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7Jun/07Off

ALERT: Payette National Forest Travel Management Final EIS

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SAWS Action Alert

Payette National Forest Travel Management Final EIS
McCall, Idaho

Comment Deadline: July 6, 2007

Send Comments to:

    Ms. Suzanne Rainville, Forest Supervisor
    Payette National Forest
    P.O. Box 1026
    McCall, ID 83638

Fax: (208) 634-0744

Email: comments-intermtn-payette@fs.fed.us

Detailed Forest Service information available here:
http://www.fs.fed.us/r4/payette/publications/trvl_mgmt/final%20eis/final%20eis%20index_2007.shtml

Idaho State Snowmobile Association (ISSA) extensive comment information here:
http://www.snowmobile-alliance.org/Action_Alerts/07/PNF_FEIS_ISSA_Public_Comments_Info.rtf

Refer to our previous SAWS Action Alert on the Draft Environmental Impact Statement from spring of 2006 for reference information:
http://www.snowmobile-alliance.org/uploads/SAWS_Action_Alert_-_PNF_Travel_Management_DEIS.htm

SAWS Action Alert on Proposed Action - Winter 2004-2005:
http://www.snowmobile-alliance.org/2004/11/payette-national-forest-travel-management-plan/

The Payette National Forest (PNF) released the Final Environmental Impact Statement (FEIS) for their forest Travel Management Plan (TMP) about a month ago.  Since then, the comment deadline was extended by ten days until close of business (5pm MDT) July 6, 2007.  Please send in your comments as soon as possible.  We recommend sending your email by July 5.  The new TMP will affect snowmobiling and other activities in this forest for the next 10 to 15 years.  This plan is extremely biased against snowmobiling, so we need to overwhelm them once again with comments from snowmobilers and we need to do so immediately.

Summary on the Alternatives according to the FEIS

  • Alternative A: No Action (the same use as before this plan)
  • Alternative B: Proposed Action; closes 17,410 additional acres to snowmobiling for a total of 468,610 acres closed to snowmobiling
  • Alternative C: Would add 78,160 acres for snowmobiling; NOT the actual ISSA Proposal that suggested far more acres should be open to snowmobiling
  • Alternative D: Granola / Crunchy Proposal; closes 204,800 acres to snowmobiling
  • Alternative E: So-called “compromise” that closes an additional 114,010 acres to snowmobiling

SAWS requests that you support a revised Alternative C that includes restoring snowmobile use to those portions of the Needles and Secesh roadless areas included in the January 2005 ISSA scoping comments. There is absolutely NO reason these areas should not be re-opened to snowmobile use.

Do not be fooled by the Forest Service proposed Alternative C.  While this proposed Alternative appears to be a “motorized alternative”, it is not even close in its current language and the amount of recommended closures proposed by the Forest Service. SAWS does not support this alternative as it is currently written. The Forest Service claims in the FEIS that no NEW motorized uses can occur in recommended wilderness areas (RWA).  The fact is motorized use is not NEW in the Needles and Secesh RWAs, as it was allowed under previous forest plans.  The bottom line is there is no law or regulatory policy that requires the Forest Service to continue to prohibit snowmobile use.  In this case, the Forest Service is making the choice to continue to not re-open our previously accessible open snowmobile use areas for NO valid reason.

That is just the tip of the iceberg.  People that are familiar with many travel plans over the past years concur that the PNF FEIS is one of the worst documents they have ever seen.  It is blatantly biased towards the anti-motorized use crowd.  The conclusions by the Forest Service are based on unreliable, outdated and incorrect information.  People cannot read the maps very easily and figure out what they are getting taken away from them.  The document is confusing and misleading.  It is almost as if the Forest Service is begging for a court appearance; which they will most definitely receive if the current proposed Alternative B becomes the final Record of Decision for this plan.

The Idaho State Snowmobile Association has prepared a long and detailed list of points to use when submitting your comments (see link above).  The ISSA comments are very well done and can not be improved upon by SAWS whatsoever, so SAWS is simply going to par down for this alert some of what they are asking snowmobilers to tell the Forest Service rather than try to write our own. 

