Brief Amicus Curiae Of Montana Wilderness Association In Support ...

13
Service Special Use permit, abandoned his back country skiguiding
business in the Ten Lakes WSA in part because the
wilderness character his clients valued was compromised by
excessive snowmobile use. Id.
In addition to scarring the land, ORVs adversely affect
wilderness character and potential in other ways. By
carrying seeds in their tire treads, all-terrain vehicles spread
noxious weeds to remote areas. Noxious weeds, in turn,
eradicate native vegetation that serves as forage for big game
animals. Noxious weeds have infested hundreds of
thousands of acres of Montana’s backcountry, in part
because of growing use of all-terrain vehicles.
Increased ORV use also contributes to the decline of
important animal populations. Snowmobile use causes
caused grizzly bears and wolverines to abandon their dens.
ER 051-052 (Dr. Sara Jane Johnson Decl., citing Forest
Service studies). All-terrain vehicles and snowmobiles
displace elk, forcing them to seek other habitat. ER 050 (Dr.
Sara Jane Johnson Decl.). Snowmobile-compacted trails
harm lynx, an endangered species, by giving the lynx’s
competitors a means to traverse deep snow.
www.fs.fed.us/r1/planning/lynx/reports/DEIS/Summary1.pdf
see also 65 Fed. Reg. 16081 (Mar. 4, 2000) (rule listing lynx
as endangered). Although Congress extolled the outstanding
wildlife resources and undisturbed habitat found in the
WSAs in 1977, and although the Forest Service’s own
scientists have shown that ORV use may adversely affect
wildlife, the Forest Service never has measured how or to
what extent burgeoning ORV use affects wildlife in
Montana’s WSAs.
Despite the undeniable link between increased ORV use
and the degradation of wilderness values, the Forest Service
has done little to maintain the wilderness character and
potential of the WSAs. With the limited exception of an area
closure order for the Hyalite WSA, issued after suit was