>nt of that
unit).
Pacific Horuw.at te&loa: Rou Hyre If'iS J99-53D6 (Seattle)
Wuitern Region: Jin Uuildjeatitn >'TS 5J6-o3U (Sea Vreaclaco)
Rocky Hountaln ktglon, keB Hatparek PTS 776-b72u (Denver)
Thank you for tiilf Opportunity to provide technical aieUuace.
Sincerely.
ho-^s '«. Ucka
Tboaet U. Luck*, CAlef
Water Reeeurcei Clvlelon
JLncloautea
cc. Rebtrt H. Reed, Envlron&eutal ScieuCKt bivlalon. Oak kldge National
Laboratory
bee; CLAC - Sopt. rose - supt.
CRTK - Supt. PKR - Hyra/|tord«roB
LAVO - Supt. KHR - Kaip«rek/HarMnca
HORA - Snpt. UR - Budaleatun/Cherry
OLXH - Supt. 47« - Klaball, DfcH
1LOHO - Supt. 47} - CUrlitlane. 0£N
SEKI - Supt. 4*9 - iUrnaaa/taroo, CtC
TUJ, - Supt. 762 - VentreeCe,
-------
LNCLUSUKt i
NAliOhAL PAJtK
firka
E.KAFX eNVIkwNHiaaAL ASSt£SMU.T
p»yposi.c SAMPLI.W uy k.siLkn v,iu>i.M,tss LAKUS tsixu
1. MUOML SUkfAU WAVU iUkVfct.
Coa
ntt
»l^fc.'
O*1'1"'.,*,
I/O'1 I
1. P»i;« 5, lint tmtjuce. Ihu PDIA itattt "Concorni viiocUted with
Katlobnl Park* are **uuc«(J ta ue tlMliur to tho**.* lor K lldetui-^M ar^** and a
• cp.r.u «a*ly*li ;t uol prt t'Btda." Arp|iiy to tbcic «ru»i ot thu hatiooti
• 2. So».. 1,4 ttie l«kci d*»l4n*t«0 (or i»»jillug to Pitt.t urc Vn «r«»o at liian
vliltor ui«. HUlgatton »b»«urok ihoula lacluJ< »d« ot bciv/ vliltot u»4. Cenccaily, thin would b« «ltvt ttiu (Lcit
wu«l>. ID ScnuCo tu
buckcouatty tiact (toui> (or at leatc Bauc available to tl)«C>. C.PA at
tnia Iniocaation to «ti> tar di»trliiittloe,
'1.
^lui ok ml datA OD tn^lviduol iakti. incluUiafi ajrlal photna, iliould Ic
ad lo toe t<§p«ctlv, ncK« tor tlulr itlti. A comyl.ta B.I at da la
t.tuitlug tti« thu »»»plluj «ttert inovld kin lorwaioul to tbo HVS W«t«r
H«§ojrcu» DivUiou in fort Coliln*. cel»raao.
' o. cloau coordloatton »f.oui«i l« Biintulnol with our Park Suj>c-rlBt*i\danti in
clrr>>ue out tl.i» «t'tort. «>; Ooimv. tbii cooraiuatloo wouid ul»u ftu iml(itii>.
to CPA fQd Its cuntcacLort ainc«- »uny t.ltii nuuntain l*kc-a »ru dtlsleult to
lucati. »oa pan. etatt cuu^U 01- licly.ul in locacUg «t>cctil.c l»K«a.
IW
Hatloul Pat i
-&tf^ I I, In Olyaplc National Park. the. elk rutting *ca*ea In ald-S^c_cb«r ahuuld
,^L / b« avoldtd. All of tha l*Kt!( mitctud lu Oljaplc uatiou4l P.rk are in elk
-ru)^ I habitat aad In area* utud during tbo rut.
J n,\ r
^y^V I 2. Thu Boh Klvez Vallvy In OlyBplc lUtlouai Park la prograaaod ior lounklva
.^L. / aaBpllng tor long-ter* ucotytt'i dtt'uct* iron air and watar pollutant*.
£<""• C.TbttEior*, any bulicepter ut* In the vallay It uadaclraUl*.
wl'i
oJI" "*
'"vy
& L
ll,x-(" 3. BCCAUI* ot the *cn*ttlvt nature ot tbu ^coayiten o£ Olynplc Uatioul pirk,
U*A chould work very cloicly wtUi the Park »u>£f to dturuln* co&dltluna uoJ«r
which l*k*l ID the Purl can be aaapiad b> helicopter,
•*ft^
North Ulead** National Park.
»"
/««»*
r .—
lfL-*hT »• It ll (Ulpcctod that (liable Laku (/4K20iU) In Nortn Catodea N»Uoo»l
wat Included by »t*tak« tine* It 1* a low-klcv*uon hydroelectric rorrvolr.
tpacltlc COBB«ttt« - Ua*Uro >U|len Parfc*
YoiaBlU Mauonal lack.
It 1* r«coBBcnd«d U,*t **Bplin( ta«t! placv at tec tbe Middle ot
to avoid UM uirlod of high vliltor uu la tt>e wilderoa**.
2, It 1* alto tecoBBcndaJ thai two ot tlit unnaaed lakna la foiic'ita i
Park bu dropped trom the «uty»v. U>k* It »hown on topographic a^pt a*
a watar body, liowcvar. ther< 1* lu tact no lakk lu llita area. Park ttati oaa
conilraed thl* through on-iltt aud aerial plioto ln*pcctloa. t*k* 4Ai-OJu i* a
• ballon ••atonol pond Uktt drl«* up lu latt auuicr anJ probably will not oxlat
In tba fall it MBpllng ukt* place at that tlB*.
S»mioU-ting* CBBJOB National Park* ,
I, It 1* not evldeut that thJr* hat Lucn *Q> invuttl^atiou Into work alxaauy
being done on tho etUct* ot acid ac.ieaitlon in Uiube pack*. Inn Park*' atau
*cl»nti»t* iiavc buon wotklnj lor two y«ar* ou baiejtnu data coii^ctiot., In
cooperation with the Ualltorut^ Atr Rdtourcut Bo^rd, .raa unt.cr*! tin i, *i\c
other federal agtncl**. Ic «bdltlon. Southern California ulitou na« cpwrtkOtvd
a water chealttry Inventory 01 ovri »nt nundcfcd Sicrr*u xn>..* tor tua jttt
•tvaral yoara, «nd tin £tat< 01 Canioruiu 1* atuut to undcrUko an aduitlouai
*urv«y of l«ku chaKlatry. It day be pomibiu tuat »OBC aaU «xitt or could bo
gathtrud In connoctlon with thaie on-going »tuui<:> that could «atl*i.y tut ucua*
of portion* ot £PA'» propoiril »»iplin£ jttofl aud tnu* polbiuiy ruduc» or uvuc
th« naed to i»Bp.c i«kea lo UMae park*.
-------
Kocky Houataln National Park
^Mountain National Park.
\, I"*- It la Difficult to detcrBlni, froas Ap[*bJl* A which laka* in
' '/ be aaaipled. Appendix A ahould Iw revlaed to clarity tin*.
^« *~-
*ft-
tlm Par*
*".,•, f3. It la repeated that clo*e coordination be •alnleinad with Park atal'l
ft^'f-H/ (particularly radio contact wltli th* ?.rn Ulipalvhcr during **B[llnt}.
««""• V
t'lT'''"/*' *s " •i*° requeatei that i-rior to «*n;iilti», iPA contact tuu Park tut
** £*iC.^lnput aa to flight patba and height*.
ilk out ot backcountry ar£a* if helicopter problvBt are el
''''' f 6. ,
**- / lo wa
Ccand Tctoo Natlaual farfc
i '«f' <-
i"' fl I 1. Park ataff have Identified potential landing iltui around Cirque Lake 1
-£n / Maran Canyon. Airlal photo* are available iron the iupctiot^aJont to *»l*t 1
/ locating the landing alta*.
^~
,«
V
it'*1 r2< Ve
" / uiler*
h»<- L
Sallow*tone national Park
1. Ine putA indicate* that \i la*«* to T«tjow*tou«i National Park will lit
aanpliid by helicopter to obtain data en ncid deposition ic wildumuc* laKxa.
Beceu*. Yellowitoue hatioual Par» Le* a ;ii}b luvul 01 lotereat ib aulJ
uapoeltlon and othur lBp*cte on olidurnua* l.u
collected and are available tor uit by tPA tin n«ny of th& yiv^uKii lUBpllbg
lak 11.
|
2. Thr llat o( lakca to o« taa^ito In Snuol.-kir.gt oma>on Uatlonal Parka
Include* 15 lakua thatar* out ld«utltl>d by naou. Ihe Parka* »tmi bauua to
know itic naa^e am! location* of theie uik.j la ototr tv vvaluKti tli« lining ot
potential etlectt of helicopter lil^r.ti uii i.«ck dock or backpackera.
3. buu to the Intettklvc *tU3ica underway at iia^rala Lat» lo Suquula National
Park, aalpllng at thla alta cannot tn approvad.
^ Uaana Volcanic National Park
fl. The PDLA dona uot (pucltlcal^y addr«i* whtither lakpliag activities will
bu carried out on weekdaya er waek&nd*. Park atari prefur* thai »aBpllnk nt
dona on wwakdaya whan there 1* It** u*e Ib the bacVcouotrj.
Spectfle CojaunU - fcock/ Mountain laglon Parka
Glacier Hatlonal Park
I 1, BescJ upon an aaaltele by Claelar liatlouaj Park'e loaearch ana Raewurce
I Hanaa«B»ut Division*, • *y*t«B*tic approact to ectaullth b«cr.Jln« data in
/ Glacier'* ^rlttlr.t lake* baa been o«vtiopcd. Ttlo proCi:** lanplu* 1J) lake*.
• / twice a year, with aaaple testlnu done by tliu Unlvvielty oi Mont.ua1* tallow
I Bay La Dora lory, a leading t«*t rauliity for water laapln* and i* tPA lertlilm.
I Our analyse* Indicated that In order to eitabllii, any H««nlnb£ul b«*«linJ data,
I a tlaj eerlcc approach over a long lere would oe necc*aary. Al*o. bujied an
I information pruaented In tb* PBCA, our chrBlcal analyela of water s»»iUe» i*
| Bucb Bore coBpr«h*n*lve.
2. U<-llcopt«r u»« in Glacier National Park lue been under cloio acruiiny u,e
la*t feu year*, retultlng In a i.OOu toot above ground l»v»i (ACi.) alnlnua
llBltitlon mint piacod en elrcralt flying ov«r lite Park. Nuat lake*
iduntlfled can be reached by grouni kccw-o (>-*prci*ii> wn.n one consider* tu>.
3-b m>ck eaatpllng window). Any proyoial 10 lucre**"- nciicu,i i.ub.vct In Gncl>-t National rare. Many
•dvur*t. litter* Ua/* bean rtcnv^a conc^ruir^ r.clicn^n *ui.eiil»-« to iutixiloa
(j,j wri.rv hloli ruer*atii>nai u*c la iiuticipaiil (-t t.u tint- 01 kaa^ilnj,)
Unrr>4on Lvivea all ha»
-------
tNCLOSUKi II
NATIONAL PAkK. CGHhiNW
PHOPUSLD SAHPLlNC LOCATIONS ll» KLLLO'Ji lU
SArtt*LlHG UF VISTUN WlLOtkNLSS AkLA
i. KAHUNAI.
Ha a*
Cok
ttAUOfcAl. l>Akk
bU.iCun'Ul,»
cata
Hcfirld* Uke
NyBph Lake
Cooee Lake
Pern Lan*
4U1-0
4DJ-12
4D3-1J
4DJ-1B
to Slough
Dttr highway
near Freight K6*d «nd
Hr«hol« Klver
v«it Ot WUltt Uk«
Lalitudc / LongltuU*
' J2"
Xaxc «ut-.U ivitlltLl* ou
ebmlitrj
l«k« turvuyed,
alk»Hnltj: 5»
»v«U«bl« OB
i 0.1 1 toul
, d*u
iurv»y*d, field th«rkaj
kuca. ^11; 5.6, total
: IS i>p>, d«l»
on tailor ctenintry
v«it ot Whltt Unt.
bug iln.i
o«»t oi Nymph
M*y, »cta
«n(|
etc*
tail ot CrlEily Uttu. •
•lullow uciJ4 lik.uly
tn« Blddl< oi
U*,e. p*ii 7,4, taul
• Iktlintlj 0.31 p|>a, «bua(Uiot
d«u »«ill»biii (oatipg back
to early l»0ll'»)
•outt. ot itelutlon Luku,
d>atropolc bog llk«ly
l»kt probably Ury
}. Approximately 2,032,721 acr.i o( Ycilowecoaa National Park have been
rccoi.Bended to Congeal* foe dm l&nallen a* wlldcrnma.
BanageKnt ot the backcountry le carried out in • deit|oatlon. UPS
(197B) apeclfy that ulldtruaaa ajujig«e^c.t poilclvi art bxtondtfd to "patk ac«al
that iiave bucn atudled and reco»>ud*d for wiiiUroeai d«el|catlon." lor UMtt
rttaione, and to protect ethar ulldiroeaa-ralated valu.i, Yallvwttop* ttellooai
Park etall 1» geoerally oppoatd to the uae ot Itcllcoptera to taaiple lakea in
the baekcountry. If It can be ihown that the only Itaaible Btana tit aaBpilnf a
Hutted uuaber of lake* ii by tUc uie ot • Lellcoplir, conelderatloo wlli b«
(Ivao on a caaa-by-c*»a ball*.
