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Joined: Dec 2002
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There is a contradiction between the newspaper article and what the Environmental Assessment says. The paper would lead you to believe that the proposal is to remove the toilets and institute a pack-it-out program. The EA favors the following:

PROPOSED ACTION
The proposed action is to replace the two existing toilets, along the Mt. Whitney Trail at
Outpost and Trail Camp with the minimum necessary structures to serve the allowable
recreation use in the area of 60 overnight, 100 day and 25 over Trail crest per day. The
proposed replacement toilet buildings will have a footprint of approximately 16’ x 16’ or
256 square feet. In addition there will be a deck area outside for unloading bins and
several small liquid drying beds for a total footprint of 500 square feet or less. Connected actions include a proposed schedule for helicopter flights for construction and annual reoccurring maintenance.

Pack-it-out is listed as one of several alternatives, but apparently it is not the favored one. Indeed, the report mentions problems that happened after an earlier toilet removal:

Also in 1973, the Regional Office instructed the Forest to remove a fiberglass toilet from
Trail Camp (by helicopter) to maintain the purity concept of the Wilderness Act
(Written correspondence of Wayne Maynard, Forest Planner, 1973). Also, a metal toilet
was removed from Lone Pine Lake. Maynard writes “Regardless of the interpretation of
‘purity’ sanitation of Trail Camp remains the problem”. “After the toilet facility at Trail
Camp was removed, sanitation problems occurred immediately” (Mt. Whitney Trail
Interim Management Plan 1974).

Joined: Apr 2003
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Well, I'm glad to see I'm not the only one confused about what's going on.

I went and reread what appeared to be the official announcement posted on Jan 7 by list member "1531" (the link to the Inyo Register seems to be stale, so I can't verify that this announcement is legit).

That says:
<blockquote><em>
The EA for Mt. Whitney Human Waste Management analyzes the latest proposals for the management of this area. Alternative 5, Toilet Building Removal and Mandatory pack out of waste is being identified as the preferred alternative at this time; this is a change from the originally proposed action of Toilet Building Reconstruction [emphasis added]. This preferred alternative would remove both toilet structures along the Mt. Whitney Trail and require visitors to pack out their own solid waste.
</em></blockquote>
So I have some confidence that the FS plans to remove the toilets and go to a PIO system.

My question remains: what additional information has come to light to render the EA's proposed action inferior? Absent that additional information, it seems that the EA is the best argument against this "preferred alternative."

And my other question remains: How am I supposed to respond to this changed proposal without having the arguments in favor of it in front of me?

Bill Law

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I just checked my email, finding that Ms. Hennessy at the Forest Service sent this reply:
*****
Thank you for your message asking for clarification. I can now see where
the confusion may be rooted. You received the Environmental Assessment
electronically, and apparently you were not sent the cover letter that went
with the hard copy mail. In that letter there is an explanation that the
Preferred Alternative is now Alternative 5 (Pack-it Out) and not the
Proposed Action (re-build the toilets). I will look through the files to
get you a copy of that letter. The letter also requests that comments be
sent to (electronically) comments-pacificsouthwest-inyo@fs.fed.us, Subject:
Mt. Whitney Toilets. Or by mail to Garry Oye, District Ranger, White
Mountain Ranger Station, 798 Main Street, Bishop, CA 93514.

I have forwarded these comments on unofficially, but please send them to
the address above. The comment period closes Feb 4. Thanks for bringing
this to my attention.

-mb

Mary Beth Hennessy
Wilderness Management -Inyo Nat'l Forest
E-Mail: mhennessy@fs.fed.us
Phone: (760) 873-2448 Fax: (760) 873 2458
*****

Therefor we must carefully read the report and submit thoughtful comments as instructed in the email above.

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Ken,

I am not ragging at you. However, to state my letters to Mr. Oye are not serious is a big assumption on your part not having seen what I have sent to Mr. Oye. My letters to the Inyo are always serious and respectuful on what I view as problems with forest management. Another thing you state my post is political if anything it is apolitical.

I took Mr. Oye's comment in the LA Times Whitney Special Section seriously and waited a couple of weeks to write him a serious letter so it wouldn't be lost in the full of angry comments, which garnered no response. This was the first time I have not been responded to by the person in management I have addressed. This is fact.

