SAWS Action Alert
Comment period deadline is October 31st, 2005
The Beaverhead-Deerlodge National Forest Draft Forest Plan and Draft Environmental Impact Statement (DEIS) was released June 30th for comments. This plan revision is another example of the Montana region 1 forest service running out of control and catering to the wishes of the extreme green crowd.
Alternative 5 is the forest serviceÔÇÖs preferred alternative in this draft plan. If implemented it would:┬á
- Create six new wilderness areas as well as add to the two existing wilderness areas for a total of 249,000 acres of Recommended Wilderness Areas (RWAÔÇÖs). This is an increase of nearly 70%.┬á┬á
- This alternative calls for prohibiting winter motorized use in all RWAÔÇÖs. Currently recommended wilderness areas are open to motorized winter use.┬á┬á
- The six RWAÔÇÖs would close such areas as: Snowcrest Range, Italian Peaks, East Pioneer Mountains, Mt. Jefferson, and Hellroaring Creek. Pressure from extreme green groups in the recent past have attempted to close the Mt. Jefferson area several times.┬á┬á
SAWS recommends that you tell the forest service that you support a modified version of Alternative 4.┬á We also recommend that you include some of the following information, in your own words, in your comment letter:┬á
- Alternative 5 as currently written is not acceptable to you.┬á┬á
- You support a revised Alternative 4 that contains no RWAÔÇÖs and contains zero acres and zero miles of trails closed to snowmobile use.┬á┬á
- You do not support the closing of any RWAÔÇÖs, especially the Mt. Jefferson and Hellroaring Creek areas, to winter snowmobile use. Remind the forest service that snowmobiles cause little to no impact to the environment.┬á┬á
- The Mt. Jefferson and Hell Roaring Basin areas are extremely popular areas for snowmobilers who come from across the western United States to enjoy this area. These areas see heavy snowmobile use each winter, which provide a tremendous positive economic boost to the surrounding communities throughout the slow winter months. The fact that these areas would even qualify as wilderness with the current level of snowmobile use proves that snowmobile use causes little to no lasting effect on the environment.┬á┬á
- Alternative 4 is the only alternative in this plan that shows any substantial positive economic impact.┬á┬á
- FSH 1909.12 requires the forest service ÔÇ£meet the tests of capability, availability, and needÔÇØ when determining new areas for wilderness recommendation. Clearly there is no need for additional wilderness in this forest for the 1.5% of forest visitors that currently recreate in this forest.┬á┬á
- 1.5% of current BDNF visitors use the existing wilderness areas in this forest (per NVUM results). There is no need to recommend more wilderness areas with such a small use of existing wilderness areas in this forest.┬á┬á
- The Mt. Jefferson / Hellroaring Basin area is comprised of only 4,447 acres, below the minimum threshold of 5,000 acres for wilderness consideration. In addition, it is adjacent to a wilderness study area managed by the BLM. If there is a re-evaluation of the WSA status of this adjacent land by the BLM, then the Mt. Jefferson / Hellroaring Basin area does not meet the requirements to be included in the recommended wilderness category.┬á┬á
- The Mt. Jefferson / Hellroaring Basin areas do not have an enforceable boundary. The area is geographically enclosed by the Continental Divide on the south and the west. But other than Mt. Jefferson and the ridges immediately adjacent to it; and Reas Peak, there is little indication of your presence in the area until you are well within the basin.┬á
- If you are from outside the Island Park area, tell the Forest Service how far you travel to ride in the Beaverhead-Deerlodge National Forest, how long you stay in the area each time you visit, and how much money you spend per day while staying there. According to Island Park motel and restaurant owners and snowmobile rental shops, the average stay is seven days and the average money spent is $300 – $400 per day.┬á
- The Mt. Jefferson / Hellroaring Basin area is an incredible family riding location due to the varying types of terrain and the ease required to take in magnificent views that encompass close to 200 miles in all directions.┬á The area also enables disabled snowmobilers to take advantage of the same benefits.┬á
- Do not consider closing an area to people that do a lot to support a community, for the benefit of one individual with a back country skiing outfitterÔÇÖs license that could go 10 miles north into the Lee Metcalf wilderness.
Please send your comment letters by October 31st to:
Beaverhead-Deerlodge National Forest
420 Barrett Street
Dillon, Montana 59725
Below this alert is our SAWS position statement for the BDNF Plan Revision. It contains more details of this plan that you may find useful in your comment letters.
Dave and Scott (north Washington and Idaho SAWS reps respectively)
Snowmobile Alliance of Western States
Copyright ┬® 2005 Snowmobile Alliance of Western States. All Rights Reserved.
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SAWS Position Statement: Beaverhead-Deerlodge National Forest Plan Revision and DEIS
The Snowmobile Alliance of Western States is very concerned about the Beaverhead-Deerlodge National Forest Plan Revision, as we are also concerned with the Gallatin NF and Flathead NF plan revisions in Montana, and most other forest plan revisions that are currently being revised throughout the western United States. ┬áAs I wrote in my December 2003 article titled ÔÇ£The Common Thread – Forest Plan Revisions and so-called Wilderness AreasÔÇØ, the forest service finds these plan revisions ÔÇô an outline for future management of our forests – as the perfect opportunity to create de-facto Wilderness without having to go through Congress. This is exactly what the forest service is attempting to do with the BDNF plan revision.
