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26Aug/090

ALERT: Clearwater National Forest Travel Planning – Draft Environmental Impact Statement (DEIS) Phase

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SAWS Action Alert

Comment Deadline: October 1st, 2009 

Send Comments to:
Kamiah Ranger Station
Attn: Lois Foster, Travel Planning lOT Leader
Rt. 2, Box 191
Kamiah, ID 83536

Or, Email: comments-northern-clearwater@fs.fed.us
Be sure to add "Travel Planning" to the Subject line.

Reference Maps (Pages A-11 and A-12 specifically):
http://www.fs.fed.us/r1/clearwater/Projects/TravPlan/Assets/DEIS/Doc/11_DEIS_09jul_vol2_AppendixA_Maps.pdf

 

Clearwater DEIS Home Page:
http://www.fs.fed.us/r1/clearwater/Projects/TravPlan/ClwTravel.htm

Many organizations and individuals are responding to this Clearwater National Forest (CNF) DEIS. We anticipate a relatively large response from snowmobilers, to this DEIS.  Doing your part will send a clear message to the Forest Service that snowmobilers have to be taken seriously.

Effective Comments: 

Comment letters need to be unique. Include personal stories of historical usage (the earlier the better) within the proposed closed areas. If you have photos, consider providing photocopies with mailed letters or attach them to your email as evidence of usage of these areas. Form letters are not recognized. Include your name and address, or it will not count. Send your comments early; a huge number of comments arrived late last time during Scoping, and did not count.

Forest Service statement: "The analysis of over snow travel is focused on cleaning up some currently inconsistent, unnecessary, or missing snowmobile restrictions, and defining areas where snowmobiles are permitted or prohibited".

Please focus your comments on "defining areas where snowmobiles are permitted or prohibited". The Winter Travel portion of the Preferred Alternative C (or just Alt C); focuses on closing all Recommended Wilderness Areas (RWAs), within the CNF. Winter Travel Plan, Alt D is exactly the same as Alt C, which suggests Alt C, is the most severe travel restrictions considered, dispelling the notion of any compromise, by the Forest Service. Summer user's Alt C, on the other hand, was a balance between Alt B and Alt D, to their credit and large user response.

Winter Alt C closes approximately 200,000 acres of the most unique and remote snowmobiling left in the lower 48.  Of the 1.8 Million acres within the CNF, 150,000 acres known as Hoodoo or Great Burn, represents nearly all the good off-trail riding in the CNF.  The Forest Service's assertion that they are only closing 11.2% of the forest to snowmobiles, belies the fact that this 11.2% represents nearly all of the best off trail riding opportunities in this forest.  Even the Forest Service states that only 27% of the CNF is even suitable for motorized use.  And, as usual, the Travel Plan fails to mention that there is 260,000 acres of existing Wilderness in CNF.   Great Burn's closure will shut down all Alpine (above tree line) riding in the CNF, and for all intensive purposes, outlaws the last remaining area of any significant altitude riding in CNF, accessible from the state of Montana.  Snowmobiles require public land that is of sufficient altitude to provide deep, long lasting snow.  For some reason, the CNF has embarked on a mission to close all high elevations acreage within it's borders.

SAWS suggests selecting Alternative A.  No change. Alt A, and Alt B are nearly identical, except Alt B includes closing the entire forest until November 15th, to snowmobiles.

Below are some suggestions that you may want to include in your comment letter.