I" 4. Yallovitonc Hatloaal Park at^ff 1* prepared to aaalat £PA raa-^rchan with
/ boreti, vablelat, aJid peraoanal IB the **Bpllog uttort.
-------
H,.. .«*<••«•?.—
4UJ-7J
4D3-7S
44«49'*S-
*.4°1J'S"
TrlloMr* Uiki>i. •urvnyart.
fti. 7.B-8.3, total »mUnl-
Uj. JO-40 «•• O*1" «v«U-
• Dl* aa mter chcmiitiy
§*mpl«tf( pH! 6.8-7.1.
•ikallolty: 14-16 PP«i
-------
LETTER #34
•V' '
WILDERNESS OUTFITTERS
Smoke and Thelma FAser
Telephone (406) 549-2820
3800Rolllcsnoke Drive
MISSOUIA, MONTANA 59802
March 26, 1985
W.iyne D. El son
EA Project Officer, M/s 443
US Environmental Protection Agency
1200 Sixth Avenue
Seattle, HA 98101
Dear Mr. Elson:
I am sorry this reply is a little late, however, I did not realize
that the EPA was going to do a National Surface Water Survey of Western
Wilderness Lakes this soon. I was also unaware that the comment period
was so short. It is unfortunate that you did not get your information
out to more of the people whom this survey will directly affect.
I am strongly opposed to any use of the helicopter to obtain these
water samples for this survey. 1 have been involved in the wilderness
movement for twenty-five years and I feel I was somewhat instrumental
in the Montana movement for the creation of the Wilderness Act of 1964.
This act specifically forbids motorized transportation of any kind, in-
cluding the landing of helicopters within wilderness.
As a commercial outfitter for twenty-five years, I know the Bob
Marshall Complex thoroughly and am well acquainted with other wildernesses
within Montana. I can strongly urge that you use conventional transporta-
tion to obtain these water samples, such as the horse or hiking. Most all
of the lakes and water areas can be visited very easily by these modes of
transportation. Vou have obviously known for some time that these water
sairi[.lus wrjro necessary and again, I feel strongly that you did not notify
the public and the people affected by this early enough so that public
response could be made. The water samples you plan to take happen to
take place in the fall and this is the outfitter's primary season for
hunting biij game. Outfitters, of course, have their wilderness camps or
hunting areas around many of these lakes and will be disturbed greatly by
a "scientific huliocopter".
Page 2
March 26, 1985
Wayne D. Elson
In closing, I would like to state that I am strongly opposed (as
I'm sure most outfitters or users of the wilderness would be if they knew
of this survey) to using heliocopters as a way of getting water samples
for the National Surface Water Survey. ' I feel you are spending way too
much money for this survey that could be done Very easily by the old tried
and proven method of hiking or horseback.
#183
Please keep me informed.
Sincerely,
Arnold "Smoke" Elser
AE:te
#186'
#187
M»MO«H Of
MONTANA RUTFITTRR AND OUID«'« A»»QCIATION
PHOFIBBIONAU MmoiHNIBk OUTFIT T«H>» A»«OCIATION • MONTANA Wll.0«RN««» ASSOCIATION
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LETTER #35
SFATE Of CAUfOCNIA
CEOICE DEUKMEJI
AIR RESOURCES BOARD
1102 O SIKH
P.O BOX 28)5
MC«AM[NIO. CA 9HI2
Wayne D. Elson
-2-
March 27, 1985
(916) 445-4383
March 27, 1985
Wayne D. Elson
Environmental Assessment
Project Office (M/S 443)
U. S. Environmental Protection Agency
12UO Sixth Avenue
Seattle, WA 98101
Dear Mr. Elson:
Thank you for forwarding to the Air Resources Board
copies of the 'Draft Environmental Assessment for the National
Surface water Survey, Western Wilderness Area Lakes' prepared
oy the Environmental protection Agency. This document presents
a clear picture of the need for implementing the lake sampling
program to establish the sensitivity of lakes to acid
deposition damage in the western United States.
This survey marks the first time the federal acid rain
research program has implemented a comprehensive project of
direct interest to California, so we are particulary pleased to
offer our endorsement.
The evaluation of potential impacts of the four
alternative sampling strategies is well done and relatively
complete. However, the discussion of 'Impacts to Water
Bodies'of helicopter use on page 62, Section 4.1.4 needs
further elaboration. It is desirable that the effects of
routine helicopter emissions on both the terrestrial and
aquatic systems be consiaerea. During the on-site sampling
period, helicopter engine emissions may have an adverse impact
on pristine air quality in the wilderness areas and on dilute
surface waters in sensitive regions. While these impacts are
minimal and probably transitory, information on the level of
emissions ana possible mitigation measures needs to be included
in this document if it is to be considered complete.
Again, thank you for your efforts in support of
California. I would appreciate your keeping us informed on the
progress of your survey in California and on the sampling
approach you ultimately select. If you have any questions
regarding these comments, please contact Dr. John R. Holmes,
Chief, Research Division at (916) 445-0753.
Sincerely,
amds D. Boyd
Executive Offiter
Robert M. Reed
Environmental sciences Division
Building 1505
Oak Ridge National Laboratory
Oak Hidge, TN 37831
#189'
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LETTER #36
KAK 2 7 ms
James Phelps
Public Lands Chair
Montana Audubon Council
2110 Bradbrook Court
Billings, Montana 59102
March 22, 1985
Wayne D. Elson
EA Project Officer, M/S 44-3
U. S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 96101
Dear Sir:
Please consider this letter as comment upon the draft
Environmental Assessment, National Surface Water Survey,
Western Wilderness Area Lakes, dated March 1, 1985- We
note comment is due by this date, March 22, 1985- This is
a very short period of time for a citizen conservation group
to canvass it members on an issue, find among them those with
information, and in turn make the necessary comment. With
all tne other issues we Just simply did not have sufficient
time to do so. We realize the statutes governing and/or
the regulations are probably set within this time frame,
but again had no real opportunity to check. It is also
not uncommon to extend comment periods without everyone
affected learning about such extensions. With all of
tnis, we hope you accept the brief comment.
The proposal seems to be a common-sense approach to the
problem. No one wants to damage or destroy the wilderness
values and the use of hellocopters—perhaps a transitory
disturbance—looks to be the best alternative. Acid rain
is a question that needs addressing and knows no boundaries.
Therefore, we offer no objection.
I will propose our Council discuss the question at our
next meeting so as to gain the attention of our 8 chapters.
Very truly yours,
V
Kr. Robert M. Reed
Environmental Sciences Division
Building 1505
Oak Ridge National Laboratory
Oak Ridge, TU }?6}1
Harriet harble, President
Montana Audubon Council
p. 0. Box 649
Chester, HT 59522
LETTER #37
Wayne D. Elson
E.A. Project Officer
M/S '1-13 USEPA
1200 6lh Avenue
Seattle WA 98101
Dear Mr. Elson;
'13BS
5201 Dururet Ave. Apt. 25
Bakersfield CA 93309
March 21, 1985
I am writing this note to inform you of my support of the Environmental
Protection Agency's plan to sample western wilderness area lakes by helicopter
for potential acid ruin damage.
This alternative is superior over pack animal sampling because it is much
faster, cheaper, and would probably cause less "foreign" damage lhan a horse
or mule pack expedition. An exception to the no molcrv/.c-d vehicles ixiliry
should be made in these wilderness and near wilderness areas in this one ea.se.
I don't believe that the effect of a momentary blast of helicopU-r noise could
compare with the long term potential damage to an ecosystem by acid rain run-off
into lakes and rivers. There is no natural buffering sjslun oT limjstone and
other carbonate rocks in California, so this could someday be a signi I icajit
problem if the amount of carbon dioxide and other reactants released into
the atmosphere continues.
1 work for a petroleum engineering company as a geologist and I enjoy
hiking and camping in the mountains around Bakersfield. I have then both
professional and personal interests in the resolution of this issue.
Thank you for allowing me to express my support of the exclusive use of
helicopter sampling plan, and for your desire to moniter and solve a very
real and serious problem.
Sincerely,
"Laurie Ellen Scheer
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LETTER #33
COLLEGE OF NATURAL RESOURCES
UMC5J
UlahSun Univ>f|ily
Luuor«on
In ihv l¥50'a compared with that collected In meant yuum shown
con»ld»r«bl« chang* In tha pll. Evan though tha data colluctgd In tho
ll'iO'e li qumt lonubla a» to It) accuracy bocauaa of tha muthodl uood,.lho
Urns, conilatont dlf(iirvncaa, oftan in axcaai of 1.0 pll, strongly auggeut
acidification ot lak»o. Thla ia«oa raaaonabl* glvon tho low bufforlnii
capacity of thva* lak«a.
Slncu only a f«w of thaia lakaa hava 2-3 data collection dacaa
b«glnnlng In tha 1950'i, 1 would auggtat on* or two of thvaa lakaa ba
Includud In your aurvuy, If th«y ara not Included at clilu tlma.
Plaaaa add ny nana to your Balling Hit concarnlng chla project. 1
would ba «ap«cUlly lnt«ri>it«d In knowing which lakaa, if any, In tha Ulnta
Mountalna you ara planning to aanple.
gincaraly,
Dennla Auatln
Wildlife BlologUt
#190
DAija
(VR.10 'OS lliO<1 Era BEflTTUi ICGIOtt X
P.B4
Vtul Cl««ry
Match 6, l«BS
fata 2
Th« o«i* ttiadt in lupport of htllcopcar aceaia In Saction 3.1,3,
bagtnnlnj on p»«i 33, could »lio bi mad In lupport ot IQDIO naana
ot dtpaaltloa moat Coring. A* tuggtatid thatain, nnco an araa ia
diiivnacad wlldmiii It comti undar humaD influanc* du« Co lei
m*n»|«mane t«1utroniiDCa end ti\t more or Ian coBCintraCad in dun
of ptopla. and botin. A faw diiccataly toeac*d nunLtoring lien
•liould ba Itai ob.laetUnibl* than tha tvldtncai of vl«it«tion In Chi
tat* populae porttoni of tha area,
AJI itittil in my pravtoui lattar, wa can tuppart tha propoitd
• uipUnt tttatk aa a maana to add to eh* knawladg* of lak* acidity) la
• il«vta« It* i««ia»« ffuvihar iailuvivi al ratfulahLun* wiUioua a bady aff
(upportlrg avldano*, w* could not tndoraa Lc.
Wa ippraciat* tha opportunity to raviiw thia draft, tad would
Ilk* Co b* kipt in(oroad on tha projaot.
\<\
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.-:''. -i. -."*;. .< ,.>Froncl«co. CA 94102 (415)986-1532
M«ry J«w Merrill. Prnktont
MEMO
TO:
FROM:
RE:
March 11. 1985
State Forest Department Rm. 1416
Resources Building
9th and O Street
Sacramento, 95814
League of Women Voters of California
926 J Street #1000
Sacramento, 95814
Permission for EPA to proceed with the National
Surface Water Survey of California Lakes
The League of Women Voters would btlge you to grant the above
permit. After attending the briefing meeting on the project, held
In San Francisco last month (Feb. 11 X It la our opinion that any -
disruption of the environment would be of a very temporaty
nature. At this point, when concern about acid deposition has
been receiving much public attention, the data to be obtained
appears to be valuable and necessary If we are to establish a
viable program for protection of our mountain lakes.
Thank you for this opportunity to attend the briefing meeting
and to comment on the proposal.
Mary Jane Merrill , President
Ya-**^*- ^4o^^-«--—
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-as 11:11 EPH SEATTLE REGION x
BPR.O9 'BS 16.-47 EPfi SEfiTTLE REGION X
P.SZ
f. Cekndg 8OJ1 a (J»M1B3)
April 2, 19SS
Wayne D. Elson
EA. Project Officer, M/S 143
0. S. Envlroncantil Protection Agency
1200 6th AviiQua
Seattle, Wi 93101
Dear Ur. Elaon;
Thank you for the opportunity to consent on the Draft Environmental Assess-
ment for the national Surface Rater Survey. We are sorry for the lute reply,
but hope that our consents can be considered nonetheless. Our constants are
as follows:
- Because of the shore duration of sampling at each lake, we do not
anticipate any serious detrimental impact on wildlife in the aras.
- We are concerned about establishing a precedent for the use of
hallcoptera in wilderness areas, but feel that the importance of
this study and the narrow "window" for data gathering justifies the
use of helicopters in this Instance.
- Our major concern is the possible disturbance of or conflict with
Bis gaxe hunters In the field during the sampling period. We re-
ducat tlldt aaaipHns acbadulaa be ftdjttACad A* much m* poevibl* to
svald open bunting areai. Be have discussed this already with Lea
Sprengar of your Denver office and feel that icost conflicts can be
avoided or reduced.
- Da euzaaat tb»t tha helicopter* b» clearly a*rka4 "BPA. Aj;ld
Study" or slcllar wording 10 that bockcountry visitors In the ore*
alll be Informed »g to the purpose of the visit.
— We would liVe access to the data when it is collected and processed.
We feel that this trill be an Important addition to our lake data bank
and general understanding of high Lake cheoistry.
Flwie fael free to contact u« If you have question* or need nore information.
