Comment on Draft Forest Service Winter Travel Management Rule by AUGUST 4, 2014
For the first time in its history, the U.S. Forest Service has been ordered to pay closer attention to the management of snowmobiles and other over-the-snow-vehicles (OSVs). We now have a chance to help shape how this management will happen at the Forest level.
A 2013 court case, brought, and won, by our friends Winter Wildlands Alliance, has forced the agency to adopt plans that dictate where over-the-snow-vehicles can go. The Forest Service issued the draft rule that would tell Forests how to do this planning a couple of weeks ago. We have until August 4, 2014 to comment on the rule. We are asking you to take ten minutes and submit a comment regarding this draft rule.
There are two ways to comment. Our allies at Winter Wildlands Alliance have created a template letter where you can fill in details highlighted in yellow and follow their straightforward submission instructions. Go to www.winterwildlands.org/take-action and you can be done in few minutes.
Or, you can read the draft rule at http://www.regulations.gov/#!documentDetail;D=FS-2014-0004-0001. Comments are easy to submit – just hit the blue “Comment Now!” button in the upper right side of the page. For this, we have talking points below, but it’s critical to personalize your comments. Be passionate, draw from you own backcountry experience, and be polite. It’s these personal comments that make the biggest impact.
This really is a unique, once-in-a-lifetime opportunity for quiet winter backcountry enthusiasts to help shape public lands policy. Personal comments make a real difference in agency decisions and rule-making. So please take a few moments and submit a comment. Once all comments are received and analyzed, the Forest Service will issue a rule by September 9, 2014. Then individual forests will begin drafting their management plans.
We know you’ve all heard it before – “this is urgent,” “a once-in-a-lifetime chance,” “our future depends on your comments.” Well, it’s true again. This really does represent an unparalleled chance to influence how winter use will be managed on our National Forests for decades. Please take the time to comment.
Talking points for comments:
1. Closed Unless Designated Open. Individual forests or ranger districts can choose to implement an “open unless designated closed” approach (the status quo) or a “closed unless designated open” approach (same as ORVs). This is inconsistent and confusing. In order to promote consistency across the National Forest system, both seasonally and geographically, the over-snow vehicle rule should require a “closed unless designated open” approach to OSV management.
2. Scrutinize all Snowmobile Use – No Grandfather Clauses. The draft appears to grandfather-in a range of past designations for over-snow vehicle use. Plans that are comprehensive across a whole Forest or Ranger District aim to minimize user conflict and resource damage, and which involve the public in a meaningful way, should not have to be redone. I am concerned that the draft goes too far by allowing past administrative decisions that do not have the same comprehensive scope, analysis, or level of public involvement to count as travel plans.
3. Minimize Impacts of Snowmobile Use. The Forest Service needs to issue a final over-snow vehicle rule consistent with Executive Order 11644, which requires regulation of off-road vehicles – including snowmobiles – to specific routes and areas. In designating these routes and areas the agency must consider, with an objective of minimizing, impacts to: forest resources, wildlife, and conflicts between motor vehicles and other recreational uses. By allowing previous designations to stand without ensuring they incorporated these “minimization criteria”, the proposed rule appears inconsistent with Executive Order 11644.
4. Areas Should Be Defined and Analyzed on a Small Scale.The draft proposes to change the definition of an “area” to include broad expanses even larger than a ranger district and states that impacts of individual trails within that area would not need to be analyzed (page 8). I have a number of concerns about this issue. For one, official trail systems attract and concentrate use above and beyond that found in a dispersed-use area. While this is not necessarily a problem, it is important that the Forest Service analyze the impacts of increased use and consider what effect a motorized trail system may have on non-motorized users and the environment prior to authorizing new trails. Second, by expanding the definition of an “area” the Forest Service is effectively allowing individual Forests to avoid taking a close look at where motorized use is indeed appropriate. This departure from the way all other ORVs are managed is inconsistent and should not be included in a final rule.
Greg, Mike, Jeff, and Wolf
Montana Backcountry Alliance was formed in 2005 to build an organized community advocating for traditional, human-powered winter recreation. We have commented as a group and individually on forest service management plans, held ski movie premiers, and helped conduct citizen monitoring projects. We intend to build on our success and further strengthen the traditional winter recreation community by advocating for specific non-motorized areas with reasonable access for human-powered recreationists. The motorized lobby is powerful, organized, and well-funded. But we are motivated and dedicated to establishing a strong voice in this important debate. We are also hopelessly addicted to skiing and riding, and will be busy enjoying the wonderful opportunities Montana offers in the winter. Get out and enjoy them too!