Applying The Recreation Opportunity Spectrum (ROS)
To The Wilderness Debate

Recommendations For Counties and Access Protection Advocates
From the Western Counties Alliance

www.westerncountiesalliance.com

Summary

The application of criteria set out in the Recreational Opportunity Spectrum to proposed wilderness areas substantially reduces the amount of acreage that qualifies. In many cases, the entire proposed area is disqualified.

Background

The Recreation Opportunity Spectrum (ROS) is a set of criteria developed by academic researchers that is used to evaluate the recreational opportunities offered by any particular piece of land. The opportunities range from primitive on one end of the spectrum to developed on the other. The ROS is widely used by recreation specialists in the Forest Service and the Bureau of Land Management, among other agencies.

Wilderness recreation opportunities are at the extreme primitive end of the spectrum and are only available when the set of criteria required for this type of recreation experience are present. One of the most significant of these criteria is the general rule that to have a wilderness recreation experience, an individual must be at least 3 miles from the nearest road or trail where motorized vehicles are in use. The reason for this guideline is that a wilderness recreationist must feel that they are truly away from the constraints and safety of modern civilization.

This focus on recreation opportunities is essential because wilderness designation is almost exclusively a recreation management scheme not a resources protection scheme. The Wilderness Act is clear in this regard. The BLM has distilled the requirements of the Act down to three primary criteria. One, that an area must be at least 5,000 contiguous acres of public land. Another is that the “imprint of man’s work must be substantially unnoticeable.” The BLM in particular has interpreted this criterion such that the area does not necessarily have to actually be in a natural state, but must merely appear to be so.

The third primary requirement an area must meet is two-part. Only one of the two must be met. An area must either offer “outstanding opportunities for solitude” or for a “primitive and unconfined type of recreation.” No matter how natural an area might be (or, more accurately, appear to be) unless it meets one of these two criteria, it does not qualify for wilderness designation.

Both of these primary criteria are human-experience and recreation oriented. The definition of “substantially unnoticeable” for the imprint of man is a subjective one. The second, two-part criterion is even more clearly recreation-oriented. A simple definition of “solitude” is the state of being completely alone, something which can only be measured in terms of human perception and experience. The recreation orientation of the “primitive and unconfined type of recreation” is clear.

Applying the ROS to the wilderness debate

The simple fact that wilderness designation truly and legally is almost exclusively a recreation management exercise an essential reason to keep any discussion of possible wilderness designation focused clearly on recreation but it is only one. At least as important is correcting whenever possible the popular perception, perpetuated by most of the media and by wilderness advocates both outside and inside government, that wilderness is primarily a land and resource protection designation. In fact, as with any land management scheme, resource protection trade offs are inevitable. Some resource values may be enhanced by wilderness designation but others will be harmed.

The ROS has largely been ignored by all parties in the wilderness debate, yet when applied “on the ground” it dramatically changes that debate, as a couple of simple calculations demonstrate.

It is not uncommon for the boundaries of Wilderness Study Areas (WSAs) to come virtually to the berm of a road that serves as a boundary. In areas demand for designation by wilderness advocates, this technique is even more common. Applying the 3 mile set back general requirement of the ROS criteria dramatically impacts the acreage which may in fact be eligible for wilderness designation. For a straight length of boundary road, this ROS criterion reduces the eligible acreage by the area of 3 sections of land, or 1920 acres, per mile.

The impact of applying the ROS set back to so called “cherrystemmed roads” is even more dramatic. Anyone looking honestly at the Wilderness Act must conclude that cherrystemming roads is a clear violation of the intent of Congress. Now, the ROS 3-mile criterion provides specific research support for that common sense conclusion. Because by definition these roads penetrate areas that are claimed to be potential wilderness, the 3 mile setback applies to both sides of the road as well as to its terminus. The means 6 sections on either side, or about 3,800 acres per straight road mile are disqualified and an additional approximately 9,000 acres at the terminus. For a straight one mile cherrystemmed road, just under 13,000 acres of land are disqualified, for a 2 mile road just under 17,000 acres, and so on.

Because of the 5,000 acres of federal land minimum size requirement the actual impact on the acreage of land that would qualify for potential wilderness designation can be magnified even more than the acreage compromised by the 3 mile buffer zone. This impact will vary depending on such factors as the shape of the area, the number and location of roads and the presence of non federal lands such as private property or state school trust sections. The application of the ROS set back criterion combined with these other factors frequently creates isolated patches of land of less that than 5,000 acres in size. In other cases the remaining acreage which might qualify is contained in parcels that are so long and narrow or are otherwise configured as to be unmanageable as wilderness.

