Note: This paper was prepared as a resource for discussions between MDNR and several conservation organizations. It does not necessarily represent the position of any organization.
May 29, 2002 DRAFT
Notes on Missouri State Park Wild Area Management Issues
By David Bedan
Valuing and Protecting Wilderness Resources in Missouri’s State Parks
Beginning in the Nineteenth Century, most parks in the United States were established originally as places of recreation and tourism but many were also set aside to protect specific scenic wonders, geological curiosities or cultural resources. A growing appreciation of the values of wilderness influenced by Aldo Leopold and Robert Marshall led to the establishment of the Federal Wilderness System beginning in the 1920s and given force of law in 1964. As a result of the influence of thinkers such as Leopold and E. O. Wilson there has more recently been an increasing concern about the loss of biological diversity, and parks are now seen also as places where biodiversity can be restored.
In 1978 a system of Wild Areas was established in Missouri’s State Parks by the Missouri Department of Natural Resources (DNR) based on the same principles as the federal Wilderness System. These areas—eleven in number totaling 23,000 acres—range from the Gans Creek Wild Area in Rock Bridge Memorial State Park, which is surrounded by Columbia’s suburban sprawl, to Goggins Mountain Wild Area in the eastern Ozarks, which is surrounded by many more square miles of scenic forested public and private lands.
As is the case for most public lands, the Missouri State Park System is managed for multiple uses and to protect multiple resources. The managers of state parks must value and protect all of these resources:
In many cases these values are complementary. For example, wild areas often simultaneously serve recreational, biodiversity and cultural values. But it is often difficult or impossible to maximize protection of all these resources on a specific tract of land. For example, if there is an endemic endangered species the area might be managed primarily for biological diversity and others uses limited or prohibited. If there is a rare archeological resource the same philosophy would apply. Inherently, protection of the value of wildness often requires severe limitations on other management goals.
Wild areas were established to protect the values of both wildness and naturalness. Disagreements arise about the appropriateness of management options, management methods, and permitted recreational activities. Decisions about management options often become confused with decisions about management methods. Decisions about management options often involve the degree to which the park’s resources are manipulated. Decisions about management methods involve how management is implemented and what tools are used, especially motorized vs. non-motorized methods. In both cases decisions must be made about whether the option interferes with other resource protection goals. The key to facilitating management decisions is realizing that not all acres in a park can be maximized for all of the resources and values. Obviously, choices have to be made.
The eleven designated Wild Areas comprise 16.6 percent of the 138,000-acre Missouri State Park System. These areas were chosen because wildness was judged to be their highest and best use. Other areas, such as Prairie and Taum Sauk State Parks, were deliberately not placed in the Wild Areas system because they were deemed to have more value for another purpose such as management for restoration of biological diversity, which would entail more aggressive management. About 71,000 acres (51 percent) of the park system is being managed for biological diversity through stewardship and Natural Area management plans. In these areas biodiversity can be maximized without compromising other values.
Although about 63,000 acres (4 percent) of the 1.5 million-acre Mark Twain National Forest have been designated as wilderness, there have been no wilderness or wild areas designated on the large acreage of state lands—nearly a million acres—owned or managed by the Missouri Department of Conservation (MDC). Thus of the 1.1 million acres of natural resource lands managed by the state, only about 2% are wild areas. Restrictions on the management of wild areas are therefore affecting only a very small percent of the ecological restoration opportunities on public lands in Missouri. Similarly, wild area restrictions are impacting only a small part of the recreational opportunities on public lands in Missouri. In this context any deviation from wild area management policies should be extensively evaluated and justified and considered only when all other alternatives have been thoroughly explored. An explicit public decision-making process should be followed when considering such changes in policy.
Challenges for State Park Managers
In recent years conflicts have arisen regarding the management of the wilderness resources in relation to the other resources. In some cases state park managers have been tempted to disregard the wilderness resource in order to maximize one of the other resource values. To a large degree, this is due to a lack of institutionalization of the values inherent in the Wild Area concept. Policies, guidelines, and criteria are insufficient or too vague for to be useful for staff when making decisions about wild area management. And there has been no training in the values, policies, decision-making procedures and management of wild areas.
