Trout Creek drainage is evaluated as prime wolverine habitat. It is wooded, maintains a viable community of rodents which, with carrion, make up the bulk of the wolverine diet, and it is little-used by man. The wolverine is one predator that plays an important role in the ecology of our wilderness, and one we could well afford to encourage because his habits are complementary, rather than adverse, to man's interests. True, the wolverine was once the scourge of trappers, but that era has passed. Today he is needed to help control rodent populations, including the porcupine, which with the loss of other major predators such as the wolf and grizzly bear needlessly destroy grasses and trees.

The fact that the Trout Creek drainage within the proposed Wilderness, although virtually pure wilderness, has little except solitude to offer man as a visitor is an important asset. Areas such as this, where man will seldom visit, are needed for the benefit of certain wilderness creatures such as the wolverine. The non-use of this area by human visitors also contributes to the continued safeguarding of the municipal water supply.

The oil and gas leases mentioned in both the Mandall Creek basin and the Stillwater Reservoir area, as those in Unit N, pose little threat to wilderness management.

The planned campgrounds for vehicle recreationists are seen as a definite threat. The Forest Service emphasizes that Bear River from Stillwater Reservoir downstream is already fully developed. Overlooked is the fact that approximately six miles from Stillwater Reservoir there is a road network on the National Forest in the vicinity of Gardner Park and Harper Reservoir where more vehicle camping facilities could be provided. There is no valid reason to replace the wilderness use of the Mandall Creek basin and the slopes above Stillwater Reservoir with mass recreation sites. Vehicle recreationists could camp a few miles from Stillwater Reservoir and drive to the reservoir where ample space for parking has been provided by the citizen wilderness boundary being withdrawn 1,320 feet from the existing road and reservoir waterline.

The 20, or more, small lakes and beaver ponds scattered throughout the approximately six-square-mile Mandall Creek basin would be overwhelmed by vehicle recreationists with ready access. The very reason for their attractiveness is the existing degree of remoteness from roads. Development would destroy rather than enhance this attraction.

Most of the reclamation withdrawal, and all of Stillwater reservoir and dam are excluded from the citizen proposal. The land withdrawal is unimportant, anyway, because it does not affect the designation of Wilderness.

Whereas a main reason for including Mandall basin in the Wilderness is to guard the wilderness qualities from the onslaught of vehicle recreationists, a main reason for including the undeveloped environs of Stillwater Reservoir is to safeguard a beautiful scene for vehicle-oriented visitors. Around the reservoir, the difference between the citizen and Forest Service boundary is only about one mile. These slopes below the main Flat Tops escarpment containing a half dozen small lakes form a striking backdrop to the reservoir, and the area provides space for a delightful wilderness walk circling the reservoir as well as the initial mile or two of more strenuous trails leading into other units of the Wilderness.

Within Unit O, it is estimated that to the average citizen-conservationist most concern would be given to the protection of the Trout and Mandall Creek drainages.

UNIT P, DERBY CREEK HEADQUARTERS

The boundary of this unit, which includes many lakes and ponds and the wild headwaters of the north, middle, and south branches of Derby Creek, has been redefined by citizen-conservationists since the 1966 hearing to combine features of the original recommendation of the citizens, Colorado Wildlife Division, and the U.S. Forest Service. The resulting Unit P is approximately 3,500 acres smaller than the unit recommended by citizens in 1966.

Forest Service objections to the original Unit P were based on its estimation of 24 miles of four-wheel drive trail and many miles of water transmission ditches and pipes within the area, plus its planned 15 miles of development road and its concern for dams on two lakes and drift fences on the range allotment. The Unit P boundary realignment has eliminated all but approximately nine miles of the vehicle trails, and all but two one-half-mile sections of water transmission ditch. It would also allow the Forest Service to construct its planned

Forest Development Road to within two miles of the boundary proposed by the Service.

The old, small, earth-fill dams have only a very minor, localized and unobjectionable impact, and occasional stabilization maintenance could be affected by the Forest Service for the protection of wilderness values.

Drift fence maintenance, relocation or construction is certainly within the intent of the Wilderness Act to require the administrating agency to protect wilderness values.

Because this unit is essentially wilderness in character and use, with but slight indication of man's manipulation, and for the other reasons mentioned, citizens believe that Unit P should be in the Flat Tops Wilderness.

