Post by Wyldcomfort on Nov 21, 2007 12:48:31 GMT -5
November 15, 2007
Steve Ellis
Forest Supervisor
Wallowa-Whitman National Forest
PO Box 907
Baker City, OR 97814
Re: Scoping Period Comments for the Wallow-Whitman National Forest Travel Management Plan
Dear Supervisor Ellis:
Thank you for the opportunity to comment on the Proposed Action for the Wallowa-Whitman National Forest Travel Management Plan. The following substantive comments are submitted on behalf of Forest Access For All, Inc. (FAFA), a not-for-profit corporation for the public good, incorporated under the laws of the state of Oregon. Forest Access For All, Inc. represents a broad range of forest users, from dedicated OHV riders to occasional users of the forest for sight seeing and picnicking. The members are avid hunters, fishermen, snowmobilers, ranchers, miners, hikers, bicycle riders, and mushroomers, among others. The members are intimately familiar with the Wallowa-Whitman, as many FAFA members have lived in northeast Oregon and recreated on the Wallowa-Whitman National Forest all of their lives. These users believe strongly in the concept of multiple use of the Wallowa-Whitman National Forest.
General Concerns & Comments:
Process
The process used to develop the Proposed Action is fatally flawed. Although the Wallowa-Whitman may have intended to allow the public to understand its intended management direction early in the process by identifying their proposed action, in actuality this appears that the decision to close many roads and trails has already been made without the benefit of a full NEPA analysis.
The approach the forest is taken to planning violates the 1990 Forest Plan for the Wallowa-Whitman. The Forest Plan requires a site-specific analysis to show that ATV use is incompatible due to resource management problems. It further states that this analysis will be made through the Forest Travel Management Plan. We have not seen nor have we heard of any site-specific analyses demonstrating ATV use incompatibility that have been made through this planning process. The current direction in the approved 1990 Forest Plan requires that site-specific analyses be made prior to changes in the allowed use of ATVs. This current direction cannot be changed without preparing a supplement to the Land Use Plan, conducted through an appropriate NEPA process, as required by law. NEPA is clear that a supplement is required “ if (i) the agency makes substantial changes in the proposed action that are relevant to environmental concerns (ii) there are significant new circumstances or information relevant to environmental concerns”.
Many opportunities to develop a wide range of alternatives have been negated by the regional office direction for regional consistency strategy:
· Off-road access would be permitted for 300 feet on either side of designated motorized routes to accommodate access to and from dispersed campsites only.
· No motor vehicle use for big game retrieval off of designated routes, trails or areas would be permitted.
This process was a regional decision that provided no opportunity for public input. This process has denied local citizens adequate opportunity to provide meaningful input during the scoping period of the analysis. The denial of appropriate scoping has subsequently negated the development of a range of alternatives that is responsive to the issues and concerns of local citizens.
The Wallowa-Whitman’s decisions to exclude road systems from certain other planning areas, including the Bald Angel on the La Grande Ranger District, Sled Springs OHV Trail system on the Wallowa Valley Ranger District, and the South Fork Burnt River OHV Trail System in the Unity area of the Whitman Ranger District, as well as previous administrative closures have also limited the opportunity to develop a full range of alternatives. Although these planning areas may have gone through an alternative NEPA process, that process was not in the context of designating road use, rather it was for a timber sale, a vegetative management project, or other management activity. The motorized vehicle user public did not understand that their opportunities to ride on national forest lands would be diminished due to the management activity proposed. These plans were also not widely announced to the general public so they could adequately participate in the NEPA process. Those individuals that were notified did not understand the extent of proposed road closures and changes in access opportunities that were buried inside a seemingly unrelated proposed activity such as a “Vegetative Management Project”. These planning areas and previous administrative decisions to close roads should be revisited during the Travel Management Plan alternative development to provide the opportunity for public comment in the total context of what will be open and for what use in the future. We have heard comments from your staff such as, “those decisions have already been made”, and while we understand that your staff may be frustrated with redoing some work, in the long run it will yield a better Travel Management Plan for your forest.