Please begin your comments with some personal information including who you are, where you live, your interest in the area and anything else that testifies to your credibility.  Do your best to put your comments in your own words because form letters don’t mean much to the Forest Service.  This can be as simple as copying and pasting information, and changing a word or two.

From ISSA: 

  • Commenting on this document was difficult due to the lack of information and because the maps included were worthless and those maps provided online were simply impossible to read.  1:100,000 scale maps are impossible for anyone to derive sufficient information from.
     
  • Alternative E is unacceptable.  The winter use closures to snowmobiling are not needed, necessary or defendable.  The difference in closed areas between Alternative A (the current situation) and Alternative E is 115,750 acres lost to snowmobilers.  Many of those areas proposed to be closed are key riding areas that have been used responsibly by snowmobilers for years.  The reasons for closing these areas are not driven by good science but rather by speculation and an obvious bias against our sport by some members of the planning team.
     
  • Wolverines:  According to Jeff Copeland at the Forest Service Experiment station in Missoula, the nation’s foremost expert on wolverine, “Nothing in the literature indicates snowmobiles are a barrier to wolverine movement.  There is no correlation between snowmobiles and wolverine displacement.”  Any over-snow closures based on connectivity issues for wolverine should be removed from this travel plan.  If any winter use is to be prohibited during the natal or maternal denning period it should include all winter uses, motorized and non-motorized.  Wolverine hunters in Scandinavian countries, according to Copeland, stomp around dens with snowshoes or skis to initiate den abandonment by the females, allowing the hunter to kill both mother and kits.
     
  • Lynx:  A record of decision for the long awaited Northern Rockies Lynx Management Direction FEIS was finally signed on March 23, 2007.  This document comprises the best available science for management of lynx and should be considered in development of this travel plan, even if it should require a modification of the Forest Plan.  The Payette NF is considered secondary range for this animal, outside of its core range and not important to its survival.   The ‘no net gain’ management for lynx should be changed from a ‘standard’ to a ‘guideline’ in the Forest Plan.
     
  • Roadless Areas:  There is no reason to manage any roadless area as if it were designated wilderness.  Only Congress can designate wilderness.  By managing these areas as wilderness, you have created an administratively designated wilderness, trumping Congress.
     
  • Economics:  The Payette National Forest is one of the most popular riding areas for snowmobilers in Idaho and is a very popular destination for snowmobilers from all neighboring states.  Almost every club in the state has a Payette ride each year however; most of these visitors don’t register their sleds in Valley and Adams Counties.  McCall, New Meadows, Cascade, Donnelly are destination areas that see an increase in use each year.  The only thing that reduces visitation numbers is lack of snow.

The Forest Service did not seriously consider opportunities to expand snowmobiling access and disperse use.  Alternative C, the only alternative that did, was not taken seriously and was treated as a non-viable alternative.  Once again, the PNF planning team is demonstrating its bias against snowmobiling. 

  • Exclusive Use Areas:  Alternative E increases the existing area set aside for exclusive use by skiers and snowshoers found in Alternative A from 451,200 acres to 566,950 acres, an increase of 115,750 acres or 26%.  In addition, they also have exclusive use of the massive Frank Church River of No Return Wilderness and shared access to every other acre of the PNF.  Only motorized use is limited, yet skiers and snowshoers also have impacts on water quality and wildlife; therefore this justification is irresponsible and without merit.
     
  • General comments for closures in Alternatives B and E

We oppose any closure to snowmobiling that has been proposed in Alternatives B and E that are not contained in Alternative C of the FEIS.  No analysis of need for these additional closures has been demonstrated.  No credible scientific data supporting these closures has been analyzed.  No documented conflict information has been presented in the FEIS.  In summary, no impartial, unbiased information supports any of the additional closures found in Alternatives B and E. 