When the staff of the Park Division was faced with a conflict between an opportunity to restore open glade habitat in the Wild Area at Roaring River State Park and the ban on intrusive human activities, especially motorized, in the Wild Area they were hampered by this lack of institutionalization. To resolve this conflict they proposed to temporarily undesignate the Wild area while restoration activities were conducted using trucks and chainsaws. This would be followed by a redesignation of the Wild Area. But to advocates of wilderness, this would set a very poor precedent by which Wild Area designations could be made meaningless by a series of undesignations and redesignations implemented for a variety of management, policy and political reasons.
Conflicts have also arisen in some other parks regarding trail maintenance and construction in wild areas. At Cuivre River State Park, for example, the staff is considering a massive project to rebuild eroded equestrian trails by using trucks to haul in large amounts of gravel. It is not clear whether all other options such as trail closure or re-routing, limitation of visitor use or the use of volunteers for trail work have been adequately explored.
Park managers have also cited invasive exotic plants as a problem in many, if not all, Wild Areas. These invasive plants include Bush Honeysuckle, Autumn Olive, Russian Buckthorn, Garlic Mustard, Kudzu, Cerezia Lespedeza, and Oriental Bittersweet. While most advocates of wilderness would agree that such exotics are not consistent with wilderness, the methods used to remove them could also have a negative effect. Again, it is important to explore all options before resorting to intrusive methods on wild areas.
Wilderness Management Decisions on Public Lands
Similar dilemmas and conflicts regarding wilderness management are occurring on other state and federal public lands across the nation. Landres and others summed this up well in a paper published in 2000 "Naturalness and natural variability: definitions, concepts, and strategies for wilderness management":
"Deciding when to take action in wilderness areas . . . [is] the central dilemma in wilderness management. Proposals to manipulate ecological conditions in wilderness to restore naturalness bring this dilemma into sharper focus, raising significant and difficult questions:
To these questions can be added more complex questions regarding the goals of ecological restoration. If we decide to define a target for desired future ecological conditions in wilderness what is the desired target:
This issue is further complicated by confusion between decisions about management options and management tools. Deciding whether to restore a condition of biological diversity by removing cedars and setting controlled fires to restore glades is one thing. Deciding to use chains saws, ATVs and other vehicles as tools is another matter altogether.
Federal agencies such as the U.S. Forest Service and the National Park Service have been grappling with these same issues. In a document released in 2000, "A Wilderness Agenda: Thinking Like a Mountain," the Forest Service discusses the dilemma of wilderness management as related to ecosystem restoration:
Current Situation:
"When the Wilderness Act was passed, people generally assumed that natural conditions could be maintained without human intervention. Since then, however, it has become increasingly clear that human activities—many occurring outside Wilderness and beyond the control of Wilderness managers—have altered Wilderness conditions substantially. Fire frequencies have been reduced, exotic species have invaded, and water bodies have been acidified. In some cases it is possible to eliminate these threats at their source. In many cases, however, this is not possible and Wilderness managers must decide whether or not to attempt manipulative restoration of conditions. If the restoration is extensive or ongoing, however, Wilderness character can be adversely affected by the decision to either manipulate or not. Without restoration, naturalness will decline. With restoration, the untrammeled character (wildness) will decline. Restoration will enhance certain biological, scientific and social benefits; other biological, scientific and social benefits will be lost".
Strategies:
"Develop policy that addresses the issue of what to do with major changes to natural conditions; is ecosystem manipulation appropriate, if so where and when. Develop frameworks for making decisions about restoration and for developing and organizing information relevant to restoration".
Since Missouri’s Wild Area Program was modeled on the National Wilderness Preservation System, the Missouri DNR might well research the methods and programs used by federal agencies in managing wilderness areas. (See Appendix One: "Excerpts from 2001 National Park Service Management Policies")
Management Goals, Options, and Tools
The complexity of the park manager’s task can be seen when we examine the broad variety of management purposes, options and tools. The manager must balance the values of providing recreational opportunities, restoring biodiversity, protecting wildness, and protecting cultural resources. The manager’s task is further complicated by decisions about what are the appropriate recreational, educational, commercial, and ecological and cultural preservation activities in a given park.