As long as you have people there is going to be human waste and as long as you have a trailhead as popular as Main Mt. Whitney Trail you are going major waste problems. This is how these folks have choosen to earn a living. If they don't like what the job entails they are free to find employment elsewhere. To state that properly trained and equipped forest service personal, or a subcontractor, can't handle this job safely and efficiently is silly. We are an industrialized society which handles things alot more hazardous without problems. If they need to charge more for permits to handle this problem so be it. I don't think the additional charge will stop people from ponying up for the lottery.

People use "Ranger" to refer to all forest service personel but in fact there are very few rangers. If they need to hire "sewer workers" to handle this problem; let them hire sewer workers. Either that or 50 poop police because they will need them.

Bill

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The Inyo National Forest website now has information about the 30 day comment period. If you go to the link for the report, there are some paragraphs of information under the link for the .pdf file. I don't think these paragraphs were there until at least January 26.

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Another bit of info:

I called somebody at Inyo NF and left a message inquiring about how I could comment on the current, actual proposal.

I got a call back (they left a message), which I'll paraphrase (this is from my notes): <em>"the original EA was done a year and a half ago...since then there's been additional tought, new research, new personnel, that sort of thing."</em>

My guess is that the "new personnel" is the biggest factor.

It still seems odd that we cannot comment on the validity of this "new research" or on the logic of this "additional thought."

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Powergui,

Notice that the report is dated January, 2004. You need to document the claim in your recording by keeping a permanent copy. They've put themselves in a box: if they really wrote it a year and a half ago, it may be outdated and invalid for an action now. Also, it further shows an invalid process in that they gave the public a report that they knew did not represent the true plans of the F.S., and as you pointed out, did not inform us of the actual thinking and analysis.

Note that earlier in the thread was a claim by "1531" that Ranger Oye had just finished the EA on January 2, 2004.

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For what it's worth, here's an excerpt from my comment letter on the waste management plan environmental assessment"

1. The impacts on the natural environment of all five alternatives appear to be limited, and often transitory. These do not appear to provide sufficient grounds for selecting an alternative.

<additional comment on the details of the document omitted>

Alternative four appears to be the best option presented. The approach to limiting the impact of heavy backcountry use by restricting camping to designated sites is already in use in Yosemite National Park. I have personal experience with these restrictions in Yosemite, and though they may be perceived as antithetical to a John Muir-like, unfettered wilderness experience, they nevertheless represent a workable compromise between demand and statutory conservation requirements.

As the subject document notes in several places, compliance with a pack it out policy is forecast to be no more than 80% at best. Given the large number of novice hikers using the Whitney main trail, this may be optimistic. The document states on page 15 that, “If a mandatory pack it out system fails, the Forest Service will implement further use limits and/or designated sites camping system.” The document does not define what failure means, and thus the public is left wondering at what point the pack it out strategy would be abandoned, and other, only vaguely specified, measures adopted. If alternative five is selected, the failure criteria should be spelled up front, as well as the most likely response to non-compliance.

From a cost perspective, options four and five are clearly the low-cost alternatives, with alternative 5 being the least expensive at $70,050 non-recurring cost, and $97,050 in annual operational costs. Alternative four, however, is only 14% more costly up front, and is predicted to have the same annual operational cost. Given the difficulty of changing the behavior of thousands of annual visitors, it seems likely that one of two things will happen if alternative five is selected: either the annual cost of implementing the mandatory pack it out policy will rise, or the policy will fail due to insufficient manpower.

I would expect that the chief difficulty facing Forest Service staff would be enforcement. Because of the obvious difficulties in catching people in violation of the pack it out policy, not to mention potential privacy law complications, enforcement of the policy could be expected to be problematic. In contrast, violation of designated campsite use would be very straightforward to observe, and the perpetrators easily identified. This would result in a more predictable annual cost, and have the likely side effect of reducing confrontations between wilderness users and Forest Service staff. Since alternative four involves a voluntary pack it out component, I would expect the educational cost would be comparable between the two options.

Alternative four appears to have already been identified as a fallback position if alternative five is selected and subsequently fails. Given the likelihood that alternative five will meet with significant resistance, and the limited resources the Forest Service can bring to bear on the problem, it seems like selecting alternative four from the outset makes the most sense. It preserves the physical wilderness character of the area to nearly the same extent that alternative five does, is consistent with wilderness management strategies already shown to be successful in the Sierra, and the recurring costs are more predictable and controllable.