  • The Forest Service should leave open all areas that currently support snowmobile recreation. Tell the Forest Service; do not close winter motorized recreation areas just because they are currently recommended for inclusion in the wilderness system (RWA) during previous CNF planning.  In general, these RWA areas include; Hoodoo( Great Burn ), Surveyor, Blacklead, Goat Lake, Williams Lake, Cache Creek, Beaver Ridge Lookout, and Crooked Fork areas. If you snowmobile any of these areas, tell the Forest Service which hills, access trails, meadows, mountain tops, creeks, lakes, and saddles, you have historically used, and for how many years.  You should also include the Historical Usage Coordinates numbers below. These popular areas are in eminent danger of being closed:
    • Snowmobile users with "local knowledge and judgment", cite historical usage of these specific areas affected by the CNF DEIS, Travel Plan. Include this BLACKLEADMT.: T39N R13E (29 28 27 32 33 34) T38N R13E (5 4 3 2 7 8 9 10 11 14 13 23 24 25 36) T38N R14E (30 31 32)
    • SURVEYOR: T40N R13E (19 20 21 26 27 28 29 30 31 32 33 34 35) T39N R13E (1 2 3 4 10 11 12 14 15)
    • HOODOO: T42N R11E (24 18 19 29) T41N R11E (4 9 10 17 16 15 5 8 18)
    • CROOKED FORK: T38N R14E (25 36 19 30 20 29 21 28 33 10 15 22 27 34 26 33 14 11)
  • The Forest Service insists that no one accessed any of these areas before 1987, if you did, or your family did, you must mention dates and places, of historical use.  You must also mention how many other users were in the area at the time. This could prove levels of snowmobile use prior to the areas being designated as RWA.
  • The Great Burn is huge and remote, with creek bottoms and high altitude alpine riding opportunities, as well as climbing opportunities for those adventurous enough. HooDoo/Great Burn represents one of the last truly remote, rugged, difficult to access, high altitude riding areas left in the lower 48.   A truly unique asset for the snowmobiling community.
    • The eastern boundary is the Montana - Idaho Border.
    • Great Burn is accessed by snowmobilers via Trout Creek Road out of Superior, Montana.
    • Surveyor is accessed through the Schely Mountain Road corridor, from Montana.
    • Williams Lake/Crooked Fork area you use Shotgun Crk Road on the Idaho side of Lolo Pass.
  • Great Burn is so difficult to access, it is unlikely snowmobile usage will increase.  Parking is limited, and 20 miles of trail must be covered, just to make it to the off trail riding.   Snowmobile usage in the Great Burn is not "growing" anymore.
  • The Forest Service should not close Great Burn.  It is a large area where user conflict does not exist.  No non-motorized winter time use, is available, due to the 20 miles of trail required to access it.   The CNF has recognized user conflict as a very important management decision point to resolve, yet they intend to close the one place that does not have user conflict.  In the CNF document "Motorized and Non-Motorized Recreation Uses July 19, 2006", the Forest Service asserted that "snowmobiles have created conflicts between users seeking quiet and solitude".  How can one document berate snowmobilers for user conflict, and another document intentionally force snowmobilers into conflict, by closing off all areas of no conflict, and leave open only areas of high conflict?  The Forest Service should show preference to keeping areas open to snowmobiles which have low or no user conflict, high altitude, and suitable terrain.  This only makes logical sense.
  • There are millions of acres of Wilderness Area within the CNF.  Obviously, there is no shortage of “quiet and solitude” available in the CNF.
  • If you snowmobile in the Mallard Larkins area, mention it. State and Federal land managers are unaware of snowmobile usage, or even the possibility of snowmobiling, in that area.
  • Question why November 15th was selected as a forest wide closure end date in Alt B, C and D. In the original scoping period; it was November 4th, but was changed without explanation. The general Elk hunting season ends November 3rd, so why the additional and unnecessary time, and why over the entire forest?
  • Question why high alpine meadows, must be closed, during hunting season in Alt B, C and D. Few if any animals occupy these areas during November. The Forest Service should not close any area where there is not an imperative need, identified by a biologist for the survival of Elk.
  • Snowmobilers expect that any area closed, should reciprocally be replaced with the opening of currently closed acreage.  A good example would be opening the Montana Side of the Great Burn within the Lolo National Forest, in exchange for closing an unused area within the CNF, as a possible true compromise, where all sides get something they want, but not everything.
  • If the Forest Service is serious about protecting forest lands, then it should recommend designations, such as a NRA (National Recreation Area) that both congressionally protects an area from further development, while writing into law the right of snowmobilers to enjoy off trail riding within it's protective bounds.  This comment is only approved if snowmobiles are granted off trail rights. Snowmobiles are the least damaging form of recreation that a National Forest can easily support.  Snowmobilers are good stewards of the land, and are the true environmentalist users of the land.
  • Although outside the scope of SAWS, we cannot accept Summer Travel Alt C either, as it will eliminate 40% of the motorcycle trails in the CNF.  This is on top of another 42% that has been eliminated since 1991.  These closures are definitely heavy handed.  How many 40% reductions does it take, before you have nothing left?

One last thing you need to do.  Send a letter to your Congressman.  They need to hear from the people, that the Great Burn is worth saving.

On the subject of Recommended Wilderness Areas (RWA): 

There are three RWA within the CNF; Great Burn, Mallard-Larkins and additions to the Selway-Bitterroot Wilderness (which is actually composed of 4 individual areas, Sneakfoot, Elk Summit, Storm Creek, and Lakes).  They were created in the 1987 Forest Plan.  These areas also happen to be so-called Roadless Areas (designated in 2001 by Idaho State), designated as "Wild Land Recreation" (simply means it's roadless, and a RWA, no road construction allowed). Alternatives C and D, CLOSE all three RWAs. Alternatives A and B leave all three RWAs OPEN. The Winter Travel Plan for the CNF is clearly nothing more than an attempt to close all RWAs.  Obviously, the Forest Service is preparing to push for full wilderness designation.

In the travel and planning FAQ document, http://www.fs.fed.us/r1/clearwater/Projects/TravPlan/FAQ.htm

, section C8, the forest service does not cite any law, policy, or directive to close Great Burn (HooDoo), Mallard-Larkins, or the Selway-Bitterroot Wilderness additions. They simply propose to ban motorized use in RWAs, so that in the future; "Wilderness opponents" cannot cite historical motorized usage as a reason that the RWAs do not meet "Wilderness criteria". This is the weakest of arguments; close an area, to limit arguments when congress votes on closing the area. The Forest Service is in essence making De-facto Wilderness designations for Congress, utilizing the travel planning process to do so. In the event Congress voted to NOT designate Wilderness to any one of these RWAs and release them back to general national forest use, all three RWAs would none the less remain closed to motorized users, due to the De-facto Wilderness policies proposed in Alternatives C and D, Winter Travel Plans. Snowmobile usage is historical in these areas, and closing these areas will not negate that fact.