UNIT R, SWEETWATER & TURRET CREEK HEADQUARTERS

The redefined boundary for Unit R adopts the Forest Service recommendation on the east and west ends, and the Colorado Wildlife Division in the middle. This eliminates the Forest Service objections which were based on a ditch and three proposed vehicle campsites.

UNIT S, THE MEADOWS AND THE WAGON WHEEL AND PATTERSON CREEK DRAINAGES This unit should be divided into two subunits. The Meadows portion surrounds the stretch of the South Fork of White River from the point where Fawn Creek joins the South Fork upstream to the existing Primitive Area. The larger portion is contiguous to Forest Service area G-1 and includes the major part of the Wagon Wheel and Patterson Creek drainages.

Concerning the Meadows area, the Forest Service states that its boundary was selected to place the line on more definable and recognizable locations. Its boundary leaves the entire Meadows area out of the proposed Wilderness.

In 1966, the citizen boundary excluded the jeep trail then in use the length of the Meadows. The boundary was 1/16 mile (330') from the side of the trail away from the river, and the near bank of the river on the side of the trail next to the river.

Since 1966, the Forest Service has closed the trial to vehicle traffic where it crosses the river near Nichols Creek, and thus is now managing the northern third of the Meadows as wilderness.

Citizens have recommended that the Unit S boundary be redefined to include all of the Meadows area north of Fawn Creek in the wilderness and to leave the read open only to the Special Use Permit Lodge (Budge's Resort) with the boundary remaining at 1/16 mile from the road away from the river and the near riverbank on the river side of the road, and 4 mile from the developed area of the Resort.

This recommendation has not been acted on by the Colorado Open Space Council to date, but there is reason to believe that it would be accepted as an improvement over the 1966 COSC proposal or the 1970 revision.

Concerning the remainder of Unit S, the Wagon Wheel and Patterson Creek drainages, the Forest Service's only reason for rejecting that part of the area within the citizen boundary was that it included some four-wheel drive trails deemed necessary for wildlife harvest. The Service states that there are 114 miles of vehicle trail in the unit, but this is an exaggeration because the Service included areas with vehicle trails that were not within the citizen boundary.

Further confusion by the Forest Service is evidenced in its statement which infers that Blair Mountain and the proposed route for a planned Blair Mountain Road are within the citizen boundary. The steep eastern escarpment of Blair Mountain does form the citizen boundary; the top and rounded western portion, the only part of the mountain suitable for a road, are outside the citizen boundary. The citizen boundary excludes all vehicle trails that might be described as "well-established," and Unit S is included in the Chief's New Study List of Roadless Areas, which indicates that the Forest Service now considers it as essentially roadless.

The upper or southern ends of both drainages are relatively gentle and scenic. with open meadows and scattered woods; the Patterson Creek portion is especially scenic where it includes several lakes along the eastern cliffs of Blair Mountain. The lower, northern, parts of the drainages within Forest Service Unit G-1 are precipitous and heavily forested.

Unit S is traversed by several foot and horse trails. It is accessible on three sides by vehicles, and there is no point in it more than 12 miles from a vehicle trail. There is no need for vehicle trails throughout the unit to ensure adequate wildlife harvest.

The southern boundary of Unit S was designed to exclude the proposed Blair Mountain Road and its extension along the general alignment of Ute Trail to Bison Lake. Subsequent evaluation of the increasing vehicle-recreational impact on the Deep Lake-Heart Lake and Meadows environment has raised serious question as to the advisability of encouraging more use of the entire southern flank of the Flat Tops by construction of the road.

Ute Trail qualifies for inclusion as a roadless area under the criteria established by the Forest Service. Indications now are that replacing Ute Trail with a major road would only lead to a catastrophic impact on the very limited camping resources with one of the major problems being pollution of South Fork White River and Deep Creek, a tributary of the Colorado River.

The Patterson and Wagonwheel drainages are an integral part of the South Fork White River watershed. They supply a significant contribution to the stream flow of the river, and retention of their wilderness qualities will assist in maintaining the high quality of the water in the main river. Moreover, these drainages are an important source of natural propagation for the endangered native cutthroat trout found in the South Fork of White River.