Need Rationale
1. Meet National Direction Although the national planning rule as published in the Federal Register, 36 CFR Parts 212, 251, 261, 295 “Travel Management: Designated Routes and Areas for Motor Vehicle Use” (Federal Register 2005: 70FR68264) (Travel Management Rule), directs that each forest develop a travel management plan, that rule does not direct that each forest close large sections of its road system. Rather, it requires each forest to designate routes and uses and develop maps for users to better understand what use is allowed and where. The Wallowa-Whitman has made the great leap forward to close thousands of miles of roads and trails as well begin enforcement on previous closures of which the general motorized public has no real knowledge. The Wallowa-Whitman’s Proposed Action is a huge change from the current situation, it is based on poor rationale, and it has totally caught the recreation public and other forest users completely off-guard.
2) Reduce adverse resource impacts caused by road and trail usage in order to maintain and restore the health of ecosystems and watersheds. We know that the Wallowa-Whitman has taken a great deal of previous management action to encourage dispersed recreation on the forest. The forest has deliberately moved from concentrating recreational experiences to spreading the users across the forest. The Proposed Action will do just the opposite and appears to be in direct opposition to previous decisions. By limiting the number of open roads and trails, the users will be concentrated in smaller areas, increasing the chances for undesirable impacts.
If the number of users is truly increasing as the Wallowa-Whitman implies in the needs statements that will exacerbate the problem by reducing the areas available for users. Although we do not believe that the number of users on the forest has dramatically increased, we could not obtain data from the forest to substantiate the claim. The Wallowa-Whitman must collect data to support these claims before it moves forward with the access designation process. Without good data on actual user-days, the forest cannot determine the level of need or make accurate management decisions.
If the forest is correct and the data shows the number of users is increasing, it is counter logical to think that it is an improvement in resource management to concentrate more users in fewer areas. Rather, the forest should be actively encouraging users groups to step forward and help to develop more trail opportunities such as has been done on the Dixie and Paiute National Forests in Utah. The forest must take a leadership role in this.
If there has been unauthorized use that creates resource damage, as the forest alleges, the forest should have prosecuted the responsible parties, as provided for in the law. If it is not an illegal activity but one that is causing unanticipated resource damage, there is a process in the current direction to remedy that problem. Adding more regulations and restrictions will not make up for the forest’s inability to effectively manage its current regulations.
The issue of displacement of big game is not yet fully understood. While some recent studies do show that elk do move away from motorized vehicles, those same studies also show that elk move away from hikers, bicyclists, and horse riders. These studies do not conclude that this level of flight is detrimental to the elk’s energetics or their physical condition. Clearly there was no level of disturbance great enough to be called harassment. The studies also indicated that the animals exhibited less disturbance behavior after they were exposed to the various human disturbances multiple times. This implies that there is habituation factor as well. These same studies had quite different conclusions for deer, showing little impact of OHVs on deer. There is a great deal of conflicting research data that draw very different conclusions about the impacts of OHV use on wildlife. The issues require more study before widespread restrictions on motorized vehicle use are put into place based on a perceived problem.
Other resource damage is alluded to but has not been shown to be a serious problem, rather more of an excuse that one would not want to argue with, the motherhood and apple pie sort. We have not seen in our vast experience riding roads and trails, extensive resource damage of any sort. The majority of motorized users are conscientious and concerned about the environment and resources on which we also depend.
While we do not know for sure what concerns were expressed about those roads and trails no longer required to address public or agency needs, we believe that current direction as described in the 1990 Forest Plan can help to identify those roads and trails. We did not see in the Proposed Action, any documentation that described particular roads and trails that are no longer needed by the public or the agency for that matter. We have seen the ODFW request to allow them to use more of the roads and increase the number of agency enforcement personnel. That would indicate that the ODFW agency does not see the need for closing roads that they need.