  • Comments for opening existing closures

ISSA’s 2005 scoping comments asked that viable and sustainable portions of management area 12 currently closed to snowmobilers be re-opened for our use.  Motorized use in the Needles and Secesh recommended wilderness areas is not new, as documented by the 1988 Forest Plan, and is therefore not a justification for refusing to analyze these areas for continued motorized use and to continue to exclude snowmobilers from these areas.  Re-opening these areas to snowmobiling achieves two important goals; it provides some alternative riding areas for the snowmobile community and it relieves the Forest Service of an existing enforcement burden. 

  • Comments for Specific Closure areas (MA = Management Area)

Granite Closure Area (MA 6)

We support the ISSA’s proposal as written in their January 2005 scoping comments and maps.

Slab/76 Closure (MA 6/7)

We absolutely oppose this closure. It is in one of the more popular snowmobiling areas on the PNF.  We currently share it successfully with skiers and are willing to continue to do so in the future.  Where is the analysis of need that drove this closure?  There is no shortage of skiing opportunities nearby.  To impose this closure is to set the stage for conflict and an enforcement nightmare.

Crestline Closure (MA 7)

This closure is unacceptable.  The "Crestline South" closure includes key parts of the Fall Creek/Crestline trail.  By closing snowmobilers’ access to these trails, it creates a defacto closure that equates to over 20,000 acres.  There has been some speculation that the closure might be designed to accommodate a yurt skiing operation.  If this is the case it should be disclosed and addressed openly in this analysis.

Lick Creek Closure (MA 7/12)

The closures indicated in Alternatives B and E of the Lick Creek summit area to accommodate cross-country skiing are absolutely unnecessary.  The north closure boundary ISSA proposed in their 2005 scoping comments is realistic and included an exclusive use designation of all of the land that skiers might reasonably be able to access from the trailhead according to backcountry skiers and snowshoers’ own portal requirements analysis conducted by the Winter Recreation Forum.  Like the Crestline South closure, the Lick Creek closure creates additional defacto closures on the level of tens of thousands of acres that were not addressed or even considered in the FEIS.

Patrick Butte and Hazard Creek (MA 9)

This closure is unacceptable and unjustified.  This is actually a popular spring riding area and the closures will seriously impact the groomed trail system.  The closure for wildlife habitat protection has no justification and is not supported by any definitive analysis in the FEIS.

Marshall Meadow Closure (MA 10/11)

Bear-Pete Closure (MA 11)

It is a complete farce that these closures have been proposed and appear to be nothing more than token closures.  The PNF uses their own unsubstantiated rationale that since snowmobilers do not use the areas, they should be closed.  Snowmobilers DO use these areas.  They do not provide wildlife connectivity for the non-existent wolverine.  Marshall Meadow burned recently, leaving it unsuitable as Lynx habitat year-around.

Please forward this to anyone that rides a snowmobile, regardless of where they ride. The Payette National Forest near McCall, Idaho is a high demand winter destination for snowmobilers across the western United States and for snowmobilers from the Midwest. Ask them to write the Forest Service.  The Forest Service needs to know that snowmobilers are not willing to be ignored. 

The Idaho State Snowmobile Association contributed greatly to this alert.  SAWS is proud to be associated with the ISSA and to acknowledge their hard work we ask that SAWS members, especially Idaho SAWS members that are not also a member of the ISSA to please join.  It is by far the best annual $20 an Idaho snowmobiler can spend on anything snowmobile related.  A link to their website can be found at the end of this alert.

Thank you all for your interest in and dedication to protecting YOUR right to ride.

Scott
Snowmobile Alliance of Western States

Protecting the right to ride for the owners of 303,604 registered snowmobiles (2005) in the western United States.

Copyright © 2007 Snowmobile Alliance of Western States. All Rights Reserved.

Permission is granted to distribute this information in whole or in part, as long as Snowmobile Alliance of Western States (SAWS) is acknowledged as the source. If you are not yet a member of SAWS and you would like receive these alerts, please sign up on our web site at http://www.snowmobile-alliance.org/

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If you are not a member of these organizations, please consider joining them:

Idaho State Snowmobile Association (SAWS member)
http://www.idahosnowbiz.com/

Blue Ribbon Coalition
http://www.sharetrails.org/

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