Abstract
This comment argues that the District of Montana’s decision in Wilderness Watch v. U.S. Forest Service correctly applied the Ninth Circuit’s Kofa framework to strike down a multi-agency native trout restoration project in the Absaroka-Beartooth Wilderness, holding that the Forest Service unlawfully prioritized Yellowstone cutthroat trout conservation over the Wilderness Act’s mandate to preserve wilderness character. Dee further contends that while large wilderness watersheds offer valuable climate refugia for native coldwater fish, watershed-scale restoration projects will continue to conflict with the Act’s prohibitions on motorized and mechanized intrusions so long as agencies rely on helicopter transport and rotenone application at scale. Dee concludes that land managers must develop restoration strategies more carefully tailored to the Act’s preservation mandate, or courts will keep invalidating such projects as climate pressures on native trout habitat intensify.
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