The increasing popularity of recreation in Missouri’s state parks often leads to conflicts between users or damage to other resources or park purposes. Managers will need to deal with these conflicts in new and creative ways. Not all parks can accommodate all of these activities in spite of public demand for them:
To deal with conflicts among recreational interests and other park purposes, managers have a range of options. Some may be appropriate or inappropriate depending on the context. Obviously some would never be appropriate in wild areas. Some sample options:
Even when agreement can be reached on the management goals and options, conflicts may arise regarding the appropriate tools to implement the options. Lack of funding and staff often becomes a justification for using mechanical means such as chainsaws, ATVs, or other vehicles. This causes severe conflict with values of solitude and wildness that are part of the wilderness experience. In federal wilderness areas this dilemma is often solved by enlisting volunteer workers to maintain trails or do restoration work. In Missouri many volunteers have already performed such services in both natural areas and wild areas. Some of the following management tools may be appropriate or inappropriate depending on the context, while others may never be appropriate in wild areas:
Balancing conflicting resource values and deciding on appropriate recreational, educational, commercial and ecological or cultural preservation activities, together with appropriate management options and tools, is a complex task and should not be done in an ad hoc or casual manner. A process should be developed to make sure that all issues are considered in managing wild areas particularly when deviating from the basic policy of leaving wild areas wild, without obvious human manipulation. The concept of "minimum requirement analysis" is a promising tool for making sure that all issues are explored and any actions are fully justified. Such decisions should also be made with meaningful public participation. DNR has developed an excellent program for involving the public in decisions about planning for new parks. A similar public participation process should be developed for decisions to alter management plans for wild areas.
Finally, it seems imperative that there be a voice or voices within the agency whose responsibility it is to speak for and defend the resource of wildness when these issues are deliberated. The agency routinely provides a balance of voices in reviewing issues that affect other cultural, recreational, and scientific priorities, and does so successfully. There can and should be a voice for wildness in these deliberations, a voice apparently at present missing from the dialogue.
September 11, 2002
Recommendations for the Missouri Department of Natural Resources
Regarding State Park Wild Area Management Policy
In light of recent discussions about the Missouri Wild Area System, it seems reasonable to conclude that this DNR program is in need of review and revitalization. The upcoming 25th anniversary of the program in 2003 offers DNR a tremendous opportunity to implement just such a renewal of commitment to this very special set of resources. The following concepts are offered as a preliminary menu of actions that could lead to a revitalized program:
These comments and recommendations, based on discussions with a number of interested persons, are offered as a basis for further discussion and consideration of a Missouri Wild Area Management Policy.
Appendix One
Excerpts from:
2001 NPS Management Policies
Chapter 6: Wilderness Preservation and Management
The National Park Service will evaluate all lands it administers for their suitability for inclusion within the national wilderness preservation system. For those lands that possess wilderness characteristics, no action that would diminish their wilderness suitability will be taken until after Congress and the President have taken final action. The superintendent of each park containing wilderness will develop and maintain a wilderness management plan to guide the preservation, management, and use of the park’s wilderness area, and ensure that wilderness is unimpaired for future use and enjoyment as wilderness.
6.1 General Statement
The National Park Service will manage wilderness areas for the use and enjoyment of the American people in such a manner as will leave them unimpaired for future use and enjoyment as wilderness. Management will include the protection of these areas, the preservation of their wilderness character, and the gathering and dissemination of information regarding their use and enjoyment as wilderness. The public purpose of wilderness in the national parks includes the preservation of wilderness character and wilderness resources in an unimpaired condition, as well as for the purposes of recreational, scenic, scientific, education, conservation, and historical use.
6.3.5 Minimum Requirement
All management decisions affecting wilderness must be consistent with the minimum requirement concept. This concept is a documented process used to determine whether administrative activities affecting wilderness resources or the visitor experience are necessary, and how to minimize impacts. The minimum requirement concept will be applied as a two- step process that determines:
While park managers have flexibility in identifying the method used to determine minimum requirement within the approved wilderness management plan, the method used must clearly weigh the benefits and impacts of the proposal, document the decision- making process, and be supported by an appropriate environmental compliance document. Parks with no approved wilderness management plan must develop a separate process to determine minimum requirement until the plan is finally approved. Parks will complete a minimum requirement analysis on those administrative practices and equipment uses that have the potential to impact wilderness resources or values. The minimum requirement concept cannot be used to rationalize permanent roads or inappropriate or unlawful uses in wilderness.
Administrative use of motorized equipment or mechanical transport will be authorized only:
Such management activities will also be conducted in accordance with all applicable regulations, policies, and guidelines and, where practicable, will be scheduled to avoid creating adverse resource impacts or conflicts with visitor use.
