On July 20, 2022

Silver Lake hut shortcircuits public comment

Dear Editor,

The recent proposal by Vermont Huts Association (VHA) and Moosalamoo Association (MA) to construct a hut next to Silver Lake in the Moosalamoo National Recreation and Education Area in Leicester (Addison County) reveals numerous problems with the USDA/forest service’s management of the Green Mountain National Forest (GMNF).

Pitched as connecting trails and establishing a series of huts for the benefit of back-country recreationists and people who may not otherwise be able to access the national forest, the proposal does not withstand scrutiny.

The GMNF is responding to a proposal to amend its permit for the Chittenden Brook Hut, located more than 15 miles away and in a different management area than Silver Lake. The Chittenden Brook Hut went through a process established by NEPA called Environmental Assessment (EA) as part of the Robinson Integrated Resource Plan. Nobody commented in opposition.

By attempting to amend an existing permit, the applicants and the GMNF are engaged in a scoping process that considers the Silver Lake proposal to be categorically excluded from requiring an EA, which means there is no public process beyond the 45 day comment period that ended July 11. In addition, the GMNF is using categorical exclusions for several related projects – upgrade to parking area, new trail, upgrades to Silver Lake Campground – which eliminate the EA public process and fail to consider cumulative impacts.

Categorical Exclusion, the lowest level of NEPA analysis, is appropriate for a number of listed items, including reconstruction of existing huts. New huts are not considered in the USFS guidance for categorical exclusions.

The GMNF has so far found that no extraordinary circumstances exist that would require an EA, though four of the seven items the USFS identifies as “extraordinary circumstances” exist in the Silver Lake area.

Public engagement in USFS planning is highly challenging, as there are numerous documents to review and a complex set of policies to consider. The only public forum held for the Silver Lake hut proposal was sponsored by the proponents, during which the majority of people present, who use and enjoy Silver Lake, spoke in opposition.

The more that people have learned about the proposal and the process (or lack thereof), the more it has become clear that something is seriously wrong with how the GMNF is being managed. This is in part due to the failure of the USFS to update the GMNF plan which should be done every 15 years and was last done in 2006, 16 years ago. GMNF staff have said recently that a plan update is expected in 2030 and there is no funding to do a new plan now.

The 2006 Forest Plan does not mention a network of 30 – 45 huts or the Velomont Bike Trail that are being developed without amending the plan to consider public input.

Outside of any established USFS process, the GMNF has allowed VHA to rent the Chittenden Brook Hut to its members for a week before the general public can make a reservation, and members get a 15% discount. There is no precedent for this practice, as the USFS handbook requires reservations to go through recreation.gov. Some reservations on public lands such as ski areas and Appalachian Mountain Club trails are done through a hotel program distinctly different from an unattended hut as they provide services and amenities not offered by VHA.

The VHA application for an amendment to enable the Silver Lake hut was not provided to the public by the USFS and was only received upon request of one citizen on the day of the deadline for submitting comments. In it, VHA says, “The total cost of the hut is approximately $290,000.” The cost is a head scratcher considering the Chittenden Brook Hut was reported to cost about $70,000.

“The U.S. Forest Service is privatizing our Green Mountain National Forest for the benefit of private interests. The proposed construction of a Silver Lake Hut is another example of this privatization, along with the Deerfield Wind industrial energy development, the privately controlled Chittenden Brook Hut, and numerous logging projects that make money for private industry while devastating our forests. The Forest Service is approving these sweetheart deals, despite the fact that they were not included in the obsolete 2006 forest plan, no valid environmental analysis has been done, and they are opposed by the public,” observes Michael Kellett of RESTORE the North Woods.

More than 200 people, many of whom use and enjoy Silver Lake, commented in opposition to the proposal to construct a 25-foot tall residential lodging facility heated by propane with indoor lighting. Proponents mostly commented using a form letter and demonstrate no direct connection or use of Silver Lake.

Vermonters for a Clean Environment’s comments were filed on behalf of our members who use and enjoy Silver Lake. VCE is the only organization to sue the USDA/USFS in the last 25 years over inappropriate management of the GMNF. It is time for the USFS to start listening to the public and do what’s right for Vermont’s people and forests.

Annette Smith is the executive director of Vermonters for a Clean Environment.

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