Sincerely
rD«7id
Hlldltfe. Fcograo Speeialln t
WJ/jh
Ai. ncAOuneco, o»»*<* H.
Via* Cnmlrmmn *tMo*mm* M, I
April 8, 1985
Mr. Kayn* D. Elson
EA Projact Officer, M/3 443
D.S. Environmental Protection Agency
1200 Sixth Avenua
Seattle, HA 98101
RKs National Surface Water Survey
Western Wilderness Area Lakes EA
Dear Mr. Bisoni
Enclosed are aommenta by the Environmental Defense Fund on the
alrgV^-t'Klfrt'Bn~eiV **• ?PP *>••• ^1-«ya'3 » -o-oi^r »^tiw« r-olo
ia efforts to protact th« Rocky Mountain west from the ravagas of
aoid pollution damage. A» part of EDP'a caDp»ia;a, wa have
P&x-fcloi.pmfc»^ »obl-v*ly in n*w •aurcja parmiti proaaodlnga undar 1^ho
Cl*«jt JL!E Xat, »nd ara in litigation in Arizona against tha two '
largest SO2 emitters in the Kent.
We also lobbied extensively last year to expand the NAPAP
research program to include an assessment of effects on aquatic
resources in the We«t. EOF was pleased and encouraged by NAPAP'e
decision last summer to extend the National Surface Water Survey
to include western high country lakes. EOF is convinced that the
pristine wilderness lakes in the West are extremely vulnerable to
acid pollution damage, and that preventativa measures must be
taken now to ensure protection of this invaluable resource.
Enclosed is a copy of EDF'S strategy for protecting high country,
"Safeguarding Acid-Sensitive Waters in the Intermcuntain West."
These decisions will be made primarily within the context of
permitting new sources of acid pollution under the clean Air Act.
But good decisions will not be made if good data describing
current lak* chemistry are not available.
On the whole, data are available for only a small fraction of
the wilderness lakes at risk from acidification in Colorado,
Utah, Wyoming, Montana and Idaho. And of these, only about 16
have more than a single summer grab sample. Recent evidence
collected by a university research team at lakes adjacent toe
Bnowmaaa Hildarnaaa in Colorado shows that short-term
acidification ia already occurring during snow melt. A more
thorough and broadar-baaed investigation of high country lakes,
especially headwater lakes, is desperately needed.
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flPR.09 'B5 16:51 EPfi SEftrO£ REGION X
The MSWS will help fill this large gap in our knowledge of
pollution affaota in tha Woat. The data to ba collected this
year as part of th» ragion-wida survsy of more than 700 lakes is
• naoaaaary pert: o£ designing an ad&quBte long-term sampling
program that will roflact the effects of pollution over tine.
Ttii* year'a autvay is a first mtop that provides a baaia for
• •l«k.« far mar* d«t«il«d study, tho mon«y apant on phaia* 2
and 3 Pight be misdirected.
Aa we note in our comments, the U.S. Forest Service has a
statutory mandate to protect forest wilderness lakes from the
effects of increased air pollution. But the Forest Service to
date has not collected adequate data to carry out that mandate.
KD7 therefore calls on EPA to carry out the NSWS in the West, but
we also ask that you make every effort to minimize unnecessary
intrusions into the wildeneas by helicopter. We urge you to
evaluate carefully, in conjunction with the Forest Service, where
timely •»i»pl« raoovary can ba acoompliBh&d without helicopter
<*••- Bvife. wK*r« 3uafcl£i*dr wa uraa feha PoraatL Saz-vica to allow
halioopt^r Acoaaa t.o Imka* that ara not raadily aoaasalbla by
graand ttr&naport within tha tlma ra^ulrad for Bampla raoovary and
analyvla. fliaoa bha lak«a moat in naad of aauplin? aro
tha haadwatax lakaa, EOF eirpacta that helicopter access will be
noaded in some wilderness areas.
Aoeess in thla case la Cully justified because of the mandate to
protect wilderness area values, including lakes, from acid rain
under the Clean Air Act. Access for this purpose should not be
confused with access for purposes unrelated to performing the
Forest Barvica's statutory mandate to protect the wilderness from
increased pollution. No other data-gathering proposal received
by tha Forest Service is designed to contribute to fulfilling the
Foraat Sarviea mandata undar tha Air Aat. Nor «ra any likely to
be.
Thank you for your decision to expand the NSWS to include western
high country Lakes.
Sincerely
Ro
coi Max Peterson, Chief, DSPS
John B. Crowell, Assistant Secretary, OSDA
Lee Thomas, Administrator
John Welles, Regional Administrator
. fiPR.09 '85 16:54 EPft SEftTTLE REGION X
P. 04
BEFORB TEE 0.9.
ENVIRONMENTAL PROTBCTIOH AGENCY
COMMENTS ON DRAFT EHVIHOHMENTAL
ASSESSMENT FOR THE WESTERN WILDERNESS
AREA LAKES PORTIOH OF TBS NATIONAL
SURFACE HATER SORVBY
Submitted on behalf of
the Environmental Defense Fund
April 8, 198S
Prepared by
Robert VTuiSca
Regional Counsel
Benjamin Grint
Legal Intern
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nCh.U-J 'tt> 10 ;!>V UM
MXIU) X
P.OS
FIPR.09 '05 17)01 EPfl SEflTU£ REGION X
I. IHTRODDCTIOS
The following comcenti are filed on behalf of the
».«•!..__>.!.«l D.«»n«« Piuid (BDV). BOB i« > aharie»bl«, non-
profit, pablla m«ab*r«hlp organization composed of •Cisntiata,
l«»yara, •aonomiatc, •dao»toca and oth«r concerned citizens
dedicated to the protection and enhancement of human health and
tit* •nvixonaant thorough research and •duoation and through
judicial, legislative, and administrative action. Organized
under the lava of the state of Hew York, BDP maintains regional
office* in Boulder, Colorado? Washington, o.C.t New York City;
fcichmond, Virginia; and Berkeley, California. BDP hai 47,000
active Beffibera nationwide.
II. SUMMARY
EDF's comments on the Environmental Assessment (BA) prepared
by BPA for the completion of the Rational Surface Water Survey
(SEWS) in the westsrn wilderness area lakes focus on 1) the
alternatlvei proposed by EPA for completing that study, 2) the
duty of the Forest Service (PS) pursuant to the Wilderness Aot
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(ff..03 'OS 17: IM
i 5&tm_E REG10M X
to reach all lakes selected for the survey. The helicopters
wi.ll l&nd, t*k* ••v«r&l maaaucamarifca Along with a water sample,
£i*ld baa* l»fa wh*r* t.h« wati^r «aiDplea wi.ll b
Al-tarnativa 2 replaces helicopters with horses carrying survey
teams. The survey teams will collect the water samples using a
rubber raft, take some initial measurements, prepare the samples
(or transport, and return them to the lab far further analysis.
Alternative 3 combines the first two alternatives, using horaes
to reach those lakes from which samples can be transported within
8 hour a to the field base lab, and helicopters to sample all
others. Under this plan, all chemical measurements and
analytical procedures used, including those performed on. samples
gathered by teams on horseback, will be identical to those used
in Alternative 1. Finally, under Alternative 4, the "no
action* alternative, no data will be collected from wilderness
area lakes.
A. Alternative 4 Is Rot An Acceptable Option.
EDP contends that Alternative 4 is not acceptable because oC
the critical need to characterize the chemistry o{ western lakes.
To E~t« in tha »l«t Topa. Mount Zirlcla,
JTJ.B Brldg^ir And w*miEiueh« wild*m««v ar«*a ehov that high
mount-Bin lak«» h»v« low alkalinitiaa, and the high altitude
vat«rah>d» oft«n hav« littl«, if «ny, of tha £«»taroo that can
provide aaid neutralizing capacity such as developed soils and
the btonvB* of a mature foceat. In the Jim Bridger, for
•«»mpl., «om. l.k.. h«v« • 1 W • 1 i n i t i • • aa low •• 20 uaci/1, and many
FFR.09 '85 17:07 EPft SEfiTTLE REGION X
P.03
aca below SO ueq/1. In other words, many of the wilderness area
lakes selected for study are among the moat sensitive lakes on
tha planet, and could be acidified with 10 times less acid input
then some lakes that have already been acidified in the
northeast. Consequently, these lakes ar« the most important
ones to study. If the wilderness is to be protected for future
generations a« mandated by both the WA and the CAA, it is
essential that data be gathered about the most fragile parts of
the system. Without such baseline data, it is virtually
impossible to apply the protections guaranteed by tha CAA because
the Act requires a demonstration by the FLM that en adverse
impact will be caused by emissions from a new source. 42 U.S.C.
7475 (d)(2KB)(iii). But auch demonstration cannot be made
without data, unless EPA adopts the NEPA rule requiring "worst
case" assumptions to be used when data are not available. So far
EPA has not required the states to use such an assumption.
Absent such a requirement, the Act imposes an "affirmative
responsibility" on tha FLM which cannot be met without data.
Vherefora the no action altarntive ia unacceptable unless the FS
implements an equally comprehensive program of data collection on
it 8 own.
B. The Alternative Selected Must Provide Reliable And
Accurate Data
In it« EX, th« BPA contend*. &nd EDP agraa*. that regardless
of th« method oho««n. th» d«t» Qathaeed must be accurate. The EA
•••••••• th» v.riou. •lt*rn»tivaB in terms o£ the duality of the
data produced and eoneludea that Alternative 1 (helicopters only)
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ffft.OJ "35 17:11 QY1 SCA7TLE REGION X
P.09
will yield the moat accurate and complete data. The EA also
concludes that Alternative 2 (horsea only) will produce
unreliable data because of 1) the possibility of sample
aontani-n*eiaa during filtration and prooaaain? at the Bita, 2)
tha increaaad number of sampling crews, 3) the variable transport
time to the field base lab, 4) the incompatibility of the data
with data collected in the midwest and east, because of different
protocols, and 5) the reduced number Of lakes that could ba
•aapled because of pbyaicl logiatics, certain MSWS criteria, and
a limited amount of time in which to collect the data (3-6
weak*).
While many of these assertions remain unsuppported by
evidence in the EA, ED? believes that tha reduced number of lakea
surveyed using horses only, is enough to cast serious doubt on
this approach. As previously explained, the most important lakes
to study are thoae located at the highest elevations, and
consequently, have the longest travel times or are the most
difficult to reach by horse. Under Alternative 2, theae lakes
would uodoubtably ba the first to be dropped from the study. The
importance of including these lake* in the HSWS is based on more
than tbeir sensitivity to acid deposition. As the EA points out,
if m study based on a small portion of tha total number of lakea
is to be valid as to the whole, tha sample portion must be
selected randomly, including lakes from all area*. If those lakes
which are difficult to reach are dropped from the selection pool,
tha selection will no longer be random, and the validity of the
survey will ba seriously undermined. Thus, not only are the
fiPR.10 '85 68:11 EPft SEflTTLE REGICM X
P.O2
number of lakes sampled important to the Duality of tha study, but
felt* type* o£ i*k«M •fcudiad «r* i.mpoK-fca.ne •• w«ll. Pot tiH«H«
reasons, EOF recommends that in completing the NSWS, the EPA
Should not rely on horses for acceaa to lakes whara data quality
r*qnli.rem«nt> would ba ••r-i-oual.y compromla«d. Bufc. fefa* d»ta.
quality raquiramanta n«=d -to be ndetjuut»ly docum«nt»d. W«
suspect, however, that there will be lakes in larger wilderness
areas where timely sample recovery will not be feasible without
helicopter access,
As for Alternatives 1 and 3, the choice is leas clear.
Under Alternative 3. many of tha moafc significant: probl«m«
associated with the uaa of horses exclusively, will be
eliminated. Because horses will only be used to reach those
lakes from which a sample can be returned within eight hours,
i
exceeding the 12 hour holding time ••eablivhed for eh« N8H9 will
nab aaaur. luoomo^r.bl lity ~ith miAw.»t.*-n .nd ...ti.iiv vawa a.«.
base lab. The lack of on site filtration and processing of the
samples will also geeatly reduce the risk of contamination. On
site measurement* of temperature, pB, conductivity, and
tranapaeaney of the watac will bo collected in th» lama mannac by
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(fK. 10 '85 C8:1S EPrt CO^TLE REGION X
P.03
Wfi.10 '85 03:18 EPO SEBTTIX RCGIOM X
P.04
rubber rafts, less control of sample condition* during transport
(anpocuta of lamplea to duafc and constant motion), and greater
chance of not sampling tha necessary number of lakes due to
adverse weatber conditions. Nowhere in the BA, however/ are the
effect* of these factors on the reliability, accuracy, or
comparability of tha data, fully explained or supported by actual
data. At a. minimum, EPA should make an assessment of tba number
of lakes that can be sampled by horaebaok within the guideline*
of tha NSWS to sac if Alternative 3 is feasible. Without such an
aasassaent, no conclusion can be drawn about the completeness of
the data under tbia alternative. Assuming moat lakes could be •
sampled, EOF is skill not persuaded by the BA that Alternative 3
will produce unreliable or inaccurate data.
C. The EPA Baa An Obligation To Minimize Environmental
Effects.
