Post by Wyldcomfort on Nov 21, 2007 12:49:00 GMT -5
Specific Comments:
We strongly disagree with the Proposed Action in that it will not allow use of ML1 roads. While the Proposed Action document implies that these roads are closed to motorized vehicle use, in actuality and legally, they are Not Closed to ATV use. The current forest plan permits ATV use on blocked or closed roads unless the use is found to be incompatible with resource management objectives, through a site-specific analysis. The Proposed Action also states that no ML1 roads will be designated routes. We strongly disagree with that. There are many thousands of miles of these roads that are blocked or administratively closed that should be designated as open for OHV use. There has not been any site-specific analysis to show that ATV use on these roads is incompatible due to resource management problems. We can agree that there are some ML1 roads that can be undesignated and removed from the route inventory however, we do not agree that this should be done by a blanket approach of eliminating all ML1 roads, rather it should be done through a site-specific analysis route by route approach.
We further disagree that all user created trails will be undesignated. There are certain instances that user created trails are very important links to well used OHV routes. Theses user created trails should be designated as open routes for OHV travel. They are allowed under by regulation in FSH 7715.68 “User-created Routes” would establish that users created routes may be considered for inclusion in the forest transportation system”. We request that the Wallowa-Whitman designate user created routes that are important for connectivity and route development as authorized routes.
We agree with the need to perform an in-depth mixed-use safety analysis on forest roads. We believe that the analysis will show that there can be an increase in the number of mixed-use routes designated for OHV use without compromising the safety of other users. We encourage the Wallowa-Whitman to expedite this analysis and change these current mixed-use restrictions to allow OHV use on more routes. Our members have not had adequate time to provide many comments on the mixed-use restrictions as we have been focusing on the ML1 and user created routes. We will provide substantive comments about the mixed-use routes in a future submission.
We agree with designating motorized use on existing trails. We also believe this system can be and should be expanded. The current system of only 125 miles is totally unacceptable. We have ridden on other trails systems on US Forest Service lands on the Paiute and Dixie National Forests, as an example, that have wonderful trails systems for OHV use. These trails are well built, environmentally sound and provide a great deal of user satisfaction. There is money and resources available to help the forest develop these trails, through the registration and user fees collected by the State of Oregon. We request that you build in this concept into the alternative development process. To not consider new trail construction is not acceptable.
We strongly disagree with the Propose Action that all cross-country use will be closed and that big game retrieval will not be allowed. There are many times of the year and areas on the forest that such use could be designated without creating resource conflicts. While the forest is using the regional consistency guidance as the rationale for this proposal, we do not believe that meets the intent of the public involvement requirement in the national planning rule. We were not given the opportunity to provide comments on the regional direction and that restricts our opportunity to provide meaningful input to help develop a wide range of alternatives as required by NEPA. The denial of appropriate scoping on those issues has subsequently negated the development of a range of alternatives that is responsive to the issues and concerns of local citizens.
As we have previously stated in our general comments, we do not believe this is a non-significant amendment and it is actually a violation of the current forest plan. This is a Significant Amendment and requires a Supplement to the 1990 Forest Plan. We strongly disagree with the Amended Direction as described in the Proposed Action in that it is based on closing ML1 and user created trails. We agree that the forest must designate routes by type of use and season of use as mandated in the national planning rule but the implication in the Amended Direction is that all ML1 roads and user created trails will be not be designated on the MVUM. We disagree with that as the starting place and request that you complete the required site-specific compatibility analyses before you designate the routes.
We are attaching to this submission letter, many pages of comments and concerns about specific roads and road segments that we believe should be designated as open to the motorized public. These are comments and maps completed by our member using GPS instrumentation and mapping capabilities, as well as hand drawn routes on some maps. These represent a great deal of time and effort from our members and show the level of commitment our members have to a favorable outcome from the Travel Management Plan.
We have made very specific comments and we request that the Wallowa-Whitman give very specific responses in return, rather than blend the comments together and provide answers in a very vague way when they respond in the analyses of the public comment. Anything less from your staff will be a slap in the face of our committed members.