3) Specify what uses are allowed on each road, trail and area. The Wallowa-Whitman should be very proactive in involving the OHV users in this process as the Alternative Development moves forward over the next 12-18 months. The users know the road and trail systems better than anyone and will be of great assistance to the forest service in developing alternatives that are meaningful in designating the roads, trails and areas that would be open to motorized use.
4) More closely align the travel and recreational opportunities offered to the public within the forest’s management capability. The Wallowa-Whitman is managing recreation on the forest so the threats of unmanaged recreation are not applicable. The current forest plan is the management plan for the recreation opportunities on the forest. The current direction,
“.. to permit all-terrain vehicle (ATV) use and over-the-snow vehicle use on blocked or closed roads unless this use is found to be incompatible with resource management objectives. These types of uses are generally felt to be an acceptable form of recreation except where site-specific analysis shows them to be incompatible due to resource management problems. This determination will be made through the Forest Travel Management Plan.”,
is a very strong management direction. The Wallowa-Whitman can meet the intent of 36 C.F.R. 212.55 by considering the need for maintenance and administration of roads, trails and areas that would arise if the uses under consideration are designated, and the availability of resources for that maintenance and administration. This process will be ongoing as the management of roads and trails moves forward. The Wallowa-Whitman should be fair and accurate with its analysis of the maintenance needs as a result of OHV use. Off-road vehicles typically have a lower impact on roads as a result of low weight, low tire inflation rates, wide tires resulting lower ground pressure, and slower travel speeds than conventional vehicles. Most the ML1 roads are older “specified” roads built for timber sales with ballast in both the subgrade and on the surface. Many of these roads are built with a foot or more pit-run rock in the subgrade and then surfaced with 6-12 inches of crushed rock. These roads have now completely stabilized; most have even “grassed in” and require very little maintenance.
The Wallowa-Whitman should not justify their Proposed Action on the basis of current manpower & funding limitations, as these can be remedied through the budget process with the proper prioritization and justification. The potential threats of liability claims and lawsuits are also poor rationale for closing roads, as users are operating at their own risk.
While we agree that lack of management capability and field presence has contributed to some of the problems on the forest today, we do not believe that the Wallowa-Whitman should target one user group, motorized users, to remedy the problems. We believe that the Wallowa-Whitman should recognize that motorized use is highly valued and is an important and legitimate use of the forest. In future budget and appropriations requests, motorized vehicle users groups can be very supportive and helpful to help the Wallowa-Whitman obtain necessary funding for maintenance and administration of roads and trails and help to focus resources where they are most beneficial.
5) Amend the Wallowa-Whitman National Forest Land and Resource Management Plan (Forest Plan) to close the Forest to motorized use except where designated open.
The Proposed Action and any other action that makes such sweeping changes to the current direction is a Significant Change to the 1990 Forest Plan. The Wallowa-Whitman has recognized how complex this issue is stating in its own documents:
“ Due to the complexity of the Wallowa-Whitman National Forest and the high degree of interest in travel and access proposals with forest recreationists, the forest will evaluate the process with an environmental impact statement (EIS). This EIS will include the final travel management decision tentatively scheduled for late 2008. Currently the Forest Plan allows motorized use except where restricted in the Forest Travel Management Plan….”
The fact that the Wallowa-Whitman has decided to use an EIS analysis shows that this will be a Significant change for users of the Wallowa-Whitman National Forest, requiring the Wallowa-Whitman to prepare a Supplement to the 1990 Forest Plan, as required by NEPA. See our earlier reference to the NEPA requirement for supplements.
Data
The quality of the information provided to general public has made it nearly impossible to provide meaningful input to the scoping process. The map quality, although somewhat better now, is still unclear and not easy to understand. For example, road numbers are not correct and road locations are not accurate. This is most likely a problem with the original digitizing but nevertheless makes it very difficult for users to provide specific information about certain road and trail segments. Our members have spent an inordinate amount of their personal time traveling routes with GPS instruments to try and provide accurate input.