Not withstanding the wall- juitifiad objective of obtaining
the best data passible, EPA has the obligation to minimize the
environmental affaots caused by gathering the information inside
wildaenaaa jtraai. EOF «tron»ly baliavaa th*fc EPA'a overall
objective should be to gather tha moat reliabla data it can,
impact of Alternative 1 (helicopters only) may be limited, the
impact of Alternative 3 (helicopters and horses) appears to be
less. If Alternative 3 can acheive the Sana data gathering
objectives, EPA has the obligation to use it. Without knowing
the number of lakes which cuat be sampled by helicopter rather
than by horsoe, neither tba impact nor tha feasibility of
Alternative 3 can be adequately assessed. •
to/
Under either alternative, ZDF euspaeta that some halicoptar
use will be necessary. Whila BDV raoogni*** febut Allowing
helicopters into the wilderness will hava a. temporary adverse
impact on the, wilderness, we believe that the crucial objective
of gathering data from the mos sensitive lakaa in' the Wilderness
System justifies thaie use. Vurhar, we contend that the Federal
land manager has a duty to allow their use pursuant to the CAA
K
and the WA of helicopters are found to be tha only viable means
of gathering reliable data.
V. THE FOREST 3ERVICE HAS AN AFFIRMATIVE CUT* TO GATHER ACCURATE
DATA CONCERNING THE ACIDIFICATION OF LAKES UNDER ITS
JURISDICTION PURSUANT TO ITS OBLIGATION UNDER THE
WILDERNESS ACT AND THE CLEAN AIR ACT TO PROTECT KILDEBNESS
AREAS
c
Pursuant to the Wilderness Act, the federal land manager
(FtM) must administer wilderness areas so as to protect tham and
Under the Clean Air Act, the ?LH has an affirmative
responsibility to protect tha air quality related values in such
areas. Taken together, these acts create an obligation on the FS
to collect data that is necessary to protect wilderness areas.
If this information can be reasonably gathered only by using
helicoptera, then the PS'a obligation requires thair use. This
obligation is further illustrated by the language of the Acts
themselves and the legislative history accompanying them.
A, The Federal Land Manager's Duty Under the wilderness Act
Section 2(A) of the WA directs the FLU to administer
wilderness areas so as to insure their eternal protection,
'I',
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I Wilderness areas] shall ba administered for the use
and enjoyment of tha American people in each a manner
as will leave then unimpaired for future use and
enjoyment as wiliarnass, and so ae to provide for the
protection of these aze«s, the preservation of thair
wilderness character, and for tha gathering and
disaeair.aticn of intonation regarding their use and
esjovment aa wilderness . , .
16 U.S.C. Section 1131(a).
The plain language of tha statute requires the FIM to take
protective action necessary to guarantee that high elevation
lakes located in wilderness areas will remain "unimpaired for
future use and enjoyment as wilderness." Thus the PS ha» a duty
to collect data so that informed decisions can be made regarding
actions that would affect wilderness areas. If such data con
be collected oaly by allowing WA briar access Into wildezrieaa
areas with helicopter*, then tha FS's duty r squires suoh
permission t>« granted. This obligation is made even clearer by
the CM.
B. The Federal LAnd Manager '• Affirmative Duty Pursuant
To The CAA.
Section 16»(d)(2)(B) of the CAA charge* the federal land
manager with an affirmative dutys
The Federal Land Manager and Federal official charged
wi»l» «!«••« ««*|»«M»4l»il4«y *»« meJMjr*!***!* »M «u«k I»n4ai
•hall have an affirmative responsibility to protect
the air quality ralatad vmluee (including visibility)
ol such lands within • Class I area.
42 U.S.C. section 7475(d) (2) (3) .
be protected by tfc« r«a*c«l l«jia m«jvttg«r. Tn« AOC'«
history further supports this Intention. The Senate report
Th
la required to protmot f»a»r»l
OC an 0DCa&l±Btiacl v«m«f «v*n *
not exceeded . . .
werful i;oo3.. H»
from d«t«r ior»t ion
While the general scope of the Federal Government's
activities In preventing significant deterioration has
been carefully limited, tbe federal land manager should
assume oa aggressive role in protecting tha air
quality values of land areas under hie jurisdiction . .
6. Rep. No. 127. 95th Cong., let Sess., 36.
satisfied if the rL« fiaa adequata daca. Baoausa congr«»«
mandated that the a a AQRVs ba aggreagively protected by the
federal land manager, it is a neceasary implication that Congress
also imposed on tha Flrt an affirmative responsibility to obtain •
adequate information with wbioh to protect the wildernass.
Without sucn information, tJla rut, canned protacjt wildarnaaa araaa
in a CAA proceeding, since the FS does not have a plan of it* own
designed to gather this data from a representative, statistically
valid sample of wilderness area lakes, it* CAA/WA based duty
requires it to allow tha EPA to use. helicopters to reach lakes
that are otherwise unaocessable within tha guidelines of the
news.
As an example of a recant caaa illustrating tha need for the
type of data the EPA atudy would supply, ECP cites tba Exxo
and
Chevron permit proceedings, conducted in Wyoming in 1984. In
both case tha rs found itself compelled to recommend tha permit*
ba issued because of tha lack of data to support objection* to
tlia proaeota. gut in natetag lea Moonunond«»io«>», th» ra
-------
data. Kaaely, the FS was of the opinion that:
[1] There is relatively little information available to
identify sensitive receptors for air quality related
valuss in alpine and sufcalpine ecosystems.
«ft»l« tfoar
determining baseline physical, chemical, and/or
biological conditions of sensitive receptors.
[3] There is relatively little information available
for identifying threshold levels for air pollutant
impacts on identified sensitive receptors.
Letter from James r. Torrcnco, rs, to Randolph Mood, Wyoming DSQ-
This information, which was lacking in these permit proceeding*.
is precisely the type the FS haa an affirmative responsibility to
collect but failed to obtain prior to making decisions
regarding impacts of the Chevron and Exxon projects on the Wind
Elver range. But this also is the type of information the NEWS
ie designed to provide.
Furthermore, although Wyoming DEQ and the FS relied on data
prepared by devron based on four lakes considered to be
representative of the most sensitive lakes in the wilderness
area, the PS determined later in the proceedings that these lakes
were not the tnoat sensitive. In abort, decisions to allow Exxon
and Chevron to initiate new facilities were m«d« without knowing
what coDaequer.ces theaa actions would have on large wilderness
Areas. EPA la proposing to gather some of the information the FS
should have before these permit decisions ere made.
If/,
C, Legislative History Demonstrates Congressional Intent
That th« FLM Err On the Side of Protection.
When doubt arises, whether on AQRV will be adversely
impacted, Congress haa directed the FLM not to subject a Class I
laud's AQRVs to such a risk. Senate Report No, 127 accompanying
the Act states that, "In case of doubt, the land manager should
err on the side of protecting the air quality related values for
future generations." S.Rep.No. 127, 95th Cong., 1st Sees., 36.
This policy directive demonstrates the high level of protection
intended for Clasa 1 AQKVs. While it undoubtably applies to the
FLM when he is determining whether to allow Increased pollution
in a Clasa I area, it also applies to this situation where the
PLM must balance the present impact of helicopter access against
the future impact of further acid deposition. If the PLM is to
comply with this congressional policy to err on the side of
protection, it must allow the temporary, limited impact of
helicopter intrusion into the wildernean, in ordar to gmtbar data
that will serve to protect the AQKVs for future generations.
0. Mot Only Does the Forest Service Have A Doty
to Allow EPA to Use Helicopters Where Required,
But This Use is Consistent with FS Regulations
Under Sect. 4(c) of the Wilderness Act, FS policy (DSDA,
undated) states that aircraft (Sect.2320.3)
taay be authorized for use by other Federal agencies,
officers, employees, agencies or agents of State and
county government a when necaaitary to moat, minimum
requirements for protection aod administration oC tha
area to meet the purposes of the act. The use of
equipment, structures, or activities listed »bov« may ba
approved al»OI (1) [Wnen] oltjier ma aaminl«tr«ti-w» oi m
cooperative activity essential to the management of the
wilderness cannot reasonably be accomplished with
primitive methods or by nonmachanical means. In
determination of what is reasonable, there must be a
-------
shewing that the need IB based upon more than
efficiency, convenience! and economy . . .
PS regulations go on to state that motorized equipment
and/or ir.ecb&nical transportation in wilderness areas con be
permitted only if the situation meats at least one of tb«
following conditions (6oct.2326.il)$
a. It is obvious that the situation involve* an
inescapable urgency and temporary need for speed beyond
that available by primitive means . .[e.g., fire
•Depression, health and safety, law enforcement]
b. A delivery or application problem exists which cannot
reasonably be met with the use of primitive methods . .
[e.g., delivery of supplies or material to construct or
caintain improvements necessary for management of the
area for the purposes of the act . . .]
c. An activity essential for administering the wilderness
is confined by limitations of time, season, primitive
manual skills, or other restriction which makes the job
impossible by primitive means . . . le.g., maintenance
of trails and other improvements, construction of
trails and ether improvements, geodetic control]
d. A O«O«>»ITY and aancinuing progzcm w«» ••tablichad
to«Cor« t^n« unit: waa A*»QQKpov*c«« *n«0 «ji« *m-+*.*»m~*.
Wilderness Preservation System on the basis of using
motorized equipment, and Its continued use is ••••ntial
to coctlnuation of the program.
The limited use of helicopters to reach high elevation,
sensitive lakes in order to gather data, helping to prevent
their destruction, is certainly an "activity essential to the.
uo.g«m*nt of tJi« mlamxnmmm (wbiabl annno* i-..«on«bly b*
accempllaoea with prlmntivo metnoAB or by nonm«ehiuiio«l m««ji»."
Further, this use is consistent with both Section 2326.ll(a) and
(Jo); without some nellcoprer u*«, B«O«U»« of «»• »••« *»«• .jr«.j,
and limitations of time and season, many ef the most
s»r»itiv« lakes will, go unstudied. Because the limited use of
*.11c,<=rt«r« to carrv out »n activity ••••ntial to th« protection
of the wilderness system is consistent with FS regulations and
policy, EDF urges that such permission be granted.
IV. THIS EXCTT10N TO TEE GENERAL PROHIBIT10S OF MOTORIZED
ACCESS TO W1LDEJWE6S AREAS MUST BE CAKEFDLLY LIMITED
TO ONLY THOSE SITUATIONS WH2SS SCIENTIFIC MONITORIHG
IS NEEDED TO PROTECT THE ENTIRE WILEERNESS PRESERVATION
SYSTEM PROM A LOHG TERM SYSTEM-WIDE THREAT
BDF shares the concern of the FS, EPA, and other
environmental organizations that this one time request for
motorized access will serve as a precedent for granting other
requests, in order to insure that this undesirable result does
not occur, the FS must narrowly tailor this exception. EDF
believes that the proper standard for such requests for motorized
intrusion into wilderness areas should be limited to those casss
where the purpose of the scientific study is to protect the
entire Wilderness Preservation System from a long term, system-
wide threat. EDF emphasi2es the words "protect" and 'entire
Wilderness Preservation System," because these criteria will
severly limit any further intrusions. It is highly unlikely that
a study for the purpose of protection, of «hi« magnitude will
occur again. If it does, it may be that the intrusion is
Justified. In any event, thin •tctndacd will «lmo»t •xoluaivcly
limit helicopter use to this NEWS study.
V. CONCLUSIONS
ror the reasons set out above, EOF recommend* the following
actioni
1. BOP document the need to analyze samples within the
Bhort haldlAB tim» «t.«i:«iS in efca BA.
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F-35
This comment also deals with the appropriateness of the selected water-quality
parameters, stating that buffering capacity was not being adequately addressed.
This is to be addressed in the NSWS by measurement of alkalinity (the capacity
to absorb input of strong acid without change in pH beyond a stated limit); of
course, as with other variables in Phase I of the NSWS, this measurement of
alkalinity is based on a single measurement in time and space for each of the
sampled lakes - more detailed studies are to be conducted in Phases II and III of
the NSWS.
6. Two comments (6,9) pointed out the importance of the pulse of snowmelt
runoff to lake chemistry. This is true, but it would be difficult to
measure as part of Phase I (as noted on pp. 8-9 of the EA). The input of
snowmelt runoff is being studied elsewhere in the National Acid
Precipitation Assessment Program and is appropriate for study in Phases
II and III of the NSWS. Also, see response to Comment 5.
7. EPA concurs with this concern and will incorporate the suggestion to alert
pilots to the possibility of disturbance to or collision with whooping cranes
as part of the training program for the survey and helicopter crews
described on p. 64 of the EA.
8. EPA concurs with this concern as discussed on p. 68 of the EA. Specific
suggestions will be included in the training program for survey and
helicopter crews described on p. 64 of the EA.
9. See response to Comment #6.
National Audubon Society (Letter #7)
10. EPA recognizes that the program could serve as a precedent for using
helicopters for planned research in wilderness areas (EA pp. 29, 51, and
71), but believes that few, if any, future such research programs will be
able to advance equivalent justification for helicopter access. The survey
is unique in that is is designed to develop data for the entire nation on a
problem of national concern; few future studies are likely to involve the
widespread geographic scope of possible effects and sources, the lack of
available data, unique monitoring and quality control procedures, and the
high policy and legislative priority. In some wilderness areas, the use of
helicopters has been permitted in the past, and the issue of precedent is
moot; in areas where helicopters or other aircraft have not been used, the
potential for concern about precedent is real. If the FS allows helicopter
use (i.e., adopts Alternatives 1 or 3), their decision will clearly document
the criteria used to limit any interpretation of "precedence". As stated
on p. 36 of the EA, EPA recognizes (as does the FS Manual) that a
reasonable need for using aircraft in wilderness areas cannot be based
merely on "efficiency, convenience, and economy."