The nearly 1,300 page draft forest plan and draft environmental impact statement (DEIS) was originally released June 30th with a 90-day public comment period. The comment period has since been extended to October 31st. Alternative 5, the forest serviceÔÇÖs preferred alternative in this draft plan, recommends six new wilderness areas and additions to the two existing wilderness areas for a total of 249,000 acres of Recommended Wilderness Areas (RWAs). These areas include the Snowcrest Range, Italian Peaks, East Pioneer Mountains, Mt. Jefferson, and additions to the existing Anaconda-Pintler and Lee Metcalf wilderness areas. Currently, all existing RWAs in this forest allow winter motorized use, but the preferred alternative in this plan revision calls for prohibiting all motorized use in all RWAs. This is unacceptable!
SAWS supports a modified version of Alternative 4. According to the forest service Alternative 4 emphasizes motorized recreation. No new RWA are proposed in this alternative: Alternative 4 even removes the existing 174,000 acres of RWAs in the current forest plan. It is the only alternative that shows any substantial positive economic impact. The down side to alternative 4 is that 25 miles of snowmobile trails and some 29,000 acres of land remaining open in Alternative 1 (the no action alternative) are recommended to be closed to snowmobile use (Vol 1, Recreation and Travel Management page 261). The down side to Alternative 1 is that the 174,000 acres of RWAs still exist and could soon become┬áclosed to snowmobile use at the whim of the forest service or become designated┬áas wilderness by an act of Congress┬á- kind of a catch 22 situation in our opinion. Therefore, SAWS supports a revised Alternative 4 that contains no RWAs with zero acres and zero miles of trails closed to snowmobile use.
The Mt. Jefferson and Hell Roaring Basin areas are extremely popular areas for snowmobilers from throughout the western United States. These areas see heavy snowmobile use each winter, which provide a tremendous positive economic boost to the surrounding communities throughout the slow winter months. The fact that these areas would even qualify as wilderness with the current level of snowmobile use proves that snowmobile use causes little to no lasting effect on the environment. There is no justifiable reason for these areas to be recommended for closure to snowmobilers.
Alternative 3 emphasizes primitive recreation and closes the most acres to snowmobile use. This alternative recommends 707,000 acres of RWAs. It is our belief that many of the extreme green organizations will support this alternative since it would close the most land to motorized recreation. This alternative is so far out of line with how this forest should be managed that itÔÇÖs not even worthy of any more space in our position statement.
In the Forest Plan Introduction, the forest service claims that they must make a ÔÇ£Recommendation to Congress of areas eligible for wilderness designation as required (36 CFR 219.17 (a))ÔÇØ (http://www.fs.fed.us/r1/b-d/forest-plan/drafts/draft-plan/ch_1-2.pdf).┬áSAWS does not agree with the forest services interpretation of the CFR requirements. The actual CFR that pertains to wilderness area review is 36CFR219.27 (b), not 36CFR219.17 (a) as the forest service states.┬á 36CFR219.27 actually states ÔÇ£The Forest Service may recommend special designations to higher authoritiesÔÇª” and it “must be evaluated for recommended wilderness designation during the plan revision process”. The CFR clearly does not ÔÇ£requireÔÇØ that the forest service recommend any┬ánew wilderness areas.
SAWS also does not support any RWAs in any national forest region to be closed to snowmobile use and treated as de-facto wilderness. There is no forest service requirement to close RWAs to snowmobile use. It appears that the decision on how to manage RWAs is being left up to each regional forester. BDNF falls under Region 1 control and management. Region 1 covers all national forests in Montana and northern Idaho. The region 1 forester, Abigail Kimbell, has been allowing the closure of RWAs to snowmobile use throughout Montana – for no apparent reason – and this practice needs to stop now.
Per the National Visitor Use Monitoring Results for the BDNF (http://www.fs.fed.us/recreation/programs/nvum/reports/year1/R1_Beaverhead_final.htm#_Toc524421321) ÔÇ£Recreation use on the Beaverhead-Deerlodge National Forest for calendar year 2000 at the 80 percent confidence level was 1,121,321 National Forest visits +/-18.7 percent.┬á There were 1,281,573 site visits, an average of 1.1 site visits per National Forest visit.┬á Included in the site visit estimate are 16,265 Wilderness visitsÔÇØ. This equals less than 1.5% of BDNF visitors that use the existing wilderness in this forest. And the forest service thinks we need an additional 249,000 acres of wilderness in this forest? Unbelievable!
The forest service fails to mention the requirement found in Forest Service Handbook 1909.12, Chapter 70 ÔÇô Wilderness Evaluation (http://www.fs.fed.us/im/directives/fsh/1909.12/1909.12,7.txt). FSH 1909.12,
section 7.2 states ÔÇ£Carefully evaluate the potential addition of roadless areas to the National Wilderness Preservation System to determine the mix of land and resource uses that best meet public needs.┬á An area recommended as suitable for wilderness must meet the tests of capability, availability, and needÔÇØ. Section 7.23 further states ÔÇ£Determine the need for an area to be designated as wilderness through an analysis of the degree to which it contributes to the local and national distribution of wilderness. There should be clear evidence of current or future public need for additional designated wilderness in the general area under considerationÔÇØ.
SAWS clearly does not see a need for additional wilderness areas in this forest when less than 1.5% of current forest visitors wish to visit the existing wilderness areas. The only acceptable alternative in this plan is Alternative 4, modified to remove the noted snowmobile closures. Please revisit the wilderness issue in more detail and consider our comments above prior to releasing the final plan.
Snowmobile Alliance of Western States