For these and other reasons, citizens urge the inclusion of the Meadows and the Wagonwheel and Patterson Creek drainages within the Flat Tops Wilderness.

UNIT G-1, SOUTH FORK WHITE RIVER

This Unit was included in the Forest Service proposal in 1966, but dropped in 1967. The only non-conforming features were described by the Forest Service in 1966 as: "The two small tracts of private land along the South Fork of White River within the proposed Wilderness serve no commercial or agricultural purpose. One tract consists of 90 acres, with one cabin. The other tract of 105 acres contains several summer cabins and has 8 subdivisions and 7 different owners. Access to both tracts is via Forest Service trail. Inholdings within the Wilderness are not compatible with management objectives. The Forest Service will negotiate for the acquisition of these lands by exchange or purchase."

After heeding Colorado Governor John Love's request to keep the South Fork out of the Wilderness, part of the justification for the 1967 Forest Service reversal of position on this same area was: "... the area contains 195 acres of patented land in two tracts. Some of this land is developed with buildings and structures. There are two special-use cabins in the area. The Forest Service again reviewed the area in light of this testimony and concluded that it should not be included in the Wilderness."

Virtually the same facts about land ownership are presented, and the reasoning still leaves the area as suitable for Wilderness.

Elk calving and wintering grounds, native cutthroat and whitefish fisheries, Wild River potential, magnificent scenery, watershed protection-these, and many more wilderness characteristics have been mentioned time and time again. There is no disputing the fact that the area is wilderness.

Contention centers around the problem of whether the water resources of the South Fork should be dammed, diverted, and developed within this wilderness canyon. There has been no public outcry against the idea of making commercial use of the South Fork water resources where the planned development site was below South Fork Campground at the western edge of the proposed Wilderness. Whether the prospective water developers indicate that their reservoirs would be used primarily to store and divert water, or to generate power, the anticipated market is the same the oil shale industry.

There is no question but that the planned development of the oil shale resources will require great quantities of high quality water. There are many unanswered questions about the quantity of water needed and the source of that water. Twenty year old estimates are still being quoted, but perhaps the most valid estimates available now are contained in the 1972 U.S. Dept. of Interior's Draft Environmental Statement for the Proposed Prototype Oil Shale Leasing Program. Of interest are the following comments taken from the Rocky Mountain Center on Environment, Critical Review of the U.S. Dept. of Interior Draft Environ

mental Statement for the Proposed Prototype Oil Shale Leasing Program, 1972, pages 5-8: "Attempting to sort out the complexities of water availability in terms of quality requirements and sources from the Draft is like trying to segregate all the bean sprouts from a bowl of chop suey."

"Several problems are inherent in the discussion of water in the Draft: In the first place, the sources of supply are fraught with uncertainty.

"Another aspect of uncertainty is the 'augmentation' program." (Weather modification, desalinization and 'other methods.')

"Groundwater quantity and quality is clearly an unknown....

"Depletion of the groundwater will also be significant... the relationship between ground and surface water is not adequately analyzed.

"... the Final Statement should present in clear form where it is expected that each acre-foot of water will come from, and when... (it) should also include an examination of two types of water needs which were omitted in the draft: water used but not consumed in the process, and water needed for revegetation.

"... the potential uses of the water for other purposes should be examined. Water used for oil shale will not be available for other uses, such as agriculture and recreation;

"The salinity problem of the Colorado River merits considerable discussion. Cumulative effects of diversions, reservoir evaporative losses, and new sources of mineral loading are significant.

"Alternatives to high elevation dams should be considered. The environmental impact of dams such as Yellow Jacket would probably be more significant than that of possible dams at lower elevations.

"The Final Statement should analyze not only the impact of the proposed dams, but assess the other options for securing water."

"The most conservative analysis of... 'questimates' throughout the Draft report lead to these conclusions: (a) A mature oil shale industry could be 3 to 5 times the size of the prototype program... (2) Given unlimited or greatly increased water supplies, the development of the best 'commercial' 11 million acres would be over 500 times as extensive... as the prototype program. (Although the availability of such a water supply is not realistic, a mature industry even 25 times the size... as the prototype program would be highly significant.)"

In the Draft Environmental Statement it is estimated that the planned 1985 production of one million barrels of oil per day would require up to 120,000 acrefeet of water for consumptive use. (Water to be used and returned to the stream, and revegetation water is not included).

