QLG Appeal of the SNFPA Decision page 49


The FEIS analysis of current and future public demands for outdoor recreational uses is not adequately documented or easy to follow in the FEIS. Many of the sources cited do not appear in the references sections of the FEIS, and some of the sources cited and referenced do not seem to be particularly applicable to the Sierra Nevada. Some of the information presented as hard data conflicts with other information presented as hard data.

In attempting to evaluate the effect of the Decision on recreational opportunities, we start with land allocations. Table 5.6.a [FEIS Vol2, Ch3, pg 454] shows that 31.4 percent of the per-decision land allocations were available for Primitive and Semi-primitive/Non-motorized recreation uses, while the other 68.6 percent were available for Semi-primitive/Motorized, Roaded natural, Rural, Urban, and Undesignated uses. (Unless otherwise noted, references to the FEIS in the rest of this section are by page number, all of them referring to Vol 2, Chapter 3.)

Table 5.6.c. [pg 456] reports three years of Individual Visitor Days (IVDs) from the mid-1990's, categorized by use. "Dispersed recreation" accounted for 7.9 percent of visitor days, and if you add all of "hunting" and "fishing" to the dispersed category the total is still only 16 percent of total visitor days.

Among the assumptions listed on page 477 are "Limitations will be placed on recreation activities..." and "The potential for seasonal restrictions or permanent closure of some roads and recreational sites... [is] dependent on further studies." These statements reveal the obvious, that one effect of the Decision is to shift the allocation of recreational opportunities away from "general use" and make it available only for Primitive and Semi-primitive Non-motorized use.

There is an obvious attempt to justify and sugar-coat this shift of recreational opportunity by statements such as "The fastest growing recreational activities (Table 5.6.p.) are, for the most part, low impact and nature-oriented activities" [pg 417] and "Californians have clear preferences for natural, undeveloped, and nature-oriented areas and parks" [pg 473]. Since all recreation activities in national forests would be characterized by most people as "low impact," "nature oriented," and (for most of them) "undeveloped,"it seems likely that the quoted statements are either misleading or beside the point. Similarly for Table 5.6.q. [pg 472] where all the listed activities (except possibly big game hunting) would be classed by most people as "low impact" and perhaps all except auto travel as "nature-oriented."

The two sentences quoted above that claim a growing preference for undeveloped recreation are directly contradicted by Table 5.6.r. and the accompanying discussion on page 474. The fastest growing uses are said to include downhill skiing, visiting historic places, sight-seeing and biking, none of which is a "primitive" or "undeveloped" use, whereas the slowest growing uses include rafting, backpacking, and primitive camping.

But what are the current recreational demands and their projected changes? The FEIS provides only "indices" of change for some, but not all, categories of usage. Table 5.6.r. [pg 474] lists such indices for the Pacific Coast Region (including Washington and Oregon, not just California), said to show the "change in participants from 1995 to 2050." This brings up the first problem for a reader trying to make sense out of the FEIS recreation section. Does the term "participant" in the title of table 5.6.r. mean the same thing as the standard term "Recreational Visitor Day" (RVD)?


QLG Appeal of the SNFPA Decision page 50

On the assumption that both terms mean the same thing, we then tried to apply the indices to the reported RVDs for 1995, then compute the 2050 results and some probable outcomes in the intermediate years. After finding the 1995 RVDs in the Draft EIS [Table S-47, DEIS Appendix S], we wanted to apply the indices and compare the outcomes to the FEIS projections. There are two problems: (1) The FEIS current totals and projections are stated in terms of "Individual Visitor Day"(IVD, a term not normally used outside this FEIS), not the standard term RVD; and (2) The FEIS reports the projected numbers only for the decade 2001 to 2010 [Tables 5.6.gg. and 5.6.hh., page 497], not for the year 2050.

This is obviously going to get too complicated for mere words, so we have attempted to work our way through the maze of obfuscating mumbo-jumbo in a spreadsheet on the following page, "Attempt to Reconcile Recreational Use Projections in the FEIS." That's where we found our final problem: The Forest Service changed the categories of recreation usage from one table to another. That is, you can't find 1995 numbers in Table S.47 or Table 5.6.c. that match the same categories for which table 5.6.r. gives indices. We had to match up the categories and sub-categories as well as we could. The "Recreation Categories and associated activities" labels aligned with the left edge of the spreadsheet are the main categories from Table S.47 the 1995: Camping, Travel, Dispersed Recreation, etc, with sub-categories (Camping, Picnicking, Swimming, etc) from Table 5.6.c.

The numbers go like this. First, the FEIS says that one IVD equals 2.24 RVDs (though it doesn't explain why it was necessary to change terminology between the DEIS and the FEIS). The numbers check pretty well, since 2.24 times the table S.47 RVD numbers comes pretty close to the IVD totals reported in FEIS Table 5.6.c. In the spreadsheet the first column of numbers shows the 1995 RVD totals from Table S.47, and the second column is simply the RVDs converted to IVDs.

In the third column we listed the "stated index" for each of the categories in Table 5.6.r., assigning them as well as we could to the categories in Table 5.6.c. Then we estimated an index for each major category, using a weighted average of the sub-category indices (where they existed), or estimating a category index from the leftover sub-categories that seemed closest to the mark, and assigned the result as the "estimated index" for the major category.