11. EPA has broadened Alternatives 2 and 3 to include the possibility of
accessing lakes by foot. The implications of these alternatives on data
quality are discussed in the supplemental analyses provided with the Final
EA. EPA is reviewing submitted proposals.
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F-36
12. The discussion on pp. 50-51 of the EA addresses the suitability of using
helicopters in wilderness areas. Problems with using non-motorized
access are discussed in Sect. 4.2.8 of the EA.
13. Sampling during the fall will avoid breeding periods of the bald eagle,
peregrine falcon, and migratory waterfowl. As described on p. 61 and pp.
64-68 of the EA, EPA Base Coordinators will work closely with local land
managers to schedule sampling to minimize impacts to wildlife and
recreational users.
14. Two comments (14, 44) dealt with the potential for adverse ecological
effects from spills of fuel or reagents. As noted in Comment #44, some
toxic effects could occur other than those discussed on p. 62 of the EA;
however, the volatility of the fuel should minimize the period of exposure
for aquatic biota. Part of the training of survey and helicopter crews (p.
64 of the EA) deals with practices to avoid the possibility of spills of
reagents and fuels; also, proper maintenance of helicopters should reduce
the likelihood of fuel spills.
State of Idaho, Department of Health and Welfare (Letter #8)
Comment acknowledged.
Wm. A. "Bill" Worf (Letter #9)
15. The EA (pp. 35-37) and the revised Summary and Conclusions address
these concerns.
16. The comment does not correctly quote from the Wilderness Act. The Act
does not set forth "THE minimum requirements" (emphasis added). It
states "minimum requirements," thus suggesting that such requirements
are dependent on each situation and context, and not some body of set,
inflexible minimum requirements. The revised Summary and Conclusions
discusses "minimum requirements" in relation to this action.
17. Staff expertise is appropriate for the issues addressed.
18. The Summary and Conclusions have been revised to clarify the discussion
of the purpose of establishing the Wilderness System. The EA clearly
states (p. 53) "While the most obvious wilderness use is recreational,, it is
not the primary reason the National Wilderness Preservation System was
established. The objective of the Wilderness Act is to preserve an
enduring wilderness resource characterized by naturalness and outstanding
opportunities for solitude; primitive recreation is provided for, with these
goals as overriding constraints . . .".
The EA also describes in detail the goals and values of the wilderness
preservation (pp. 32-37). The EA (Sect. 1.3, p. 4) includes a description of
wilderness (from the Act), which certainly demonstrates that EPA
understands what is meant by wilderness and why it is in need of
protection. Simply setting aside land and calling it "wilderness" does not
keep it so. Formal designation alone is insufficient protection for these
lands. They must be actively managed. Yet, this is the dilemma the FS
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F-37
and other wilderness managers find themselves caught in: the more you
manage wilderness to protect it, the less by definition it remains true
wilderness. This problem was discussed in the quotation from Roderick
Nash (pp. 33-34) from a FS publication, and is indeed the source of many
of the issues addressed by this EA.
19. The first paragraph on p. 33 of the EA notes that wilderness lands are set
aside by law in wilderness areas specifically because they are wilderness
and are not subject to the same uses and management as are national
parks, forests, and wildlife refuges. This discussion also identifies the
problems with an approach to wilderness that puts too much emphasis on
resource management.
Wilderness as resource was not listed as a wilderness value because the FS
itself does not list it that way in its own publications (cf. p. 32 of the
EA). EPA (p. 49) follows the same three values as identified on p. 32 and
examines projected impacts on these values. Wilderness as resource is not
identified as such on p. 32, nor are impacts of alternative actions on
wilderness as a resource assessed as a value in subsequent sections.
Recreation is not assessed anywhere in the EA as a value, only as a use, as
the document's structure and text clearly show. The first paragraph on p.
49 states that "the foremost value in wilderness management is taking
those actions that preserve wilderness character, that maintain the
integrity of the wilderness" (empahsis added). This probably comes
closest to what the commentor means when wilderness as resource is
identified. Environmental impacts on recreation of Alternative 1 are
discussed on pp. 53-61, while the environmental impacts on wilderness
values are discussed on pp. 49-53. Recreational impacts were identified
in the scoping process as an area of significant public concern, and,
therefore, received considerable attention in the EA.
20. The EA, as stated above, concerns itself with the three primary
wilderness values identified by the FS. The aspect of "cultural museum"
is an attribute of wilderness mentioned neither directly nor indirectly in
the Wilderness Act.
21. EPA concurs with the comment and believes that it has adequately
demonstrated the idea that wilderness should not merely be used as
wilderness (as the comment states), but also be valued as wilderness (pp.
32-37 of the EA).
22. EPA has developed additional information on the accessibility of lakes by
horse (see Appendix E.4). Approximately 40% of the lakes would not be
accessible by ground access within the time constraints defined under
Alternative 3. EPA has a list of randomly selected alternate lakes
available. However, a significant bias would be introduced if these lakes
were used to selectively replace lakes.
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F-38
23. In discussions with local FS staff responsible for the Bridger Wilderness,
and in maps and other information supplied by them (see Table 4.2-1 and
accompanying notes on p. 84), it was made clear that (1) there were lakes
the survey crews need to sample that are farther than a 7 h horseback
ride, and (2) that there are lakes to be sampled that have no horse or
other trails leading to them. No contact was made with FS staff in the
High Uintas for the analysis prepared in the EA.
EPA Base Coordinators have developed additional information on the
accessibility of lakes to be sampled in western wilderness areas since the
draft EA was prepared (Appendix E.4). This analysis shows that as many
as 40% of the lakes are too inaccesible for samples to be transported out
by horse within the 7 h time constraint of Alternative 3.
24. The cost of Alternative 2 is composed of two parts. Part 1 is the
estimated cost of the original survey, which is $3.8 million. Part 2 is the
added cost of Alternative 2, which is $3.2 million. These costs are
additive because helicopters will probably still be required to take the
samples to be analyzed. In addition, a study would be required to compare
25 lakes sampled by the two protocols.
25. EPA staff discussed feasibility of using pack animals with FS rangers in
five wilderness areas (see Table 4.2-1 and accompanying notes on p. 84).
These people were completely familiar with local packers' stock,
procedures, availability, and experience. It was beyond the scope of the
EA to contact individual packers.
26. EPA did not introduce the issue of precedence; it was identified during
the public scoping process (p. 7 of the EA). An evaluation of the extent to
which Alternatives 1 and 3 might contribute to the setting of a precedent
naturally would involve examining and documenting previous helicopter
use in wilderness areas. The issue of precedence is addressed on pp. 29,
51, and 71 of the EA. The EA does contain a statement (p. 71) to the
effect that a reasonable argument could be made that Alternative 1 is
consistent with FS criteria, and, therefore, "neither establishes or
contributes to any sense of precedence." The proposed study (of which the
survey is a critical component) is developing data for a congressionally
mandated assessment and is not merely national in scope. EPA makes no
claims that the purposes of this study are more important than wilderness
values. EPA believes that wilderness values are most directly protected
by implementation of Alternative 1. That results of the study may lead to
measures that also protect lands outside of wilderness should not diminish
the relevance of study results for protection and preservation of
wilderness values. Also, see response to Comment #10.
27. EPA does not intend to use helicopters or install equipment in wilderness
area streams in the West. Few, if any, streams in the West will be
included in the survey.
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F-39
28. EPA has already initiated a public involvement process during scoping of
the EA (Sect. 1.4). The Agency intends to continue this process and feels
that informing the public of its activities, both inside and outside
wilderness areas, is an effective way to mitigate impacts on wilderness
users.
29. Training crews in appropriate wilderness values for whichever alternative
is chosen would be part of the EPA-FS coordination activity (Sects. 4.1.6,
4.2.6, and Appendix E.6).
30. The Summary and Conclusions have been revised to address this concern.
31. As discussed on pp. 78-80 of the EA, the risk of not obtaining data of
sufficiently high quality is least with Alternative 1, which uses an
approach that has been proven in the eastern and midwestern portions of
the NSWS. The use of a new approach to sampling in western wilderness
areas presents a higher, but unquantifiable, risk to obtaining data of
adequate quality. See supplemental analysis provided with this Final EA.
American Wilderness Alliance (Letter #10)
32. Alternatives that include non-mechanized means (Alternatives 2 and 3)
are evaluated in the EA.
33. Previous use of helicopters in wilderness areas is discussed on pp. 49-50 of
the EA.
34. See response to Comment #26
35. Section 3.1 of the EA addresses these concerns.
36. These concerns are addressed on pp. 57-61 and 68 of the EA.
37. See response to Comment #22 and #23.
38. Use of outfitters and guides falls within the concept of Alternative 2 as
described in the EA; Alternatives 2 and 3 have been broadened to include
backpacking as a mode of access.
The National Outdoor Leadership School (Letter #11)
39. EPA has modified Alternatives 2 and 3 to include the use of backpackers
so that as many lakes as possible could be sampled by ground access. EPA
is reviewing the NOLS proposal.
Wyoming Recreation Commission (Letter #12)
Comment acknowledged.
Environmental Testing and Balancing, Inc. (Letter #13)
40. The issue of precedence is more fully discussed on pp. 29, 51, and 71 of
the EA. See responses to Comments #10 and #27.
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F-40
41. Statistically, the statement by EPA that "... we cannot delete lakes from
that list ..." is different from failure to sample a few lakes for a variety
of unforseen reasons. Any intentional or systematic deletion of selected
lakes may have serious statistical consequences, but accidental,
essentially random deletions will not, as long as the sample size remains
large enough to obtain reasonable error bounds to the estimates. Thus,
the perceived contradiction is not real.
42. Helicopters will not be flown in the manner in which they are used for
disbanding game herds. Proper flight approaches when landing in the
center of a lake will minimize, if not eliminate, disturbance of game. As
stated in the EA, all flights will be coordinated with local land managers
to ensure that all such mitigation practices are followed as needed for
particular lakes.
43. The EA (p. 61) specifically mentions Canada geese as of note for animals
potentially disturbed by helicopter noise. The possibility of bird/aircraft
collision is a safety consideration that is real but extremely remote.
Pilots will be experienced in western flying and hence aware of the
potential hazard posed by birds. The aircraft will not be flown as if they
were herding animals or doing stunts, but instead in a manner to minimize
noise effects and maximize safety. These considerations are already
addressed in the EA.
44. If a fuel spill were noted, the lake would either not be sampled or the data
sheet would be marked to guarantee that the sample was identified as
potentially contaminated. Also, see response to Comment #14.
45. The detailed noise data presented in Appendix C are for the Bell 206L
(Long Ranger) helicopter, a turbine-powered machine. Sound-generated
avalanches in early fall are an extremely remote possibility. Wilderness
users would not be exposed to sufficiently loud helicopter noises from
sufficiently close distances (hovercraft would land near centers of lakes,
if that is the deepest point) for sufficiently long durations (20 min. vs a
likely 8 h at 50-ft. distance) to cause ear damage. Bats would not be
active at the time of helicopter flights. Bats, as other animals, would
avoid hearing damage through fright responses and would, as mentioned
above, not be exposed to sufficiently loud noises for sufficiently long
enough times (at sufficiently close distances) to be permanently affected.
46. During review of the Draft EA, a comment was received that EPA use
pigeons to sample the wilderness lakes. Under this scheme, pigeons would
be carried in to the wilderness and then would be used to fly the samples
out. In evaluating this alternative, EPA attended a demonstration at
Rattlesnake Lake, Washington on 3/1/85. During that demonstration
pigeons carried 10 ml samples back to their home base. However, the
sample size required for the survey is 4 liters, which is 400 times the
amount of water that the pigeons could each carry. It was not felt that a
pigeon could carry this sample size. To break the sample up into small
enough aliquots that the pigeons could carry was also not considered
feasible.
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F-41
Oregon Department of Environmental Quality (Letter #14)
47. As discussed in Sect. 4.1.6 (p. 64 of the EA), EPA Base Coordinators will
work closely with local land managers to satisfy local requirements such
as the variance mentioned. In addition, a major purpose of the EA is to
identify such concerns so that they can be addressed by EPA. working
with the State agency or other concerned party.
U.S. Fish and Wildlife Service, Helena, Montana (Letter #15)
48. As discussed on p. 64 of the EA, EPA plans to work closely with local land
managers to minimize potential impacts.
North Cascades Conservation Council (Letter #16)
49. Alternative 3 considers a combination of access modes. If this alternative
were chosen, detailed planning by EPA Base Coordinators, interacting
with local land managers, would consider each lake to determine the
appropriate mode of access (Appendix E.6 and Sect. 4.1.6).
50. This comment encourages the use of a mode of access (foot, horseback, or
helicopter) found necessary for each lake; this is similar to Alternative 3.
The same comment suggests that each lake, in recognition of site-specific
differences in watershed and lake-chemistry characteristics, have a
unique baseline analysis. This approach is more suited for later phases of
the NSWS than for Phase I, which is aimed at developing a consistent set
of data for all lakes.
