5. Permit Acquisition

As currently outlined, the Proposal requires all permit seekers to obtain their wilderness permits via the recreation.gov website. There are numerous problems with this approach. First and foremost, it presumes that all users will have access to the internet. That may not be the case for low-income residents or Oregon visitors, and it is known that there is no internet access at a majority of the trailheads in these wilderness areas. Considering that, it’s entirely possible that many users interested in securing a permit for their trailhead of choice will not be able to. Then when a permit is secured, the system requires a physical printout of the permit (and accompanying parking pass) to be obtained. This only presents another barrier for those who may not own a home printer, or those who may be traveling and not have access to a printer. These are conflicting requirements, first requiring permit seekers to be internet savvy, then directing them to an outmoded process—not to mention resource-dependent and waste-producing. Forest Service staff have indicated that permits may be obtained and/or printed from local Forest offices, but only during their limited hours/days of operation.

Recommendation: If the Forest Service is going to make users compete for wilderness access and pay multiple fees to do it, it would only be appropriate for the process to be as simplified as possible, especially in today’s increasingly mobile-friendly and environmentally-conscious society. Users should be able to download their permit and carry it on their mobile device to contribute to less resource dependence and waste. Users should also be able to enter their auto information as part of their permit application for parking at the trailhead and avoid the need to print even more paper. [3] In addition, if the Forest Service expects users to adhere to these new permit requirements, it should modify its office operating hours to be open during the most popular usage times—weekends and holidays—and make sure staff are available to accommodate visitors’ permit needs.

6. Quota Concerns

Following a conversation with Forest Service staff, it was shocking to discover that the daily trailhead quotas as outlined in the CCWSP Final Decision were not as they appeared—and were, in fact, significantly more restrictive than presented to the public. This seems to be rooted in mixed references regarding two Appendix Cs—one in the Final EA and one in the Final Decision. While the Final EA indicates quotas that take into consideration both trailheads and users in the area [4], no such language or reference to that effect was carried over into the Final Decision. When Forest Service staff were asked why such a significant factor relating to “daily” permit quotas, as suggested by the Final Decision, was not included, the response was “a simple oversight.”

This is more than an oversight. This presents a potentially impossible and punishingly restrictive situation with regards to PCT section-hikers, and effectively reduces the number of wilderness entries from a daily basis to a weekly basis. For example, according to the Final EA, if three section-hiking groups obtain permits to enter the wilderness area via Irish-Taylor Lakes [5] on any Friday, and each get 8-day permits to cross all three wilderness areas, there would be no further permits issued for the following 7 days, until it was presumed these parties exited the wilderness areas. In essence, this would only allow three groups of users exclusive access to 110 miles of the PCT for an entire week. Since most section-hikers travel solo or in pairs, this would mean limiting entry to as few as three users over an area of 110 miles for an entire week.

This is simply unacceptable—and unjustified. There is no basis for this kind of restrictive approach—especially one so targeted at a single type of wilderness user, especially considering the aforementioned long-distance permit holders who are granted at-will access. When these discrepancies and concerns were raised with Forest Service staff, the response was simply, “That is something we will monitor and may address with ‘Adaptive Management’ (Final Decision, Appendix C).” We have raised this concern with the Pacific Crest Trail Association and they were equally taken aback by this blatant omission. At the recent Proposal open house sessions when this issue came up, attendees were—naturally—outraged by this lapse in full transparency. It questions the legitimacy of the entire Final Decision in that it is apparently not genuine in its presentation of accurately informing the public what the “daily” quota system actually entails.

Recommendation: We strongly urge the Forest Service to reconsider their approach to the daily quota allowance. By implementing trailhead quotas in conjunction with area quotas, it will exponentially reduce the public’s ability to acquire these new permits and access their public lands— much more so than the established restrictive quotas, which were believed to be “daily” entries. As these quotas affect overnight users and PCT section-hikers, we suggest that the Forest Service identify ONE quota method, either: 1) Daily limited entries at affected trailheads; OR, 2) Daily limited access to specific destinations. Specifically with regards to the two PCT entry points (Irish–Taylor Lakes and Breitenbush Lake), we feel that these permits should be issued on a per-person basis instead of by group (i.e., change 3 groups to 36 individuals). [6] This would ensure that more section-hikers would gain access to cross these wilderness areas.