SLCA’s Comments to Proposed Changes to Recreation Fees

Proposed Changes to Recreation Fees, Uinta-Wasatch-Cache National Forest Federal Land Recreation Enhancement Act (REA) Developed Recreation Fee Proposal September 1, 20202

RE: Proposed Changes to Recreation Fees, Uinta-Wasatch-Cache National Forest Federal Land Recreation Enhancement Act (REA) Developed Recreation Fee Proposal from July 7, 2022

SLCA recognizes the need for additional funding to address decades of UWC Forest infrastructure and maintenance backlog. We appreciate that the REA is a tool that the USFS can use to generate funding to address this backlog and mitigate impacts to natural resources for continued public use. We will continue to be an organization that partners with the USFS to steward climbing areas in an effort to limit recreation impacts to the natural resource.

We have concerns with the Proposal as written that we believe should be addressed before the UWC National Forest moves forward with implementation of the proposed fees. The following concerns are further detailed in our comments:

  1. The UWC National Forest’s Proposal does not sufficiently explain how sites were selected for fee adjustments/new fee implementation; without such explanation, we cannot know whether adequate assessment or analysis informs these decisions.

  2. The UWC National Forest’s Proposal does not sufficiently explain how the proposed fee structure was determined, nor the impact of the proposed fees for resource access; without such explanation, we cannot know whether adequate assessment or analysis informs these decisions. 

  3. The UWC National Forest’s Proposal does not sufficiently explain whether there was consideration given to how this proposal would interact with or overlap the ongoing Utah Department of Transportation (UDOT) Little Cottonwood Canyon Environmental Impact Statement (EIS) process, raising concerns of users bearing the burden of compounded access barriers, including combined fees and tolling.

  4. The UWC National Forest’s Proposal is based on a Forest Service management plan that is alarmingly out of date (the most current is the “2003 Land and Resource Management Plan”), fails to incorporate available (and soon to be available) visitor use and impact data, and and fails to provide sufficient specific data regarding the climbing community whom we represent. 

  5. The UWC National Forest’s Proposal fails to recognize the USFS national climbing area management best practices and guidance to inform how climbing resources and associated infrastructure will be funded, managed, and maintained on the UWC where fees are being proposed. 

The observations above create overarching concerns that the application of the proposed fees could result in unnecessary and unwanted infrastructure and subsequent maintenance for some Forest sites. Before additional infrastructure is added, especially restrooms, the facilities we have need to be maintained and cared for. The restrooms in LCC and BCC have been problematic for years to maintain and clean.

Last, the SLCA has concerns that the proposed fees could exacerbate inequities in natural and recreational access to marginalized communities throughout the UWC National Forest.

Julia Geisler