While we appreciate the fact that the comment period was extended, allowing FAFA members to do this work, it has been a most difficult task, especially in light of the fire closures that were in effect during most of the extension period. Due to these issues, we ask that FAFA members be allowed to participate during the alternative development process in the next 12-18 months and provide direct input and comments to the planning team as they progress.
Equal access
The law and the 1990 Forest Plan require that Wallowa-Whitman “provide equal opportunity regardless of race, color, creed, sex, marital status, age, handicap, religion, or national origin”. We believe that by closing all of the ML1 roads as shown in the Proposed Action, the Wallowa-Whitman has openly discriminated against the old, the young, and the handicapped. Many of these individuals will be denied fair and equal access to the forest if the Propose Action is implemented.
Range of Alternatives
We request that the Wallowa-Whitman develop and fully analyze a wide range of alternatives, including a no change alternative, a pro-motorized use alternative and a county government alternative. We ask that your staff develop the pro-motorized alternative in a creative and open way. We believe that a designated, well managed motorized roads and trails system, could be structured and sustainably funded to allow the forest to adequately maintain and administer the system for the long term.
Without such alternatives and analyses, the general public will not be able fully understand the impacts of various ways that the forest can designate routes, types of uses and seasons of use. Without a full understanding the public will not be able to provide meaningful input to help you develop the final EIS and Record of Decision. As mentioned earlier, our members stand ready to help you develop the alternatives during the next phase of this process.
Current Travel Management Plan
Many of our members have asked to see the Travel and Access Management Plan that the 1990 Forest Plan describes as being “maintained, identifying roads, trails, and off-road vehicle (ORV) restrictions for wildlife protection, recreation and other purposes”. The responses from the Wallowa- Whitman staff have been vague at best and certainly not forthcoming. No one was able to produce a current copy for our members to review the current status of Travel and Access Management as required in the 1990 Forest Plan. The Wallowa-Whitman has apparently violated its own plan by not keeping it up-to-date and now is planning to drastically change the current plan direction without any of the site-specific compatibility analysis that the 1990 Forest Plan required.
Steve Ellis
Forest Supervisor
Wallowa-Whitman National Forest
PO Box 907
Baker City, OR 97814
Re: Scoping Period Comments for the Wallow-Whitman National Forest Travel Management Plan
Dear Supervisor Ellis:
Thank you for the opportunity to comment on the Proposed Action for the Wallowa-Whitman National Forest Travel Management Plan. The following substantive comments are submitted on behalf of Forest Access For All, Inc. (FAFA), a not-for-profit corporation for the public good, incorporated under the laws of the state of Oregon. Forest Access For All, Inc. represents a broad range of forest users, from dedicated OHV riders to occasional users of the forest for sight seeing and picnicking. The members are avid hunters, fishermen, snowmobilers, ranchers, miners, hikers, bicycle riders, and mushroomers, among others. The members are intimately familiar with the Wallowa-Whitman, as many FAFA members have lived in northeast Oregon and recreated on the Wallowa-Whitman National Forest all of their lives. These users believe strongly in the concept of multiple use of the Wallowa-Whitman National Forest.
General Concerns & Comments:
Process
The process used to develop the Proposed Action is fatally flawed. Although the Wallowa-Whitman may have intended to allow the public to understand its intended management direction early in the process by identifying their proposed action, in actuality this appears that the decision to close many roads and trails has already been made without the benefit of a full NEPA analysis.
The approach the forest is taken to planning violates the 1990 Forest Plan for the Wallowa-Whitman. The Forest Plan requires a site-specific analysis to show that ATV use is incompatible due to resource management problems. It further states that this analysis will be made through the Forest Travel Management Plan. We have not seen nor have we heard of any site-specific analyses demonstrating ATV use incompatibility that have been made through this planning process. The current direction in the approved 1990 Forest Plan requires that site-specific analyses be made prior to changes in the allowed use of ATVs. This current direction cannot be changed without preparing a supplement to the Land Use Plan, conducted through an appropriate NEPA process, as required by law. NEPA is clear that a supplement is required “ if (i) the agency makes substantial changes in the proposed action that are relevant to environmental concerns (ii) there are significant new circumstances or information relevant to environmental concerns”.