The Forest Service also cites, "growing" motorized usage, and the Forest Service's desire to "avoid compromising the potential for Wilderness designation". Here the Forest Service asserts "growing" motorized usage since 1987, without any supportive data.  They also, imply that growing usage will somehow endanger Wilderness values, without providing any evidence as to how exactly snowmobiles are compromising potential wilderness, or how much usage is acceptable, or any other measures or alternatives to bring usage within acceptable levels. It is very difficult for Travel Plan commenter’s to make effective suggestions against hearsay. In 2001, when the state re-affirmed these three areas as Wildlands Roadless, no objections were raised about these areas wilderness character having already been compromised, they gladly accepted it, and agreed.  And here is an example of this faulty logic - most everyone agrees Mallard-Larkins gets NO SNOWMOBILE USE due to it's terrain, yet the Forest Service asserts Mallard-Larkins must be also closed, due to growing over use.  How can the Forest Service make this claim?

The Forest Service Statement:  "Technological advances in motorized equipment, particularly off-highway vehicles and snowmobiles, have made it possible for users to travel over terrain and in conditions that in the past were too rough and difficult for motorized uses."  The Forest Service believes no snowmobile usage of the "state line" or Great Burn area existed before the 1987 RWAs was created.  This is a forest wide "wet blanket" solution to a small and arguably non-existent problem.  If this holds, they will declare that any usage of the Great Burn is new, and therefore not allowed.

SAWS contends that RWAs usage was present before 1987, and usage will be limited to current levels, due to poor and limited access to these areas. Since data on snowmobile sales indicates a continuing 15 year decrease in snowmobile sales/usage, and snowmobile registrations have been flat and decreasing one can only reasonably assume that there is no "growing" snowmobile usage, only less area available every year. This is a direct result of Forest Service policies increasingly restricting available opportunity for snowmobilers. SAWS proposes that one simple way to limit "growing usage", is too provide more acres of opportunity for snowmobilers, to disperse users, not confine users to less area. Failure to disperse users, will only end up putting snowmobilers in jeopardy of being singled out again, for high concentrated usage in another area.  (records indicate that grooming was being performed in the CNF, as far back as 1980)

SAWS Position on RWAs:

Forest Service policy, FSM 1923.03 (2) states any area recommended for Wilderness is not available for any use or activity that may reduce the area’s Wilderness potential. This national policy allows each forest to determine, through the land management planning process, the uses best suited to protect an area’s Wilderness potential."

Many studies have proven the use of snowmobiles over a layer of snow leaves virtually no evidence of disturbance once the snow has melted. FSM 1923.03 also states the National Forest Service policy applying to RWA’s, as "Activities currently permitted may continue, pending designation, if the activities do not compromise wilderness values of the potential wilderness area". SAWS does not believe that snowmobile use "compromise wilderness values" or degrade wilderness character of the land. There is no Forest Service policy, directive or existing law that would prevent winter motorized recreation on snowmobiles from continuing to be allowed in RWA’s. If snowmobile use is currently allowed in areas that may be recommended for wilderness in the future, then obviously this use did not diminish the wilderness value of these areas. Snowmobile use continues to be allowed in Region 6 RWA’s and other regions throughout the US.

The direction Region 1 has chosen to adopt; elimination of activities currently occurring in all recommended wilderness areas is also contrary to the FSH directive clearly stating that the FS is not to change use in areas that they inventory as "potential wilderness areas". (FSH page 9, #71). It is completed with the express purpose of identifying all lands that meet the criteria for being evaluated for wilderness suitability and possible recommendation to Congress for wilderness study or designation. Paragraph 3 of 71 on page 9 also requires "local knowledge and judgment" which does not appear to have happened based on the preferred alternative.

Reference Map of CNF Recommended Wilderness Area:
http://www.fs.fed.us/cnpz/forest/maps/rdless/1.6.04_clw_roadless.pdf

Reference Map of CNF Roadless Area:
http://gov.idaho.gov/roadless_petition/ClearwaterNF%20Rev%20091506.pdf

SAWS Guiding Principle: 

No new wilderness! SAWS does not support any additional public lands being closed to the snowmobiling general public. Snowmobilers have lost access to enough public land. There are currently 109.5 Million acres of Wilderness, and untold millions of acres of De-facto Wilderness, as well as millions of acres up for closure consideration. SAWS does not support any RWAs being closed to snowmobile use either. SAWS believes that any closure should be balanced with a equal opening.

Wade Patrick
Idaho SAWS rep
Snowmobile Alliance of Western States

Copyright © 2009 Snowmobile Alliance of Western States. All Rights Reserved.

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