Comment from Great Old Broads for Wilderness

Great Old Broads for Wilderness strongly opposes any revision to Part 610 that would weaken protection for Wilderness Study Areas, lands with wilderness characteristics, recommended wilderness, and existing Wilderness. These wild places have been important places of hope, fun, and recreation for our families and neighbors for decades. Older women like those in our network see these lands as our legacy. They're a gift that we steward for future generations. Beyond our own families' stories, wilderness characteristics and wilderness values are important public land resources that agencies have long recognized and taken into account in their planning and management decisions. The existing guidance offers a framework that is necessary to identify, evaluate, and appropriately manage these values in a way that is consistent with agency responsibilities and objectives. The existing standards provide an effective framework for managing wilderness and wilderness-quality lands. The current guidance helps agencies fulfill their statutory responsibilities, provides consistency for agency staff across offices and regions, and supports informed decision-making. These policies have been developed and refined over the course of many years. They reflect longstanding management practices that have successfully balanced conservation, recreation, public access, and other land management objectives. The agency has offered no justification for reversing course on decades of policies that have benefitted families all across the country. In the context of this lack of clarity, it has become even more clear that retaining transparent, durable guidance is an important way to maintain public trust while providing staff, recreation users, Tribal nations, and other stakeholders with the certainty they need to make decisions. Reducing protection and consistency creates confusion across jurisdictions and management units. Such changes could also lead to the degradation of resources, diminished experiences, increased conflicts, and the loss of wilderness values that are difficult or impossible to restore once harmed. The current framework has provided a stable and effective foundation for management and should be maintained. This policy and others like it ensure that the Wilderness Act and other statutes are fully implemented. These policies must be preserved in full, and the standard of care for these lands should not be lowered in any way. Maintaining the existing guidance promotes continuity and certainty for agency personnel and for those who interact with them, including members of Great Old Broads for Wilderness. Maintaining these standards will ensure that our wild lands continue to be protected as they have been, and that our children and grandchildren can enjoy them for generations to come.