From: 2001 NPS Management Policies: http://www.nps.gov/policy/mp/chapter6.htm
Appendix Two
Excerpts from:
Arthur Carhart National Wilderness Training Center,
Minimum Requirement Decision Guide
Introduction
More than 100 million acres of Federal land are managed as wilderness, a Congressional mandate that began with the passage of the Wilderness Act in 1964. In partnership with the public, wilderness managers have a responsibility to preserve and protect wilderness values.
Simply designating a wilderness does not assure its preservation. Careful management is needed to minimize the impacts from human activities in wilderness, including grazing, access to private lands, mining, management of fish and wildlife, fire and recreation. These activities have the potential to negatively impact the values that we are charged with protecting.
This guide is provided to assist managers in making appropriate decisions about their administrative actions in wilderness. The guidance comes from the Wilderness Act, agency policies, and the experience of 35 years of wilderness management. The wilderness resource is fragile and can be lost through the erosion from seemingly inconsequential decisions.
From Legislative Mandate to Agency Policy
A clear understanding and appreciation of the purposes and definitions contained in the 1964 Wilderness Act are necessary before considering appropriate management actions in wilderness.
The purpose of the Act is stated in Section 2 (a), "to secure for the American people of present and future generations the benefits of an enduring resource of wilderness."
Section 4 (c) of the Act prohibits certain activities in wilderness by the public and, at the same time, allows the agencies to engage in those activities in some situations. Section 4 (c) states:
"except as necessary to meet minimum requirements for the administration of the area
for the purpose of this Act (including measures required in emergencies involving the
health and safety of persons within the area), there shall be no temporary road, no use of
motor vehicles, motorized equipment or motorboats, no landing of aircraft, no other
form of mechanical transport, and no structure or installation within any such area."
In the above language, Congress acknowledged that even though certain activities are prohibited, there are times when exceptions to these prohibitions will need to be made for administration of the area. However, from the regulations, special orders, and internal agency policy contained in Appendix A of this guide, it is clear that the wilderness management agencies should not view the language in Section 4 (c) as blanket approval to conduct projects or allow activities without an analysis of (1) whether the project or activity is necessary to meet the minimum requirements for the administration of the area, and (2) which tool or method should be used to complete the project that results in the least impact to the physical resource or wilderness values.
Agency employees entrusted with management of wilderness should set the highest standard possible when reviewing management practices in wilderness. Wilderness is intended to be managed differently from other public lands and this difference needs to be demonstrated to the public.
A Word About Traditional/Primitive Tools and
Mechanical Transport
There isn’t an all encompassing definition of traditional or primitive tools, but generally defined they include a variety of non-motorized devices such as hand saws, axes, shovels, and certain tools that give a mechanical advantage such as wedges, block and tackles, and winches. The Wilderness Act prohibits the use of motorized equipment and mechanical transport, but not mechanized equipment. Technological advances have improved the efficiency and function of traditional tools over the years. These improvements don’t eliminate them from consideration as traditional tools. The defining characteristic of traditional or primitive tools is the reliance on human or animal power.
Mechanical transport includes travel within the wilderness by motorized vehicle of any kind. It also includes mechanical devices that provide transportation such as bicycles.
The use of traditional tools has been a cornerstone of wilderness management philosophy since 1964. As a result, certain skills that almost certainly would have vanished, have been kept alive. So few opportunities still exist to perpetuate these skills that are an important cultural tradition in our country. This is one of the benefits of wilderness.
How to Use This Guide
This guide has been developed to help provide consistency to the way project proposals in wilderness are evaluated and to ensure that we constantly strive to maintain or improve wilderness character through the decisions that are made. The information in this guide needs to be accompanied by a clear understanding of wilderness values and the ability to translate that understanding to a variety of complex and/or difficult projects in wilderness.
The guide is not a NEPA document, decision document or policy, but rather a series of self-explanatory worksheets designed to assist in thinking through and/or documenting your analysis. The worksheets include a two step minimum requirements analysis: first, to determine if the project or activity proposed is the minimum necessary for administration of the area for the purpose of the Act, and second, to determine which tool(s) will have the least impact to the wilderness resource. The worksheets lead the wilderness manager through a series of questions to provoke thought and understanding about the necessity of the proposed project and the most appropriate tools to use.
The minimum requirements analysis is provided to stretch our imaginations for the least impactive way of administering the wilderness. The wilderness manager may authorize any of the generally prohibited activities or uses listed in Sec. 4(c) of the Wilderness Act if they are determined to be the minimum necessary to do the job and meet wilderness management objectives.