The only additional comment I would like to make on alternative four is this: since the reduction of day use permits from 100 to 70 is not anticipated to have a meaningful impact on typical daily use (page 37, “In reducing the day use quota to 70 from 100, there may be a change in use patterns but overall the total number of day users may not change.”), one has to wonder why it is being proposed at all. It would be a shame to deny an additional 30 visitors the opportunity to visit the Whitney are on the two most popular summer holidays simply to satisfy some (unstated in the document, but assumed) statistical criterion. It would suggest leaving the number of day use permits unchanged, or if they are limited in anticipation of future day use growth, that certain limited exceptions be made to accommodate Fourth of July weekend and Labor Day weekend.

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Steve,

Your cost analysis is flawed. You must take into account recurring as well as non-recurring costs. Comparing Alternative #1 to your preferred #4:

Invest an extra $160,500 non recurring costs
(200,000 vs 39,500 for construction)
Save $32,200 in recurring costs EVERY YEAR
(37,050 vs 4,850 recurring)

My calculator says you are getting 20.1% interest on your investment (if the toilets never wear out)

Return on Investment for various lifetimes
10 yr 15.9%
15 yr 18.8%
20 yr 19.7%
30 yr 20.0%

hmmm...
If they can't get the funds from the federal government, they can get them from me for a portion of the saved recurring costs!

(the numbers would change a bit for F.S. because the initial investment over alternative #5 is 170,500 with same savings in recurring costs.)

By the way, I also thought alternative #4 was pretty good, consistent with current practice in other high use areas. In my comments I said it was my second choice, but not really acceptable due to the limited "burying area" available in the area of interest.

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Ken + 5; I clipped out the parts where I excluded alternatives 1-3 from my personal consideration. I just hvae a hard time with toilets in the back country, and I think the health and safety risk to FS employees to maintain them is not worth it. Hence, I only compared alternatives 4 & 5. If all options were compared on the basis of cost, then your analysis would be correct, provided you bought into the FS's forecast of recurring costs.

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Ken
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Interesting point of view. There are people who work in the same substandard conditions, therefore the rangers should work in equally substandard conditions?

First, I have not read anything about sewer workers hear on this site. It seems to me, that it would outside the scope of this forum. To talk about things being elite and bogus, ignores the fact that this is a forum devoted to Mt. Whitney, and so, we do not have a "sewerworkers of America" thread. However, I did specifically read the EIR on the forest website that describes in detail, the work. Also aware of the work, Doug seems as bothered by the whole thing as I am.
Not looking at changing this absurd job situation is actually the elistist point of view: "I don't have to handle the stuff, so I don't care about them, and *I'm* sure not going to do it, so let them continue to do it, no matter how bad"!

Second, you state: "It's curious that some think that Forest Service employees are above this sort of work on an occasional basis, when tens of thousands of others in this country make it their primary occupation. Rangers are employed to manage our forests and parks, and that includes managing the wastes generated by visitors." This is an odd concept of management. Michael Eisner is hired manage Disney, including the bathrooms, but I don't envision him cleaning them. You conveniently change the key point that various posters have made about RANGERS, changing it to "Forest Service employees". For example, I doubt that anyone would have a problem with engineers doing the work. I simply think of Rangers as naturalists. Yes, you could have Louis Leakey or Dian Fosse (rip) cleaning toilets, I'm sure they were capable of it. The question is whether it is *appropriate* to have that particular group of people doing it.

Third, the average sewer worker is protected by a vast array of State worker safety regulations, from which the Forest Service is exempt. So I would not assume that the rangers are doing the same job, for which they are not occupationally trained, nor have the same protections.

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Ken
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DH, if you look back at the postings, you will find that the only thing that specifically talked about specific forest service employees with the work being done was actually about *rangers* doing the work. You state that you don't care how they do it, as long as it is done. Some of the rest of us *do* care how it is done.