Opportunity
The Wallowa-Whitman has a unique opportunity with the motorized users that recreate on the forest to partner and collaborate to develop a win-win situation. As you know there is a very high level of interest in this issue and there is a high level of mistrust that the forest can actually develop a workable Travel Management Plan. There is much suspicion that the request for public involvement is just way to meet the requirement of the national planning rule and avoid a lawsuit. Many of our members believe that you have already decided to implement the Proposed Action as the TMP. Your credibility with the general public is clearly at risk if you proceed in a vacuum.
We request that you allow our members to help you develop areas of special interest where they are reserved, “as-is for further study”. These areas would have the existing ML1 and user created routes designated as open to OHV travel until such time as the forest can appropriately evaluate the needs of the public and compatibility of OHV use. The evaluation could include ways to provide alternative access and high quality riding experiences for OHV use, such as new trails and roads in better locations. The Wallowa-Whitman could be a model or demonstration area for other forests in the region, showing what is possible in developing Travel Management Plans with broad public support.
Endorsement & Incorporation
We endorse the well reasoned scoping comments on the proposed Travel Management Plan for the Wallowa-Whitman National Forest submitted by the Eastern Oregon All Terrain Vehicle Association (EOATVA), La Grande, OR and the Wallowa Valley Trail Riders Association and incorporate them into our substantive comments by reference. These substantive comments provide recommendations to be considered for specific roads and trails during the alternative development process, as well as general comments that include some very creative ideas. These comments also identify new issues and makes sound recommendations for meaningful changes to the Proposed Action.
As you know, there have been more than 8,000 signatures submitted on petitions that are against any further restrictions on access on the Wallowa-Whitman National Forest. We request that you withdraw your Proposed Action and return to a more reasonable approach to designating roads as documented in the current direction in the 1990 Forest Plan. This will meet the intent of national planning rule and keep you from violating the law. As presented, your Proposed Action and the concept of a non-significant amendment to the 1990 Forest Plan are fatally flawed.
If we can answer any questions you have about these substantive comments, please contact us.
Sincerely,
Forest Access For All, Inc.
Larry Cribbs, Secretary
Attachments: Specific road and trail comments and maps
xc: Oregon Federal Congressional Delegation
State Legislators
Baker, Union, Wallowa County Commissioners
We strongly disagree with the Proposed Action in that it will not allow use of ML1 roads. While the Proposed Action document implies that these roads are closed to motorized vehicle use, in actuality and legally, they are Not Closed to ATV use. The current forest plan permits ATV use on blocked or closed roads unless the use is found to be incompatible with resource management objectives, through a site-specific analysis. The Proposed Action also states that no ML1 roads will be designated routes. We strongly disagree with that. There are many thousands of miles of these roads that are blocked or administratively closed that should be designated as open for OHV use. There has not been any site-specific analysis to show that ATV use on these roads is incompatible due to resource management problems. We can agree that there are some ML1 roads that can be undesignated and removed from the route inventory however, we do not agree that this should be done by a blanket approach of eliminating all ML1 roads, rather it should be done through a site-specific analysis route by route approach.
We further disagree that all user created trails will be undesignated. There are certain instances that user created trails are very important links to well used OHV routes. Theses user created trails should be designated as open routes for OHV travel. They are allowed under by regulation in FSH 7715.68 “User-created Routes” would establish that users created routes may be considered for inclusion in the forest transportation system”. We request that the Wallowa-Whitman designate user created routes that are important for connectivity and route development as authorized routes.
We agree with the need to perform an in-depth mixed-use safety analysis on forest roads. We believe that the analysis will show that there can be an increase in the number of mixed-use routes designated for OHV use without compromising the safety of other users. We encourage the Wallowa-Whitman to expedite this analysis and change these current mixed-use restrictions to allow OHV use on more routes. Our members have not had adequate time to provide many comments on the mixed-use restrictions as we have been focusing on the ML1 and user created routes. We will provide substantive comments about the mixed-use routes in a future submission.
We agree with designating motorized use on existing trails. We also believe this system can be and should be expanded. The current system of only 125 miles is totally unacceptable. We have ridden on other trails systems on US Forest Service lands on the Paiute and Dixie National Forests, as an example, that have wonderful trails systems for OHV use. These trails are well built, environmentally sound and provide a great deal of user satisfaction. There is money and resources available to help the forest develop these trails, through the registration and user fees collected by the State of Oregon. We request that you build in this concept into the alternative development process. To not consider new trail construction is not acceptable.