Many opportunities to develop a wide range of alternatives have been negated by the regional office direction for regional consistency strategy:
· Off-road access would be permitted for 300 feet on either side of designated motorized routes to accommodate access to and from dispersed campsites only.
· No motor vehicle use for big game retrieval off of designated routes, trails or areas would be permitted.
This process was a regional decision that provided no opportunity for public input. This process has denied local citizens adequate opportunity to provide meaningful input during the scoping period of the analysis. The denial of appropriate scoping has subsequently negated the development of a range of alternatives that is responsive to the issues and concerns of local citizens.
The Wallowa-Whitman’s decisions to exclude road systems from certain other planning areas, including the Bald Angel on the La Grande Ranger District, Sled Springs OHV Trail system on the Wallowa Valley Ranger District, and the South Fork Burnt River OHV Trail System in the Unity area of the Whitman Ranger District, as well as previous administrative closures have also limited the opportunity to develop a full range of alternatives. Although these planning areas may have gone through an alternative NEPA process, that process was not in the context of designating road use, rather it was for a timber sale, a vegetative management project, or other management activity. The motorized vehicle user public did not understand that their opportunities to ride on national forest lands would be diminished due to the management activity proposed. These plans were also not widely announced to the general public so they could adequately participate in the NEPA process. Those individuals that were notified did not understand the extent of proposed road closures and changes in access opportunities that were buried inside a seemingly unrelated proposed activity such as a “Vegetative Management Project”. These planning areas and previous administrative decisions to close roads should be revisited during the Travel Management Plan alternative development to provide the opportunity for public comment in the total context of what will be open and for what use in the future. We have heard comments from your staff such as, “those decisions have already been made”, and while we understand that your staff may be frustrated with redoing some work, in the long run it will yield a better Travel Management Plan for your forest.
Need Rationale
1. Meet National Direction Although the national planning rule as published in the Federal Register, 36 CFR Parts 212, 251, 261, 295 “Travel Management: Designated Routes and Areas for Motor Vehicle Use” (Federal Register 2005: 70FR68264) (Travel Management Rule), directs that each forest develop a travel management plan, that rule does not direct that each forest close large sections of its road system. Rather, it requires each forest to designate routes and uses and develop maps for users to better understand what use is allowed and where. The Wallowa-Whitman has made the great leap forward to close thousands of miles of roads and trails as well begin enforcement on previous closures of which the general motorized public has no real knowledge. The Wallowa-Whitman’s Proposed Action is a huge change from the current situation, it is based on poor rationale, and it has totally caught the recreation public and other forest users completely off-guard.
2) Reduce adverse resource impacts caused by road and trail usage in order to maintain and restore the health of ecosystems and watersheds. We know that the Wallowa-Whitman has taken a great deal of previous management action to encourage dispersed recreation on the forest. The forest has deliberately moved from concentrating recreational experiences to spreading the users across the forest. The Proposed Action will do just the opposite and appears to be in direct opposition to previous decisions. By limiting the number of open roads and trails, the users will be concentrated in smaller areas, increasing the chances for undesirable impacts.
If the number of users is truly increasing as the Wallowa-Whitman implies in the needs statements that will exacerbate the problem by reducing the areas available for users. Although we do not believe that the number of users on the forest has dramatically increased, we could not obtain data from the forest to substantiate the claim. The Wallowa-Whitman must collect data to support these claims before it moves forward with the access designation process. Without good data on actual user-days, the forest cannot determine the level of need or make accurate management decisions.
If the forest is correct and the data shows the number of users is increasing, it is counter logical to think that it is an improvement in resource management to concentrate more users in fewer areas. Rather, the forest should be actively encouraging users groups to step forward and help to develop more trail opportunities such as has been done on the Dixie and Paiute National Forests in Utah. The forest must take a leadership role in this.