51. The Summary and Conclusions Section has been revised to clarify the
relationship of the three phases of the NSWS. No subsequent survey of
large numbers of lakes similar to the Phase I survey is planned. Phase I
will provide the statistical basis for extrapolating results from detailed
Phase II and III studies to wilderness areas. The Phase II and III studies
will involve more detailed analysis of fewer lakes, most, if not all, of
which will be outside wilderness areas. Helicopter access to the Phase II
and III lakes will not be needed. In the event that a Phase II or III lake is
in a wilderness area, only ground access would be used.
52. It is unclear from the comment where in the EA any such statement
occurs. On p. 49, EPA states, "That the visual and audible presence of a
helicopter would be incompatible with visitors' expectations of the
aesthetic quality of a wilderness is clear." The EA (p. 30) cites numerous
instances of the projected negative impacts of helicopters on wilderness
users.
53. A study conducted by EPA in September, 1984, demonstrated that the
helicopters are not a source of contamination. Comparison of data for all
twenty-one NSWS chemical variables showed that samples collected by
helicopter did not differ significantly from samples collected from the
same lake using a boat (E. Meier, EPA, Las Vegas, Nevada, personal
communication to R. Cushman, ORNL, Apr. 4, 1985). Not sampling very
shallow lakes (important in ensuring that the Van Dorn sampler not disturb
the bottom when the water sample is taken from a depth of 1.5 m) will
also prevent propwash from disturbing bottom sediments.
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F-42
54. The lakes selected for sampling during Phase I of the NSWS were selected
at random as discussed in Sect. 2.1.1 (pp. 10-14) of the EA.
Sierra Club (Letter #17)
55. EPA believes that the agency is correct in undertaking a NEPA review in
this actaion. The Federal action in this case is EPA's proposed sampling
of western wilderness area lakes. The means of access to the lakes and
the sample protocols are all part of the proposal. While the FS and NPS
have the authority under the Wilderness Act to decide what type of access
is appropriate, EPA will make the ultimate decision on whether the
proposal will be undertaken. EPA prepared this EA to determine if the
proposal could have a significant impact on the environmentally sensitive
wilderness areas. The FS provided substantial input throughout all phases
of developing this EA. The findings in the EA will assist EPA in its
decision on undertaking the proposal.
56. EPA believes that NEPA and the Wilderness Act both apply in this
proposal. EPA has a responsibility under NEPA to determine the impact
of its proposal on the wilderness environment. The FS and NPS are
responsible under the Wilderness Act for determining the mode of access
to these areas. The broad-based environmental review that has been
performed under NEPA addresses the issues that are of consideration
under the Wilderness Act. The findings in the EA will assist EPA in its
decisionmaking process on the proposal to sample in the wilderness areas.
The EA will also provide the information which the FS and the NPS need
on order to make a decision on access.
57. We agree that the FS and the NPS are the federal agencies which are
responsible for making the decisions on EPA access to the involved
wilderness areas. Their decision will be based on the criteria in the
Wilderness Act. We have revised our EA to more fully address these
considerations and believe that the EA now provides sufficient
information for the FS and the NPS to make a decision on this matter.
58. EPA prepared this environmental assessment to determine if its proposal
would have a significant impact on the western wilderness area lakes. On
a cumulative and individual basis, we have determined that the impact of
the sampling would not have significant impact. Based on our experience
with the Eastern portion of the NSWS, and specific information on some
of the lakes, we do not anticipate any significant site-specific impacts.
However, prior to sampling any of the lakes, we will coordinate with
Forest Service Supervisors and Park superintendents to determine
conditions at the lakes and any measures which should be taken to avoid
any significant impacts on the environment.
The Wilderness Society (Letter #18)
59. The issue of precedence is not ignored; it is addressed on pp. 29, 51, and
71 of the EA. See response to Comment #10.
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60. The selection of lakes was done randomly. Many of the most sensitive
lakes are located within these areas. See Appendix £.2.
61. The purpose of the Phase I survey is to provide a statistically valid data
base that can be used as a basis for extrapolating results from future
studies, including Phase Q and ffl, to a regional or national level. Without
the Phase I data, selection of regionally representative lakes for Phases II
and m would not be possible. The problem with existing data is that there
is no statistical base that can be used for extrapolation, so that
quantitative regional assessments cannot be made. Phases n and m will
provide the detailed studies needed to evaluate trends in acidification and
the resulting effects on biota and the ecosystem as a whole. EPA has no
intention of making additional requests to use helicopters in wilderness
areas because the detailed studies would require repeated visits and more
elaborate equipment so that ground access would be most appropriate.
62. EPA has presented its reasons for preferring to use helicopters in the EA.
EPA believes several reasons relating to the need to gather accurate,
reliable, and usable data necessitate helicopter use. These reasons are
unrelated to efficiency, convenience, and economy. Whether helicopters
are safer than horseback or backpack access is unknown at this point
(Table S-l). Discussions with George Schaller (see Table 4.2-1, p. 84), a
FS staff member with the Custer National Forest in Montana having
responsibilities for the Absaroka-Beartooth Wilderness Area, resulted in
his recommendation that the helicopter sampling mode be chosen over
other access modes because of safety (and other additional reasons). In
this particular wilderness area, he cautioned, no access mode was
particularly safe in the falL He stated it was unusually rugged, and some
of the lakes selected offered severe challenges.
63. Downtime is considered during planning to allow for weather conditions,
maintenance of equipment, mechanical problems, and unforseen
circumstances. The 60% figure for downtime was used during the eastern
and midwestern portions of the NSWS and proved to be a good
approximation. This figure should not be a disadvantage of using
helicopters, but simply a realistic planning tool.
64. Alternative 3 has been broadened to include access by foot.
65. EPA disagrees with the statement that protection of wilderness lands will
be "sacrificed for the primary goal of the survey." It is true that the
primary goal of the survey is not to collect data on wilderness areas
per se, but it is also true that the data obtained from the survey can and
will be used by wilderness area managers to identify areas susceptible to,
or already experiencing, acidification and assist these managers in taking
steps, along with other agencies such as EPA, to limit the damage done
and thereby protect the wilderness system. The problem of acidic
deposition is a regional one, and a regional data base is needed to evaluate
the extent of the problem and possible solutions. In addition, the regional
data base will permit the results of studies done outside wilderness to be
applied to specific wilderness areas and problems.
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66. Figure 4.1-1 and accompanying text on pp. 50-51 lay out the relationship
of the long-term threat of acidic deposition vs the short-term intrusion of
helicopters. Whether intrusion by helicopters has been, is, or could
become a long-term problem is a matter of FS policy. The issue of
precedence is discussed on pp. 29, 51, and 71 (see response to Comment
#10).
67. EPA disagrees. EPA believes that the Federal action in this case is EPA's
proposal to sample western wilderness area lakes. Thus, EPA is correct in
undertaking the NEPA review on this action. See response to Sierra Club
comments. EPA also believes that this EA has adequately addressed all
the considerations necessary to make an informed decision on this
proposal including the FS and NFS decision on wilderness access.
Furthermore, in this particular action, EPA has gone beyond the EA
process by providing opportunity for public participation which is
comparable to the environmental impact statement process, i.e., a
scoping process and public review of the draft EA. Site-specific
considerations will be addressed through coordination with the lane
managers prior to sampling.
The National Audubon Society, Rocky Mountain Regional Office (Letter #19)
68. As noted in the comment, grizzlies are less likely to be encountered
during the sampling period than at other times. The possibility of
encounters will be ascertained by coordination with local officials and
steps taken to minimize effects. Sampling will not involve "repeated
passes at low elevations" but one-time, direct descents to lake surfaces.
69. As discussed on p. 64 of the EA and in Appendix E.6, EPA Base
Coordinators will work closely with local land managers. At this stage in
planning, which will begin shortly after the decision on access mode is
made, detailed planning for each lake will be undertaken.
70. See response to Comment #11.
71. Accessibility for Alternative 2 is defined in terms of distance and the
presence of trails to lakes in the Analysis of Feasibility discussion on pp.
80-85. Accessibility must take into account the ability to get both
sampling crews and equipment to the lake.
72. This comment and #133 question the universality of the recommended
NSWS protocols. The proposed methods have not necessarily been
followed by the scientific community in a uniform manner; however, the
goal of the NSWS is not so much to provide data comparable to previously
published data (which vary widely in quality) as it is to provide an
internally consistent data set of expected high quality. See response to
Comment #50.
73. Alternative 3 provides for a combination of access methods that would
take into account protection of wilderness values. There would be a
greater risk of developing comparable data quality with this alternative
(Appendix E.I).
74. Section 4.1 (pp. 64-68 of the EA) describes the suggested mitigation for
these concerns.
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Gary Paull (Letter #20)
75. The EA provides three reasonable alternatives for gaining access to
wilderness area lakes. EPA has broadened Alternatives 2 and 3 to include
ground access by foot as well as by horse. Statement of an agency's
preferred alternative is normally done in a NEPA document.
76. The EA, as a NEPA document, is a full-disclosure document. EPA believes
the EA presents a balanced comparison of alternatives, including the use
of non-mechanical means of access and has discussed the importance and
usefulness of the data that would be generated by the survey.
77. The table has been modified in response to this comment.
78. See response to Comment #75.
79. Landing a helicopter on a wilderness lake does not violate the Wilderness
Act, if the FS or other appropriate land management agency permission
has been obtained. EPA believes that use of helicopters is the best
approach to obtaining high-quality data that could be used to develop
control strategies for reducing acidic deposition. Although not within the
explicit mandate of the Wilderness Act, such controls (and the processes
that generated them) are in keeping with the purposes and the spirit of
the Act (pp. 50-52).
80. The absence of lakes in Nevada and the desert SW is a consequence of the
sampling universe used (see Fig. 2.1-2, p. 12, alkalinity and subregion
boundaries) and of the random selection process. Another random sample
drawn from the same universe might have a few more lakes in Nevada and
New Mexico, but the number would still be few because of the absence of
lakes of interest in these states.
81. The statement is true, but there are also situations where a helicopter
could reach a lake after a snow storm when access by foot would be very
difficult or impossible.
82. See response to Comment #53.
83. Shaking of the sample by pack horse is likely to be longer in duration.
Shaking in a helicopter, however, will also occur.
84. See p. 35-36 and revised Conclusions Section of EA.
Washington Wilderness Coalition (Letter #21)
85. NEPA does not call for any alternative action to be proven beyond
reasonable doubt as the only way any objective can be accomplished.
NEPA calls for a full disclosure and consideration of all the environmental
impacts associated with proposed actions. Some of the reasons for using
helicopters that are beyond their efficiency or convenience are listed at
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the bottom of p. 3 of the EA. EPA is not advancing Alternative 1,
because of the efficiency, convenience, and economy of helicopter use.
Instead, EPA believes that use of helicopters is the best approach to
obtaining high-quality data that could be used to develop control
strategies for reducing acidic deposition (see Sect. 2.5).
The use of helicopters in wilderness areas is a legitimate action under
Sec. 4(c) and 4(d)(2) of the Act, associated FS Manual, and USDA
regulations. See revised Summary and Conclusions.
86. EPA has broadened Alternatives 2 and 3 to include access by foot. Use of
volunteers to collect samples is discussed on p.8 of the EA.
Denver Audubon Society (Letter #22)
87. Phase I is critical to Phases II and III because it will provide a statistical
basis for selecting lakes to be studied in detail and over the long term and
will allow the data from these studies to be extrapolated to regional and
national levels.
88. The quality of data collected in the survey is critical to the survey
objectives and is the primary factor driving EPA's need to use helicopters
in wilderness areas. EPA believes that to get the high quality data needed
for regional and national assessments, use of helicopters is necessary.
Collection of data by other access modes will produce data that is of
lower quality and/or a data base that cannot be used to assess acidic
deposition in the West. EPA believes these data can be used by the FS in
managing its wilderness system and believes the approach is the
"minimum tool" needed to obtain this kind of information. The FS must
decide if the long-term protection of the wilderness system is best served
by allowing these data to be collected.
89. Alternative 3 provides for a combination of access methods to be used,
which would, within certain time constraints, allow some of the lakes to
be sampled from the ground.
90. Lakes were randomly selected, and there is no redundancy here. The
reason for the large proportion of lakes in wilderness areas is that both
low alkalinity lakes (i.e., potentially sensitive lakes) and wilderness areas
are correlated with high altitudes in the mountains. Adding more lakes
for Phase II would not be advisable, because the purpose of Phase I is to
get an adequate statistical sample; having fewer lakes in Phase I would
increase the confidence limits of the Phase I data base.
Sierra Club, Rocky Mountain Chapter (Letter #23)
91. The EA presents a consideration of three reasonable alternatives that are
being considered for access.
Michael Lee Wilson (Letter #24)
Comment acknowledged.
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Sierra Club, Oregon Chapter (Letter #25)
92. See response to Comment #104.
93. Additional consideration of alternative access modes has been made in
preparation of the EA, with specific consideration given to the
possibilities of using ground access. The FS and NFS will determine
whether the use of helicopters can be permitted within wilderness areas
under the provisions of "minimum requirements" needed for
administration or in a manner "compatible with wilderness values."
94. EPA believes that the "minimum requirements" for protecting wilderness
from acidic deposition is the use of helicopters for the survey, and that
helicopter access is compatible with preservation of wilderness values in
these circumstances. As stated on p. 49 of the EA, "To the extent that
other alternatives cannot meet the timing and quality guidelines of the
lake survey, Alternative 1 would be in keeping with the spirit of the
Wilderness Act." EPA believes the use of helicopters, in this context, is
"within the concept and philosophy of the intent of retaining an enduring
resource of wilderness unimpaired for present and future use and
enjoyment as wilderness" (p. 35).