We strongly disagree with the Propose Action that all cross-country use will be closed and that big game retrieval will not be allowed. There are many times of the year and areas on the forest that such use could be designated without creating resource conflicts. While the forest is using the regional consistency guidance as the rationale for this proposal, we do not believe that meets the intent of the public involvement requirement in the national planning rule. We were not given the opportunity to provide comments on the regional direction and that restricts our opportunity to provide meaningful input to help develop a wide range of alternatives as required by NEPA. The denial of appropriate scoping on those issues has subsequently negated the development of a range of alternatives that is responsive to the issues and concerns of local citizens.
As we have previously stated in our general comments, we do not believe this is a non-significant amendment and it is actually a violation of the current forest plan. This is a Significant Amendment and requires a Supplement to the 1990 Forest Plan. We strongly disagree with the Amended Direction as described in the Proposed Action in that it is based on closing ML1 and user created trails. We agree that the forest must designate routes by type of use and season of use as mandated in the national planning rule but the implication in the Amended Direction is that all ML1 roads and user created trails will be not be designated on the MVUM. We disagree with that as the starting place and request that you complete the required site-specific compatibility analyses before you designate the routes.
We are attaching to this submission letter, many pages of comments and concerns about specific roads and road segments that we believe should be designated as open to the motorized public. These are comments and maps completed by our member using GPS instrumentation and mapping capabilities, as well as hand drawn routes on some maps. These represent a great deal of time and effort from our members and show the level of commitment our members have to a favorable outcome from the Travel Management Plan.
We have made very specific comments and we request that the Wallowa-Whitman give very specific responses in return, rather than blend the comments together and provide answers in a very vague way when they respond in the analyses of the public comment. Anything less from your staff will be a slap in the face of our committed members.
Opportunity
The Wallowa-Whitman has a unique opportunity with the motorized users that recreate on the forest to partner and collaborate to develop a win-win situation. As you know there is a very high level of interest in this issue and there is a high level of mistrust that the forest can actually develop a workable Travel Management Plan. There is much suspicion that the request for public involvement is just way to meet the requirement of the national planning rule and avoid a lawsuit. Many of our members believe that you have already decided to implement the Proposed Action as the TMP. Your credibility with the general public is clearly at risk if you proceed in a vacuum.
We request that you allow our members to help you develop areas of special interest where they are reserved, “as-is for further study”. These areas would have the existing ML1 and user created routes designated as open to OHV travel until such time as the forest can appropriately evaluate the needs of the public and compatibility of OHV use. The evaluation could include ways to provide alternative access and high quality riding experiences for OHV use, such as new trails and roads in better locations. The Wallowa-Whitman could be a model or demonstration area for other forests in the region, showing what is possible in developing Travel Management Plans with broad public support.
Endorsement & Incorporation
We endorse the well reasoned scoping comments on the proposed Travel Management Plan for the Wallowa-Whitman National Forest submitted by the Eastern Oregon All Terrain Vehicle Association (EOATVA), La Grande, OR and the Wallowa Valley Trail Riders Association and incorporate them into our substantive comments by reference. These substantive comments provide recommendations to be considered for specific roads and trails during the alternative development process, as well as general comments that include some very creative ideas. These comments also identify new issues and makes sound recommendations for meaningful changes to the Proposed Action.
As you know, there have been more than 8,000 signatures submitted on petitions that are against any further restrictions on access on the Wallowa-Whitman National Forest. We request that you withdraw your Proposed Action and return to a more reasonable approach to designating roads as documented in the current direction in the 1990 Forest Plan. This will meet the intent of national planning rule and keep you from violating the law. As presented, your Proposed Action and the concept of a non-significant amendment to the 1990 Forest Plan are fatally flawed.
If we can answer any questions you have about these substantive comments, please contact us.
Sincerely,
Forest Access For All, Inc.
Larry Cribbs, Secretary
Attachments: Specific road and trail comments and maps
xc: Oregon Federal Congressional Delegation
State Legislators
Baker, Union, Wallowa County Commissioners