When deciding what projects or activities to undertake and tools to use, follow these steps:
1. Complete a minimum requirement analysis, Step 1 of the worksheets, for all proposed projects or activities. This step should not be used to justify use of motorized equipment or mechanical transport, but rather, to scrutinize the project or activity and make the best decision for wilderness in the long term.
2. Complete a "minimum tool" analysis for the project. This analysis can follow the attached worksheet or, if not, should at least address the same points. If the analysis shows a justifiable need for motorized equipment, it is important to have this analysis in writing to provide to the official(s) who can authorize the use of mechanical transport or motorized equipment in wilderness. For some units, this analysis may become an integral part of an environmental analysis required to document a decision to use motorized equipment.
Ongoing management practices, especially if they involve mechanical transport, motorized equipment, or structures, should be reviewed to determine if they are still necessary or the best way to complete the task at hand.
How Does the Minimum Requirements Analysis Tie to NEPA?
The minimum requirement analysis is intended to assist you in making a decision and the worksheets will document your analysis. This process does not take the place of NEPA.
If a formal decision under NEPA will be required to implement your project, consider formatting your minimum tool analysis so that it can be incorporated directly into your environmental analysis. The minimum requirements analysis will tie to your statement of Purpose and Need for the project in your environmental analysis.
From The Arthur Carhart National Wilderness Training Center: http://www.wilderness.net/carhart
Appendix Three
Informational Resources on Wilderness Management
The challenges faced by the managers of Missouri State Parks regarding wild area management are also being faced by other public land managers. There is a growing body of literature on the subject. This is small sampling from the Aldo Leopold Wilderness Research Institute.
From http://www.wilderness.net/leopold/htopics/restor.htm, the Web site of the 
LEOPOLD INSTITUTE P.O. BOX 8089 MISSOULA, MT 59807 406-542-4190
THE WILDERNESS RESTORATION DILEMMA
Managing wilderness in the 21st century is complicated. Recently, a debate regarding ecological restoration in federally designated wilderness has intensified - how should we manage for "naturalness" or "wildness" or both? Leopold Institute investigators have weighed in on this issue in a number of topical journal articles as listed below.
SYNOPSIS
Cole, David, N. 2001. Management Dilemmas That Will Shape Wilderness in the 21st Century. Journal of Forestry 99(1): 4-8.
Landres, Peter; Brunson, Mark W.; Merigliano, Linda. 2001. Naturalness and Wildness: The Dilemma and Irony of Ecological Restoration in Wilderness. Wild Earth 10(4): 77-82.
Cole, David N. 2000. Paradox of the primeval: Ecological restoration in wilderness. Ecological Restoration 18(2): 77-86.
Cole, David N. 2000. Natural. Uncrowded or Free: Which of These Should Wilderness Be? International Journal of Wilderness 6(2): 5-8.
Landres, Peter B.; Brunson, Mark W.; Merigliano, Linda; Sydoriak, Charisse; Morton, Steve. 2000. Naturalness and Wildness: The Dilemma and Irony of Managing Wilderness. In: Cole, David N.; McCool, Stephen F.; Borrie, William T.; O'Loughlin, Jennifer, comps. 2000. Wilderness science in a time of change conference - Volume 5: Wilderness ecosystems, threats, and management; 2000 May 23-27; Missoula, MT. Proceedings RMRS-P-15-VOL-5. Ogden, UT: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. 377-381.
Sydoriak, Charisse A.; Allen, Craig D.; Jacobs, Brian F. 2000. Would Ecological Landscape Restoration Make the Bandelier Wilderness More or Less of a Wilderness?. In: Cole, David N.; McCool, Stephen F.; Borrie, William T.; O'Loughlin, Jennifer, comps. 2000. Wilderness science in a time of change conference - Volume 5: Wilderness ecosystems, threats, and management; 2000 May 23 - 27; Missoula, MT. Proceedings RMRS-P-15-VOL-5. Ogden, UT: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. 2000.
Cole, David N. 1996. Ecological manipulation in wilderness--an emerging management dilemma. International Journal of Wilderness 2(1): 15-19.
Landres, P.B., P.S. White, G. Aplet, and A. Zimmermann. 1998.
Naturalness and natural variability: definitions, concepts, and
strategies for wilderness management. Pages 41-50 in Wilder-ness
& natural areas in eastern North America: research, management
and planning (D.L. Kulhavy, M.H. Legg, editors). Center
for Applied Studies, College of Forestry, Stephen F. Austin
University, Nacoghoches, TX.