95. See response to Comment #10. Nowhere in the EA does EPA consider
"previous helicopter use as precedent for its proposed action." On p. 49,
other precedents are cited, but not used as justification for the issue at
hand.
96. Two comments (109, 122) note that immediate extraction of monomeric
aluminum in the field is preferable to extraction in the field base
laboratory after several hours, in that less sample degradation may
occur. This is correct, although there are also potential drawbacks to
extraction in the field, as discussed on pp. 76-78 of the EA. The overall
quantitative effect of such a modified protocol on data quality has not
been determined (see Appendix E.I).
97. See response to Comment #23. Subregion B of the NSWS, which includes
Oregon, has one of the lowest percentages of lakes that have been
determined to be inaccessible by ground access (Appendix E.4.)
98. A small number of lakes could be dropped from the sample as long as the
lakes are not systematically deleted and as long as the sample size
remains adequately large. The inclusion of randomly selected alternate
lakes in the sample allows for some leeway in obtaining an adequate
sample.
99. Alternatives 2 and 3 have been broadened to include the use of
backpackers.
100. The question of liability would have to be evaluated carefully on a
case-by-case basis if any volunteers were involved in the survey.
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101. EPA agrees that it is possible that backpackers could carry the necessary
equipment. The following estimates of weight of equipment have been
developed assuming a four person crew: food and water (50 Ibs.), camping
equipment (96 Ibs.), sampling equipment (121 Ibs.), and a raft (65 Ibs.).
This would mean that if the weight were equally divided, each crew
member would carry approximately 80 Ib packs. Equipment such as the
raft and hydrolab are bulky and would require one individual each. It is
likely that more backpackers would be needed, especially for lakes that
are distant (i.e., greater than five miles from the nearest trailhead).
State of Washington, Department of Ecology (Letter #26)
102. EPA has conducted an extensive review of sampling methods, which has
been peer-reviewed, and believes that the methods selected are essential
to obtain the high quality data needed for developing an adequate data
base that can be used to relate future and past research to the regional
problem of acidic deposition. Possible access methods are evaluated in
the EA, and consequences to the quality of data are evaluated in the EA
and the supplemental materials included with this Final EA.
103. Alternatives 2 and 3 have been broadened to include the access by foot.
If this alternative is chosen, the suggestion made will be considered in
detailed planning for sampling conducted between the EPA Base
Coordinators and the local land managers. See Appendix E.6.
104. Alternatives 2 and 3 have been broadened to include foot access. EPA
concurs that the situation described might occur.
105. The cost of each alternative ranges from $4200 per lake to $7800 per
lake. For example, the costs of Alternative 3 are about $4200 per lake.
This figure can be calculated by dividing the cost of the survey for
Alternative 3 ($3.8 million) by the number of lakes (about 900). There are
several things that contribute to this cost.
Sample analysis costs are about $750 per lake. This is because a more
extensive analysis is done than that performed by the Department of
Ecology. In addition, about 40% of the samples are QA samples, because
of the stringent QA/QC requirements associated with this program.
Logistic support, including mobile field labs, field crews, and helicopter
support amounts to about $2300 per lake. Data analysis costs are about
$1000 per lake. The remaining management costs bring the total cost per
lake to $4200.
106. EPA has broadened Alternatives 2 and 3 to include the use of
backpackers, and will consider the availability of experienced personnel if
one of these alternatives is chosen.
Wyoming Outdoor Council (Letter #27)
107. EPA has broadened Alternatives 2 and 3 to include the use of
backpackers, but agrees with the comment that ground access will present
logistical problems and would have a higher chance of disturbing
wilderness users. In addition, the increased numbers of sampling teams
would mean that a significant risk of lower data quality would exist.
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108. See response to Comment #10. A public involvement and education plan
for Alternative 1 or 3, to be sponsored by EPA, will be developed to assist
the FS in informing the public about survey activities.
109. This comment advises that the NSWS data must be able to "hold up under
scientific scrutiny." The peer-review process used in recommending
protocols (see p. 15 of the EA) was employed for this goal.
Bob Oset (Letter #28)
110. As addressed in the EA, Alternatives 2 and 3 involve the use of ground
access as alternatives to use of helicopters.
111. The issue has been addressed on pp. 29, 51, and 71 of the EA. See
response to Comment #10.
112. Alternatives 2 and 3 have been broadened to incorporate the use of foot
access. Random sampling is required for statistically valid, legally
defensible results; there is no basis for selecting "representative " lakes.
113. Alternative 2 has been broadened to incorporate the use of hikers. If this
alternative is selected, EPA will use experienced personnel. EPA is
concerned with liability in using volunteers (Sect. 1.5 of the EA).
Robert V. Walker (Letter #29)
114. See response to Comment #23. Hiking and horseback times were not
estimated from guidebooks but were, as shown in Table 4.2-1 (p. 84),
estimated for one-way transport out by FS staff in the respective
wilderness areas involved.
115. See response to Comment #10.
The Colorado Mountain Club (Letter #30)
116. The EA identifies the major safety and logistical problems of using ground
access. Further evaluation of these problems can only be done during the
detailed planning which will occur after the decision on access mode is
made.
U.S. Forest Service (Letter #31)
117. The Summary and Conclusions included in the Final EA have been revised
to place an earlier emphasis on the conflict of using helicopters under the
Wilderness Act. EPA has attempted, in cooperation with the FS, to define
reasonable alternatives to gaining access to wilderness area lakes. Under
NEPA, EPA is required to state its preferred alternative. It is also
necessary to understand the consequences of adopting any alternative in
terms of data quality and logistics in making the final decision.
118. The suggested wording has been added as the second paragraph in the EA.
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119. Presenting a quantitative analysis of how data quality under each
alternative would differ is difficult to do with the data available.
However, EPA has prepared a supplementary analysis to address this issue
(see Appendix E.I).
120. This comment and #133 address whether the expected data under
Alternative 1 would not be more precise than needed. The objective of
the NSWS is to obtain data of the highest quality that is feasible,
anticipating that policy-makers will need data that can withstand
challenge (e.g., if expensive controls on emissions are proposed).
121. This comment points out that criteria other than sample holding time
should be used to select among the alternatives; factors such as
protecting wilderness values were discussed in the EA and will likely be
used by the FS in arriving at their decision. The seven hour criterion is
not for economy or convenience, but rather for ensuring sample quality.
122. The description of Alternative 4 in the Summary and Conclusions has been
rewritten.
123. EPA believes other means of access are not suitable for meeting the
needs of the survey and, therefore, that the sentence, as written, is
appropriate (see fuller explanation on pp. 50-52).
124. The paragraph has been rewritten in the revised Summary and
Conclusions. The response to Comment #10 discusses the precedence
issue.
125. The Summary and Conclusions has been revised to address this concern;
the random sample must include wilderness areas to be representative of
the region. See Appendix E.2..
126. The revisions to the Summary and Conclusions address this concern (see
revised Table S-2).
127. Appendix E.7 indicates that the second and third lines of the last
paragraph on page 5 will be modified to read ..."(i.e, most wilderness
areas and national parks)...."
128. The data collected in Phase I of the NSWS should be useful to wilderness
area managers concerned with taking steps to protect these areas from
the effects of acidic deposition. In some wilderness areas (e.g., the
Bridger Wilderness Area in Wyoming) sufficient numbers of lakes will be
sampled to provide information useful to the specific area. More
importantly, however, Phase I will provide a regional data base that will
provide wilderness area managers a unique perspective on potential
sensitivity of lakes within the wilderness system. The Phase I data base
will allow extrapolation of results from detailed studies in Phases II and III
and other ongoing research to geographic areas, including wilderness, thus
allowing land managers to understand the nature and extent of the threat
and take steps along with other government agencies such as EPA to
protect the resources. Without such a data base, wilderness area
managers will be faced with collecting data for each area piecemeal and
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will not be able to place their results in a regional context. It is
important to understand that the acidic deposition problem is regional in
scope, and a regional approach to developing data is needed to understand
and deal with it. Exclusion of wilderness areas from the survey would
severely limit the applicability of the NSWS data base to wilderness area
management problems; i.e., it would be difficult to apply Phase II and III
results to these areas and to develop control strategies that would
objectively factor in the sensitivities of wilderness area resources.
129. It is not the specific chemical determinations that will be made during the
NSWS that should be at issue here. Most of the parameters can be
measured with alternative protocols so that use of helicopters would not
be needed. Measurements of monomeric aluminum using the established
protocols require a short holding time and would provide a uniform
evaluation of this biologically important chemical parameter. What is
unique about the NSWS survey is the collection of high quality data from a
large number of lakes within a short period of time so that the data are
comparable to one another and can be used as a basis for extrapolation of
more detailed studies in the future. Without this data base, trends of
acidification will be difficult to identify and proposed approaches to
establishing emission controls will be subject to legal challenge. Appendix
E.I evaluates the risk of reducing data quality that would be involved in
adopting alternative access modes. EPA believes that use of helicopters
is the most efficient and effective way of obtaining the data needed.
130. Section 1.5 of the EA addresses some of the concerns raised in this
comment. Appendix E.7 has been added to provide supplementary
discussion of the concerns raised in this comment.
131. The peer review is discussed and referenced on p. 15 (first paragraph after
the list of chemical variables). Also, see revised Summary and
Conclusions.
132. Information on whether or not each of the 13,506 lakes is located within a
wilderness area is not available. The identification of lakes within
wilderness area lakes was only done for those lakes selected as the
random sample. The location of wilderness areas was unknown at the time
the random sample was selected, so there could have been no targeting of
wilderness area lakes for inclusion in the sample.
133. The comment questions the need for measurement of extractable
aluminum in the NSWS as a whole, and in western lakes in particular.
Data on extractable aluminum are important in characterizing the
chemical composition of lakes and in the selection of regionally
representative lakes for Phases II and III (see expanded list of primary
objectives in the revised Summary and Conclusions). While western lakes
are generally of near-neutral pH and presumably have low concentrations
mof aluminum, the data are important for two reasons: (1) there is recent
evidence that acid sensitive lakes exist in the West [pp. 1-2 of the EA,
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The American West's Acid Rain Test World Resources Institute Research
Report #1. March 1985] and (2) the NSWS calls for a consistent set of
data, and it would not be proper to omit certain measurements because of
the presumed results. See also responses to Comments #70 and #120. An
expanded discussion of the importance of monomeric aluminum follows:
The NSWS objectives relate to all three phases of the survey. Phase II
will include a determination of biological resources in a representative
subset of Phase I lakes. Phase III will be a long-term chemical and
biological monitoring program of a still smaller subset of Phase II lakes.
Moreover, an ancillary objective of Phase I is to determine what data
must be collected to support other projects within NAPAP, particularly
within the Aquatic Effects Task Group.
There are substantial data available indicating that monomeric aluminum
is the major ichthyotoxic form of dissolved aluminum and that it
demonstrates a complex mode of action which includes impaired ion
exchange and mucous clogging of the gills. The occurrence and
bioavailability of this toxic form of aluminum is a function of pH, the load
of organic ligands, and the calcium concentration in the receiving water.
In the absence of complexing organic ligands, dissolved monomeric
aluminum levels can be expected to increase exponentially with
decreasing solution pH. In the presence of weak organic acids with pK's
near 4.5, dissolved aluminum will be complexed and precipitated,
producing an apparent solubility maxima near pH 5. By providing
statistically valid estimates of pH, monomeric aluminum and color (a
surrogate for organic carbon), the NSWS will provide data useful for
interpreting the complex interactions of these parameters and how their
effects on aquatic biota are mediated by regional hydrogeology and water
quality.
Measurements of monomeric aluminum in the NSWS population is critical
if the survey is to meet its objectives vis-a-vis Phase II, Phase III, and
NAPAP.
134. As indicated on p. 64, there will be detailed coordination between EPA
Base Coordinators and local land managers in planning sampling of
specific lakes. Under Alternative 3, three access modes would be
considered for each lake (helicopter, horseback, or foot). The revised
Summary and Conclusions Section of this Final EA includes a more
detailed discussion of criteria that would be used for Alternative 3.
135. Such wording is appropriate for Sect. 4 (Environmental Consequences)
rather than Sect. 3 (Affected Environment). Sect. 4.1.6 describes the
suggested mitigation for conducting the NSWS under Alternative 1. In
selecting lakes for sampling, wilderness areas were not considered
because the objective was to get a completely random sample that could
be used for extrapolating more detailed studies to an entire region. EPA
proposes to preserve the wilderness environment by measures discussed in
Sect. 4.1.6.
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136. EPA believes that such considerations are more appropriate in Sect. 4 of
the EA where safety is considered, rather than in Sect. 3, a description of
the affected environment. Implications of extreme weather are discussed
on pp. 66 and 73 of the EA.
137. See response to Comment #134.
138. The comment questions whether the data would be sufficient to
characterize an individual lake. Characterization of individual lakes is
not within the scope of the NSWS, Phase I, although some wildernesses
could be characterized to the extent that several lakes within a
wilderness are sampled; the number of lakes within a given wilderness was
a random result of the process of lake selection.