You state: "Second, certain precautions and safeguards are necessary for the proper handling of waste. They aren't in place because some government bureaucracy requires them, they are in place because they are necessary to do the work. It's riciulous to assume the rangers, or whoever the Forest Service has servicing toilets, is untrained and unprotected, and you have no basis for making that assumption." You appear to have no understanding as to how worker protections came into being. As for the basis of my assumption, I got the information from the EIR posted on the gov't website. Have you read what the procedures are? Do you understand that the proposed update involves having large pans of fecal contaminated urine sitting in exposed areas to evaporate. Hmmmm. That conjures up pleasant images of pine-tinted air.

You state: "Third, there's nothing "substandard" about doing such work. Saying there is when you know nothing about it just reinforces the elitist point of view with which you have positioned yourself. I suppose you look down on the medical profession because they have to work with blood and guts, and morticians because they work with dead bodies. It must be quite nice to be able to reap the benefit of others in society doing all the "substandard" yet very necessary work that you are too effete to imagine doing yourself."

Yep, I really look down upon those medical workers! What you don't appear to know is that there are a wide set of regulations under which such people work, that protects them from personal contamination by the things with which they come into contact. According to the EIR, which I recommend you read (are you getting the hint?), these rangers are NOT adequately protected, and are at severe risk of disease contraction.

I still don't understand the "elitist" comments, especially in the light of your comments that you won't do a job yourself; you don't care who doesn't it, as long as it is not YOU; and you don't particularly care if it puts the people doing the work at risk. Your tone sort of makes you sound like you thing of the Rangers as
"the help". I don't.

My attitude is that I would not ask a person to do a job that I would not do myself. If that makes me elite, then guilty as charged. Frankly, when I read in the EIR of what they have to do with my waste, I am motivated to never use the solar toilets, even if they remain.

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I think it's time you boys stop fighting and head home for supper. The street lights are on and I'm sure I heard your mama calling your name. I guess "writing EIR's" must not be too time-consuming, eh DH?

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Ken
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My last word to you DH... your supposed expertise in *writing* EIR's does not apparently extend to bothering to *reading* EIR's, which you appear not to have done. Otherwise you would understand the unique exposures to Rangers servicing the solar toilets, and why your analogies to flush toilets and trailhead repositories are just silly. I suppose that if our little conversation prompts some folks to actually read it, and comment on it, there is some good to this. I'd suggest you read it, rather than rely on your "expertise". Your written comments will have a great deal more impact, instead of just replying to newspaper reports of the report.

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I'm with Dave. Gawd, I'm sick and tired of that A-S-S DHMeieio. What ever happened to the good old days when he was "unregistered"?

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Actually, I thought Ken's comments were very constructive and well thought out.

Just because someone has had enough of your predictable posts and opinions on every subject doesn't necessarily make them a troll, and trust me,Dave O'Th'Mtn and I are not the same people. We, and many others you prefer to lump into a "troll category" are just dismayed to find that some people have way too much extra time on their hands, and you choose to use yours adding what you feel is constructive debate and input to any and all subjects on this board.

Constructive debate and knowlageable input are always welcome, your posts are usually neither.

And no, I'm not Ken either.

Example: Ken asks whether toilets at trailhead are usable. You had to chime in without any clue that your guess is they would be buried, and go on to some story about a trip of yours where you used toilet roofs for tables. The very next post was from a person who had been at the trailhead recently, and at least one of the toilets were usable. His post was what this board is all about, recent information about conditions, your post was your usual "Gotta post something because everybody needs my posts, and I don't have a clue, but I'm gonna post anyway, and anyone who disagrees with me must be a troll."

Doug Thompson, the Moderator of this board, unregistered you the first time, I'm sure you consider him to be just another "Troll"

And all this from someone who's never set foot on the summit of Mt Whitney.

By the way, don't bother responding to my post, because I have neither the time nor the inclination to get into a "good or constructive debate" with you.

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DH. Might I suggest you choose an alternate screename, as yours has become the laughingstock of this board. Just a well intentioned suggestion.

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And so? You're the latest laughingstock, self appointed expert, person using up Doug's bandwidth with pure babble, call it what you want, its you. Search on that.

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KNOCK IT OFF, YOU TWO!!

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Hi Today is the last day to send or/e-mail comments on the waste subject. I will close this thread tonight but leave it on the board,for reference. Please keep the comments civil this site is for positive input, THAT CAN BE FOR OR AGAINST BUT MUST BE CLEAN.(a pun) Thanks Doug

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