This amount can be provided by existing impoundments such as Green Mountain, Ruedi, Flaming Gorge, and Fontenelle Reservoirs, which will have to be used anyway for a mature industry capacity of even 3 to 5 million barrels per day. Thus, construction of reservoirs on the upper South Fork, which might store 216,000 acre-feet at best is certainly not necessary at this time; perhaps in 20 years. By that time we will know much more about the entire project, there may be firm answers to the questions raised by ROMCOE, and likely the whole energy problem will have changed.

In summary of this discussion, development of South Fork water resources at sites within the proposed Wilderness is not necessary at this time for the development of oil shale resources, and if development is necessary in the national interest at some later date, that development may take place under provisions of the Wilderness Act. In the meantime, the watershed can be protected under Wilderness management.

USDA Forest Service, Flat Tops Wilderness Proposal, 1967, page 9, (emphasis added: "The greatest public value of any of the resources, other than the wilderness resource, within the proposed Wilderness is the water yield from the drainages under consideration. Quality, quantity, and continuous flow of water are of major economic value to the dependent downstream lands and users. A basic objective of watershed management is to maintain sufficient vegetative cover to assure soil stability and proper hydrological functioning of the watershed. Wilderness management meets this objective.

"High-quality water yields will be maintained by the retention of a natural vegetative succession."

For these reasons, citizens believe that the South Fork of White River Unit G-1, must be included in the Flat Tops Wilderness.

UNIT T, MARVINE AND EAST MARVINE CREEKS

The 1966 citizen proposal included small portions of the Ute and West Marvine Creek drainages which were objected to by the Forest Service and have since been eliminated from the citizen proposal. The citizen boundary now includes an area of approximately 8,700 acres (1966: 11,980 acres), and is a consolidation of the 1966 citizen and Colorado Wildlife Division boundaries.

Forest Service objections to the area included in the present Unit T are that East Marvine Creek "is used heavily by motorized equipment and will be developed for a deferred rotation range management system with man-made improvements," and that Wild Cow Park, part of the same drainage, "is covered by existing oil and gas leases." It is also stated that "Lower Marvine Creek has established four-wheel drive trails and extensive commercial timber lands," but the topography of the area indicates that this statement refers mainly to portions of the drainage outside the citizen boundary.

Citizen feeling about the oil and gas leases and range management plans expressed previously apply here also.

The problem of use by motorized equipment is a matter of priorities. Roads have not been established in the area, there are several hundred thousand acres of National Forest land not proposed for Wilderness classification within a few miles that could absorb what use now exists in this unit, and the Marvine Creek Campground just outside the citizen boundary is a logical stopping point for vehicles.

Citizens believe that the wilderness values present in this unit should be given top priority, and that it should be included in the Flat Tops Wilderness.

UNITS 1, 3, AND 5

Of six small units of the existing Primitive Area recommended for declassification by the Forest Service to place boundary lines on more definable and recognizable locations, units 1, 3, and 5 are contiguous to units proposed as additions by citizens and are thus recommended for retention by citizens.

Mr. Mallett, please. Mr. Mallett, we are getting a little short on time. If you could summarize your statement for us I think it would be helpful. We will include the full statement in the record.

STATEMENT OF JERRY MALLETT, WESTERN FIELD REPRESENTATIVE, WILDERNESS SOCIETY

Mr. MALLETT. Thank you, Senator. I am Jerry Mallett, western field representative for the Wilderness Society with headquarters in our western regional office at 4260 East Evans Avenue, Denver, Colo.

One point I'd like to particularly stress immediately is that the United States is a great Nation, primarily because it was founded in the wilderness resource. The white man for the first time discovered a continent that was untouched and contained an abundance of water, timber, wildlife, and other natural resources. As a result, the country grew very quickly. Today we are finding a great need to protect these few remaining wilderness areas to provide some insight into the lives of our forefathers who developed this great country.

I am very happy to be here today in strong support of S. 1863. On behalf of the members of the Wilderness Society I would like to thank Senator Haskell and Senator Dominick for this opportunity to present our views.

My first experience with the Weminuche was in 1950. At that time. I didn't think much of the wilderness value. It wasn't until a number of years later during my career in the Army that I started