The statement "the concept of protecting the wilderness system must be
based on protecting each wilderness area," is an area of legal
interpretation that is cloudy (pp. 35-36. 50-52, and 68-69) and of
significance to the issue at hand. The Wilderness Act is ambiguous on the
point (p. 69) as is the FS Manual. In either case, the FS Chief has the
authority to permit helicopter use if it is felt such action is necessary for
the protection of the wilderness system (p. 36).
139. A quantitative estimate of the error cannot be made without first
collecting the data. On the basis of existing information, it is apparent
that the error would be large because many of the lakes most sensitive to
acidic desposition are located in wilderness areas. By not sampling the
lakes in these areas, one would be biasing the study towards less sensitive
lakes. Helicopter access is preferred because the highest quality data
can be obtained using established protocols (Appendix E.I). A complete
survey of location of sensitive lakes and in alkalinity classes in relation to
wilderness areas was outside the scope of this EA.
140. See revised Summary and Conclusions and Appendix E.
141. See Appendix G.
National Park Service (Letter #32)
142. Table S-l has been modified as suggested.
143. This statement has been added to the Affected Environment section of
the revised Summary and Conclusions.
144. A statement recognizing this concern has been added to the Summary and
Conclusions. Detailed planning between the EPA Base Coordinator and
local NPS staff, as described on p. 64 of the EA. will take this type of
concern into account before sampling occurs.
145. Close coordination will occur (see response to Comment #155 and pp. 61,
62, and 64 of the EA)
146. Sensitive areas will be considered during coordination (Sect. 4.1.6);
existing studies have been considered during design of the NSWS and will
continue to be used in later phases.
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147. NFS comments on the preliminary draft were not received in time to
incorporate major changes into the Draft EA.
148. The EA recognizes the sensitivity at Olympic National Park (p. 61). EPA
Base Coordinators will work closely with NPS staff at the Olympic
National Park to resolve this concern.
149. Alternatives 2 and 3 have been broadened to include foot access.
150. Because EPA anticipates deleting a few lakes from the sample for reasons
similar to those mentioned in the comment, there should be no problem in
deleting this one.
151. This change is noted in the errata sheet provided with the Final EA.
152. EPA Base Coordinators will work closely with local NPS staff at Mount
Rainier to resolve this concern.
153. EPA plans to work closely with local land managers (p. 64) in detailed
planning for sampling.
154. See response to Comment #144.
155. EPA Base Coordinators plan to work with local NPS staff to mitigate any
potential impacts on visitors (pp. 64-68 of the EA).
156. This comment suggests that if the effects of helicopter landings and
exhaust on the lakes were a problem, the helicopter could land near the
lake and the sampling crew could walk to the lake (and presumedly use an
inflatable boat to sample, similar to Alternative 2). As discussed in
responses to Comments #14, #53, and #186, effects of the helicopters on
the lakes are not expected to be significant.
157. See the Public Involvement Plan attached to this EA. EPA will work with
NPS staff in preparing materials and administering the plan.
158. EPA will provide the information as requested.
159. See response to Comment #144.
160. The analysis on p. 61 of the EA addresses this concern.
161. EPA Base Coordinators will work with local NPS staff to determine
whether any samples should be collected in this area, and depending on
the alternative selected, the mode of access.
162. See response to Comments #148 and #149.
163. EPA will re-evaluate this lake.
164. See response to Comment #155; adjusting schedules for sampling is one
such mitigation measure.
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165. Dropping a few lakes from the sample is anticipated by EPA; Base
Coordinators will work with local NFS staff at Yosemite to resolve this
concern.
166. The purpose of the Phase I survey is to provide a uniform data base for
the Nation so that data from specific studies such as the one mentioned
and from Phase II and HI can be statistically related to a regional context.
167. EPA used USGS maps to determine lake names, and in some cases
contacted local land managers for assistance in naming lakes. EPA Base
Coordinators will work with NFS staff to refine the identification of lakes
in Sequoia-Kings Canyon National Parks and elsewhere during the detailed
planning phase.
168. EPA notes this restriction.
169. Sect. 4.1.6 indicates that sampling on weekends will be avoided when
necessary to minimize impacts on backcountry users.
170. Once Phase I is completed to establish a statistical data base on the
distribution of sensitive lakes, Phase II and Phase III, incorporating the
types of studies described in the comment, will be undertaken (see p. 2 of
the EA).
171. Alternatives 2 and 3 include alternatives to using helicopters.
172. See response to Comment #149; EPA Base Coordinators will work with
Glacier Park personnel to resolve conflicts of using helicopters if
Alternatives 1 or 3 are selected.
173. See responses to Comments #155 and #172.
174. The number of lakes selected for sampling in Rocky Mountain National
Park is based on a random sample, and probably reflects the fact that
lakes in the three alkalinity classes being sampled primarily occur in high
mountain lakes. It is unlikely that another random selection would change
by much the number of lakes being sampled in the park.
175. Appendix A.2 lists the lakes in each National Park.
176. EPA Base Coordinators will work closely with local NPS land managers
(Sect. 4.1.6 of the EA).
177. See response to Comment #176.
178. EPA will use experienced pilots (pp. 65-66).
179. Such measures will be included as part of the training program and safety
program described in Sect. 4.1.6 of the EA.
180. If helicopters are used, EPA plans to land on the lake, not around it. EPA
Base Coordinators will work with Grand Teton National Park staff to
resolve this problem.
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181. EPA Management Team staff are familiar with the studies described and
will consider them in developing all three phases of the NSWS.
182. These comments are noted. EPA Base Coordinators will discuss them
with local NPS staff during detailed planning.
183. See response to Comment #144.
184. EPA appreciates NPS cooperation; Base Coordinators will contact NPS
staff during planning after the decision on access mode is made.
State of Wyoming, Game and Fish Department (Letter #33)
Comment acknowledged.
Wyoming Outfitters (Letter #34)
185. EPA regrets that you were unaware of this proposal. As discussed in Sect.
1.4 of the EA, EPA has made an extensive effort to involve the public and
government agencies in defining the scope of the EA, including press
releases that generated numerous stories in the press and on radio and
television.
186. Alternative 2, which has been broadened to include foot access, is
described in the EA as one alternative to obtaining the samples within
wilderness areas.
187. Public notice of the proposed project was made on December 20, 1985,
(see response to Comment #185) and numerous stories appeared in the
press and on radio and television thereafter. EPA plans to work with local
land managers to minimize conflicts with hunters and other wilderness
users (Sect. 4.1.6 of the EA).
188. Data quality is extremely important in this survey, and there is legitimate
concern that the survey objectives cannot be met with access modes other
than helicopter. Alternative 2, however, has been developed as a
reasonable alternative to be considered in making the decision on access
to wilderness areas.
State of California, Air Resources Board (Letter #35)
189. EPA believes that routine helicopter emissions will have minimal effects
on air quality in wilderness areas because of the short time the
helicopters will be present within wilderness. A supplementary analysis is
included with this Final EA to show the levels of emission from helicopter
engines similar to those that will be used in the survey. See response to
Comment #53 for discussion of potential effects of emissions on aquatic
resources.
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Montana Audubon Council (Letter #36)
Comment acknowledged.
Laurie Ellen Scheer (Letter #37)
Comment acknowledged.
Dennis Austin (Letter #38)
190. The EPA management team will consider the possible addition of these
lakes to the sampling program, but they would, of course, not be part of
the random sample.
State of Wyoming, Office of the Governor and State Engineer's Office (Letter #40)
191. The purpose of the Phase I survey is to provide a statistically valid data
basis that can be used to identify potentially sensitive lakes and for
extrapolating data from future, more detailed studies on trends in
acidification and the effects thereof. EPA agrees that the Phase I data
will not by themselves provide a measure of trends.
192. As noted in the response to the previous comment, more detailed studies
will be parts of Phases II and III (also, deposition monitoring is addressed
in other NAPAP research tasks). EPA does not foresee the(-GO-TO-GL-)
mechanized transport in wilderness areas for these later studies. In fact,
an advantage of having the Phase I data set is that detailed studies
involving repeated visits and installation of equipment can be focused on
regionally representative lakes outside wilderness areas. It will be
possible to relate the results of these studies to wilderness area lakes
because of the statistical data developed during Phase I.
193. EPA has no intention of doing deposition monitoring within wilderness
areas. Such monitoring might be more appropriate for the FS and NFS.
Deposition monitoring on a national basis is conducted as a part of
NAPAP.
194. The Phase I study addressed in the EA should be evaluated in the context
of the whole NSWS, the scope of which should be responsive to your
concerns.
State of Colorado, Division of Wildlife (Letter #41)
195. See response to Comment #10.
196. EPA will work closely with local land managers to minimize any impact
on big game hunters (p. 68 of the EA).
197. EPA is considering marking the helicopters as suggested.
198. The data generated during the NSWS will be made available to interested
parties.
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Environmental Defense Fund (Letter #42)
199. Alternative 3 provides a basis for detailed planning of several access
modes (foot, horse, and helicopter). No matter which of the alternatives
is selected, EPA Base Coordinators will work closely with the FS, the
NPS, and other land managers in planning the sampling program to
minimize impacts (Sect. 4.1.6 of the EA).
200. Under Alternative 3 of the EA, EPA would be able to work with the FS
and NPS to limit the use of helicopters to lakes where they are most
needed. Additional information developed by EPA in consultation with FS
and NPS staff (Appendix E) indicates that under Alternative 3, as many as
40% of the lakes would not be accessible by horse and would, therefore,
have to be accessed by helicopter or foot.
201. Under Alternative 3, EPA would have the option of limiting helicopter
access to those lakes which could not be sampled in a manner that would
significantly modify the established protocols. Data quality, however,
would be less certain than for Alternative 1. EPA has spent considerable
time in documenting the quality of data required in this study. The
methods chosen and the sampling design have undergone extensive peer
review (p. 15 of the EA).
202. As noted in response to Comment #200, EPA has developed additional
information that indicates as many as 40% of the lakes would not be
accessible by horse (Appendix E.4). If Alternative 3 were selected, EPA
Base Coordinators and local land managers would work closely together in
assessing the number of lakes that can be reached by horse or foot within
the 7 h time constraint, By combining different sampling techniques
cumulative sources of error are introduced and data quality is less certain.
203. Alternative 3 is being considered by EPA in the EA.
204. EPA concurs with EDF's comment and believes that the request to
conduct NSWS sampling in wilderness areas is a unique request which
should not set a precedent for future requests.
205. The short holding time protocols have been subject to scientific peer
review, which is referenced on p. 15 of the EA. Also, see Appendix E.I.
206. See responses to Comments #200 and #202.
207. Identification of specific lakes would occur during detailed planning
between EPA Base Coordinators and local land managers.
208. EPA would attempt to do this within the logistical and data quality
constraints discussed in the EA under Alternative 3.
209. The FS plans to issue a decision in early May.
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APPENDIX G
PUBLIC INVOLVEMENT PLAN
A scoping process was undertaken to involve affected government agencies and
the public in defining issues to be addressed in the EA. The scoping process has
consisted of three types of interactions. Initially, meetings were held between
headquarters staff of EPA, the FS, and the NPS to discuss the concerns of the land
management agencies and to define the type of analysis that would be needed.
Following a meeting in Washington B.C. on November 7, 1984, EPA decided to hold a
series of scoping sessions with FS staff in the five most affected FS Regions, to
describe the proposed survey and solicit regional FS concerns. Meetings were held in
Missoula, Montana; Ogden, Utah; Portland, Oregon; San Francisco, California; and
Lakewood, Colorado, between November 26 and December 7, 1984. In addition to FS
and EPA staff, representatives from the Department of the Interior and various state
agencies attended some of the meetings. On December 14, 1984, a request for public
comment was sent directly to interested organizations. On December 20th, a press
release was sent to the Associated Press and United Press International wire services
in each of the affected states. Since that time numerous stories have appeared in the
press and on the radio. These stories have generated a number of comments to EPA.
The draft EA was published on March 1, 1985, and comments from government
agencies and interested members of the public were solicited. Forty-two letters with
comments on the EA from state and federal government agencies, environmental
groups, and citizens were received. These comments have been reviewed and the EA
revised in response (Appendix F).
If a decision is made that allows access of wilderness area lakes by helicopter
(Alternatives 1 or 3), a communications plan will be developed to describe and
coordinate EPA's activities for release of information to the public on the western
lakes portion of the national acid rain survey. The objective here is to mitigate the
effect of EPA's sampling in the wilderness areas on those who depend on those areas
for solitude and moral restoration. This plan will provide a variety of information to
the public. The purpose of the survey as well as EPA's reasons for preferring to use
helicopters will be presented. In addition, the actual schedule of sampling will be
presented. This will allow people to see when EPA will be sampling in each of the
affected wilderness areas. If Alternative 2 (ground access only) is selected, a
somewhat reduced plan will be prepared because ground access would be of less
concern to wilderness users.
This part of the plan will include the following actions: presentations to
interested groups; notices of the action, posted at all wilderness entrances and
distributed to the public through the FS and NPS, and other government agencies, the
preparation of news releases, public service announcements, and videotapes for
newspapers, radio and television; and the preparation of articles for state game and
conservation magazines.
EPA's regional office in Seattle will have the lead responsibility for developing
and implementing this communications plan. However, the regional offices in San
Francisco and Denver will also play a role in soliciting public input and informing
interested parties in each phase of the plan.
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