In applying the ROS it is always important to remember that the 3 mile setback is merely a general guideline. Due to topography or other factors present on a particular piece of land, a smaller setback may be acceptable. In other cases, however, the setback may need to be further. This is especially true in relatively flat areas at lower elevations with gentle topography and little screening vegetation. One of the reasons why the ROS criteria are particularly important in discussions of proposed wilderness for BLM-managed lands is that these conditions characterize much of the land administered by that agency. These same conditions have resulted in more roads on BLM land than on the higher elevation lands usually administered by the Forest Service.

In all cases, however, the burden of proof that a less than 3 mile buffer is appropriate must rest with those making such a claim. Equally, those who claim that a wider buffer is necessary must justify that position.

When all these factors are applied to a particular parcel of land it is common for it to be completely disqualify as wilderness. This is particularly the case for areas proposed on BLM-managed land and is especially true for areas that are “found” to qualify in the so-called citizen inventories.

This is why it is easy to understand why wilderness advocates ignore the ROS criteria in their “citizen inventories.” Since their primary goal is to simply lock as much public land as possible away from multiple use management, they routinely ignore the intent of the Wilderness Act, regulations and numerous on-the-ground realities in pursuit of that objective. Forcing them to apply the ROS set back criteria on every possible occasion will go a long way to keeping them more honest in the wilderness debate.

It is also easy to understand why wilderness advocates inside the federal agencies ignore the ROS criteria whenever it is convenient. As public employees, however, their actions are clear indefensible. To be sure, it must be recognized that in the case of the BLM and some of the Forest Service proposed wilderness areas, the ROS had not been developed and so could not have been applied. There is no justification, however, for ignoring the ROS in more recent work, particularly the “re-inventories” conducted by the BLM in Utah and Colorado. In these and others instances, agency personnel found hundreds of thousands of acres within the 3 mile setback zones which they claim had “wilderness characteristics” without explaining why the ROS criteria should not apply.

Since Congress is the ultimate determiner of what qualifies as wilderness, it is also essential that the ROS criteria be part of any future debate.

Recommendations for counties and access protection activists:

Counties with Geographic Information System (GIS) capabilities should apply the ROS setback criteria to their roads to determine the impact on any proposed wilderness areas in their counties, including BLM WSAs. This is a relatively simple thing to program. Because the ROS 3 mile set back is only a guideline, it is recommended that maps with a 1.5 mile buffer also be generated. Examples of such maps generated on a county wide basis for 2 Utah counties can be found in Appendix D .

Even applying this narrower 1.5 mile buffer zone has a significant impact on the ground especially where there are extensive cherrystemmed roads. In Utah, for example, wilderness advocates claim to have found more than 9 million acres of land that meets wilderness criteria compared to 3.2 million acres of official WSAs, expanded to about 5 million acres when BLM “re-inventoried lands” are included. They also admit, however, that more than 80% of their acreage lies within two miles or less of a road.

Counties without GIS capability should ask the federal agency or a state government entity such as the school trust land administration agency to generate these maps. They could also ask their congressional delegation to ask the federal agencies to generate these maps.

For activists or counties that cannot easily obtain computer-generated maps, a rough estimation of the impact can be done completely by hand. By using a compass to swing three-mile arcs into proposed wilderness areas from appropriate places on nearby roads or cherrystems, the impact on these areas can be roughly approximated. If this is done on maps showing section lines marked, a rough estimation of the acreage impact can also be made.

When good maps are obtained by whatever means, they should be widely circulated to the public, elected officials and the media. The counties could ask the federal agencies, wilderness advocates and opponents and the general public to suggest areas where the setback could be less than the 3 mile guideline or where topography and lack of screening would require a greater set back. All recommendations to deviate from the 3 mile buffer width should be justified by those making the recommendations.

The impact of these buffer areas on proposed wilderness should be central to any discussion of wilderness suitability with the media, state and federal agencies, use groups and particularly wilderness advocates.

Wilderness advocates conducting so-called “citizen inventories” of public land as part of their campaign to justify their demands for larger wilderness designations should immediately be challenged to incorporate the ROS guidelines into their inventory procedures.

For more information, e-mail, mailto:allies@westerncounties.org