Then we simply multiplied the category index by the 1995 category total to obtain the estimated IVDs for 2050, listed in the right hand column.

The totals near the bottom of the spreadsheet show the 1995 total as 37.8 million RVDs, which are equivalent to 84.8 million IVDs. In order for 84.8 million IVDs in 1995 to grow to 148.4 million IVDs by 2050, the index (growth factor) would have to be 1.75.

The final task was to compute the decade rate of increase that could be compounded for 5-1/2 decades to give the 1.75 index. That turns out to be a growth factor of 1.107 per decade, i.e. almost one percent per year if compounded yearly.

On those assumptions, there would be 93.8 million IVDs in 2005.


QLG Appeal of the SNFPA Decision Page 51 

Attempt to Reconcile Recreational Use Projections in the FEIS

Recreation Category and Associated Activities Reported RVDs 1995 (x1000) IVDs
(RVDs x 2.24) 1995 (x1000)
Stated Index of Change 1995-2050 Estimated Index
of Change 1995-2050
2050 (x1000)
CAMPING 9993 22,384   1.70 38,053
Camping     1.73    
Picnickng     1.63    
Swimming     1.72    
TRAVEL 12,860 28,806   1.85 53,292
Bicycle     1.65    
Motorized boat     1.88    
Snow vehicles     3.60    
DISPERSED RECREATION 2,803 6,279   1.85 11,616
Hiking     1.85    
Horseback riding     1.77    
Mountain climbing          
Non-motorized boating     1.97    
WINTER SPORTS 3,580 8,019   1.85 11,616
Cross-country skiing     1.90    
Downhill  skiing     2.11    
Snow shoeing          
Ice skating          
RESORTS 4,168 9,336   1.70 15,872
Group Camps          
Lodging Resorts          
Recreation Residences          
HUNTING 727 1.628 0.64 0.64 1,042
FISHING 2,187 4,899 1.38 1.38 6,760
INTERPRETIVE SITES 1,529 3,425 1.68 1.68 5,754


Non-consumptive wildlife     1.77    
Off-road driving     1.33    
Family gathering     1.65    
Sightseeing     1.87    
Walking     1.73    
Primitive camping     1.44    
Backpacking     1.46    


37,847 84,777   1.75 149,428
QLG Appeal of the SNFPA Decision page 52

Does the computed 2005 IVD total equal the FEIS reported 2005 total?

Compute 2005 total






FEIS 2005 Totals






Alt 1






Alt 8-mod






Unfortunately our computed total does not agree with the FEIS reported total in Tables 5.6.gg and 5.6.hh [page 497]. The reported total is 110.1 million IVDs, about 17 percent more than the computed total.

Seventeen percent seems like an extraordinary discrepancy to show up in the first decade of a 55 year projection, but one has to remember (if it's any comfort) that all these mathematical conjectures are based on some very flimsy data to begin with.

There are other discrepancies between the tables and the text. For example, the 1996 total of IVDs for "Resorts" (including group camps, lodging resorts, and recreational residences) is 4.145 million IVDs, while page 470 says that "Recreation resident use accounted for 6.9 million visitors in 1996." How is it possible to reconcile those two very simple and supposedly factual statements? Did all those 6.9 million visitors stay only a fraction of the 12-hour period that counts as a "visitor day"?

Finally, nothing in the Recreation section indicates a methodology or its application that would actually determine the "supply" of recreational opportunities that are feasible or are being made available by any of the Alternatives or the Preferred Alternative. Historic "demands" (i.e. the numbers and distributions of RVDs and IVDs) are multiplied by some growth factors (determined entirely from historic trends, assuming they have any validity at all), and then these demand projections are treated as if they were the available "supply" at some future date, without any showing of how that equivalency is established or justified. Then some (but not all) of the categories are adjusted from alternative to alternative, so that, for example, Alt 8-mod show 84 percent of the "no change" values for Alternative 1 in the categories of Developed Recreation and Trail Use, 90 percent of Mechanized Travel and Total use, with no change in some other categories.

Is there anything at all to support these calculations or the assumptions behind them? Is it the assumption that if some trails are closed potential hikers will not show up at all instead of using the remaining trails at some slightly increased frequency?

The FEIS says that "Management for conservation of biological diversity and restoration of key ecosystem components in the Sierra Nevada have comparatively little relative effect on the recreation..." [page 498]. Well, if that is so, why would there be a 16 percent drop in developed recreation and trail use under Alt 8-mod? Or is a 16 percent drop not significant?

NEPA requires EISs to be "...concise, clear, and to the point..." [Sec 1500.2(b)], and that "Agencies shall insure the professional integrity, including scientific integrity, of the discussions and analyses..." [Sec 1500.24]. Without doubt the recreation section of the FEIS lacks clarity in failing to give proper references for many of the sources cited and quoted, in the numerical analyses, and in the obscurity of the methods used to assign effects to alternatives. By questioning professional and scientific "integrity," we don't mean to impugn anybody's good faith, we mean the word in its classic sense -- the coherence of the section literally dis-integrates when, on close examination, its internal inconsistencies and its lack of scientific rigor become apparent.