If there has been unauthorized use that creates resource damage, as the forest alleges, the forest should have prosecuted the responsible parties, as provided for in the law. If it is not an illegal activity but one that is causing unanticipated resource damage, there is a process in the current direction to remedy that problem. Adding more regulations and restrictions will not make up for the forest’s inability to effectively manage its current regulations.
The issue of displacement of big game is not yet fully understood. While some recent studies do show that elk do move away from motorized vehicles, those same studies also show that elk move away from hikers, bicyclists, and horse riders. These studies do not conclude that this level of flight is detrimental to the elk’s energetics or their physical condition. Clearly there was no level of disturbance great enough to be called harassment. The studies also indicated that the animals exhibited less disturbance behavior after they were exposed to the various human disturbances multiple times. This implies that there is habituation factor as well. These same studies had quite different conclusions for deer, showing little impact of OHVs on deer. There is a great deal of conflicting research data that draw very different conclusions about the impacts of OHV use on wildlife. The issues require more study before widespread restrictions on motorized vehicle use are put into place based on a perceived problem.
Other resource damage is alluded to but has not been shown to be a serious problem, rather more of an excuse that one would not want to argue with, the motherhood and apple pie sort. We have not seen in our vast experience riding roads and trails, extensive resource damage of any sort. The majority of motorized users are conscientious and concerned about the environment and resources on which we also depend.
While we do not know for sure what concerns were expressed about those roads and trails no longer required to address public or agency needs, we believe that current direction as described in the 1990 Forest Plan can help to identify those roads and trails. We did not see in the Proposed Action, any documentation that described particular roads and trails that are no longer needed by the public or the agency for that matter. We have seen the ODFW request to allow them to use more of the roads and increase the number of agency enforcement personnel. That would indicate that the ODFW agency does not see the need for closing roads that they need.
3) Specify what uses are allowed on each road, trail and area. The Wallowa-Whitman should be very proactive in involving the OHV users in this process as the Alternative Development moves forward over the next 12-18 months. The users know the road and trail systems better than anyone and will be of great assistance to the forest service in developing alternatives that are meaningful in designating the roads, trails and areas that would be open to motorized use.
4) More closely align the travel and recreational opportunities offered to the public within the forest’s management capability. The Wallowa-Whitman is managing recreation on the forest so the threats of unmanaged recreation are not applicable. The current forest plan is the management plan for the recreation opportunities on the forest. The current direction,
“.. to permit all-terrain vehicle (ATV) use and over-the-snow vehicle use on blocked or closed roads unless this use is found to be incompatible with resource management objectives. These types of uses are generally felt to be an acceptable form of recreation except where site-specific analysis shows them to be incompatible due to resource management problems. This determination will be made through the Forest Travel Management Plan.”,
is a very strong management direction. The Wallowa-Whitman can meet the intent of 36 C.F.R. 212.55 by considering the need for maintenance and administration of roads, trails and areas that would arise if the uses under consideration are designated, and the availability of resources for that maintenance and administration. This process will be ongoing as the management of roads and trails moves forward. The Wallowa-Whitman should be fair and accurate with its analysis of the maintenance needs as a result of OHV use. Off-road vehicles typically have a lower impact on roads as a result of low weight, low tire inflation rates, wide tires resulting lower ground pressure, and slower travel speeds than conventional vehicles. Most the ML1 roads are older “specified” roads built for timber sales with ballast in both the subgrade and on the surface. Many of these roads are built with a foot or more pit-run rock in the subgrade and then surfaced with 6-12 inches of crushed rock. These roads have now completely stabilized; most have even “grassed in” and require very little maintenance.
The Wallowa-Whitman should not justify their Proposed Action on the basis of current manpower & funding limitations, as these can be remedied through the budget process with the proper prioritization and justification. The potential threats of liability claims and lawsuits are also poor rationale for closing roads, as users are operating at their own risk.
While we agree that lack of management capability and field presence has contributed to some of the problems on the forest today, we do not believe that the Wallowa-Whitman should target one user group, motorized users, to remedy the problems. We believe that the Wallowa-Whitman should recognize that motorized use is highly valued and is an important and legitimate use of the forest. In future budget and appropriations requests, motorized vehicle users groups can be very supportive and helpful to help the Wallowa-Whitman obtain necessary funding for maintenance and administration of roads and trails and help to focus resources where they are most beneficial.
5) Amend the Wallowa-Whitman National Forest Land and Resource Management Plan (Forest Plan) to close the Forest to motorized use except where designated open.
The Proposed Action and any other action that makes such sweeping changes to the current direction is a Significant Change to the 1990 Forest Plan. The Wallowa-Whitman has recognized how complex this issue is stating in its own documents:
“ Due to the complexity of the Wallowa-Whitman National Forest and the high degree of interest in travel and access proposals with forest recreationists, the forest will evaluate the process with an environmental impact statement (EIS). This EIS will include the final travel management decision tentatively scheduled for late 2008. Currently the Forest Plan allows motorized use except where restricted in the Forest Travel Management Plan….”
The fact that the Wallowa-Whitman has decided to use an EIS analysis shows that this will be a Significant change for users of the Wallowa-Whitman National Forest, requiring the Wallowa-Whitman to prepare a Supplement to the 1990 Forest Plan, as required by NEPA. See our earlier reference to the NEPA requirement for supplements.
Data
The quality of the information provided to general public has made it nearly impossible to provide meaningful input to the scoping process. The map quality, although somewhat better now, is still unclear and not easy to understand. For example, road numbers are not correct and road locations are not accurate. This is most likely a problem with the original digitizing but nevertheless makes it very difficult for users to provide specific information about certain road and trail segments. Our members have spent an inordinate amount of their personal time traveling routes with GPS instruments to try and provide accurate input.
While we appreciate the fact that the comment period was extended, allowing FAFA members to do this work, it has been a most difficult task, especially in light of the fire closures that were in effect during most of the extension period. Due to these issues, we ask that FAFA members be allowed to participate during the alternative development process in the next 12-18 months and provide direct input and comments to the planning team as they progress.
Equal access
The law and the 1990 Forest Plan require that Wallowa-Whitman “provide equal opportunity regardless of race, color, creed, sex, marital status, age, handicap, religion, or national origin”. We believe that by closing all of the ML1 roads as shown in the Proposed Action, the Wallowa-Whitman has openly discriminated against the old, the young, and the handicapped. Many of these individuals will be denied fair and equal access to the forest if the Propose Action is implemented.
Range of Alternatives
We request that the Wallowa-Whitman develop and fully analyze a wide range of alternatives, including a no change alternative, a pro-motorized use alternative and a county government alternative. We ask that your staff develop the pro-motorized alternative in a creative and open way. We believe that a designated, well managed motorized roads and trails system, could be structured and sustainably funded to allow the forest to adequately maintain and administer the system for the long term.
Without such alternatives and analyses, the general public will not be able fully understand the impacts of various ways that the forest can designate routes, types of uses and seasons of use. Without a full understanding the public will not be able to provide meaningful input to help you develop the final EIS and Record of Decision. As mentioned earlier, our members stand ready to help you develop the alternatives during the next phase of this process.
Current Travel Management Plan
Many of our members have asked to see the Travel and Access Management Plan that the 1990 Forest Plan describes as being “maintained, identifying roads, trails, and off-road vehicle (ORV) restrictions for wildlife protection, recreation and other purposes”. The responses from the Wallowa- Whitman staff have been vague at best and certainly not forthcoming. No one was able to produce a current copy for our members to review the current status of Travel and Access Management as required in the 1990 Forest Plan. The Wallowa-Whitman has apparently violated its own plan by not keeping it up-to-date and now is planning to drastically change the current plan direction without any of the site-specific compatibility analysis that the 1990 Forest Plan required.