SAWS Action Alert
Comment Deadline: May 19, 2006
Send Comments to:
┬á┬á┬á Forest Supervisor
┬á┬á┬á Payette National Forest
┬á┬á┬á P.O. Box 1026
┬á┬á┬á McCall, ID 83638
┬á┬á┬á Fax: (208) 634-0744
Detailed information available here: http://www.fs.fed.us/r4/payette/publications/trvl_mgmt/deis_trvl/trvl_deis.shtml
The Payette National Forest (PNF) released the forest Travel Management Draft Environmental Impact Statement (DEIS) about a month ago.┬á Since that time, the Idaho State Snowmobile Association (ISSA), Blue Ribbon Coalition (BRC) and Snowmobile Alliance of Western States (SAWS) all requested that the comment deadline be extended from 45 to 120 days so that we can all better evaluate the DEIS and prepare substantive comments.┬á We got 90 days.┬á The new travel plan will affect snowmobiling and other activities for the next 10 to 15 years.┬á This means we need to overwhelm them NOW!
Summary on the Alternatives
Alternative A: No Action
Alternative B: Proposed Action; closes 17,408 acres to snowmobiling
Alternative C: Adds 37,799 acres for snowmobiling; not the original ISSA Proposal
Alternative D: Granola / Crunchy Proposal; closes 199,349 acres to snowmobiling
Needless to say Alternative C is our best bet but SAWS does not support this alternative as it is currently written. SAWS requests that you support a revised Alternative C that includes restoring snowmobile use to those portions of the Needles and Secech roadless areas included in the Dec 2004 ISSA proposal. There is no law or policy that requires the Forest Service to continue to prohibit snowmobile use.
The Payette National Forest is currently under the direction of a temporary forest supervisor.┬á Region 4 hopes to have this position permanently filled by this spring or early summer.┬á It will be our job to give the supervisor as much input and relevant information with which to work, as this person will be making the final decision.
Here are some points for you to use when sending comments to the Forest Service.┬á There are a number of important details that need to be addressed before considering the merits of Alternative C.┬á Please outline some personal information such as who you are, where you live, your interest in the area and anything else that testifies to your credibility.┬á Please put your comments in your own words.┬á
- Alternative C is not the ISSAÔÇÖs proposal and is not a motorized alternative.┬á The Forest Service omitted proposed openings by the ISSA within recommended wilderness areas (RWA), resulting in just a 3.5% increase in access.┬á The original ISSA proposal asked the forest service to open approximately 146,600 acres that were previously closed to snowmobiling for no valid reason, not the miniscule amount of 37,800 acres contained in the so-called motorized alternative.┬á The Forest Service has communicated that they would not consider opening any area that is currently classified as ÔÇ£recommended wildernessÔÇØ and closed to winter motorized recreation.┬á There is no law in the Forest Service Manual that requires the Forest Service to close any RWAÔÇÖs. In fact, FSM 1923.03 states RWAÔÇÖs are ÔÇ£not available for any use or activity that may reduce the areaÔÇÖs wilderness potentialÔÇØ. So they took away the possibility of opening approximately 112,000 acres to snowmobiling in this DEIS.┬á This is wrong and the law is on our side in this case.
- The DEIS fails to consider the potential outcomes of the Roadless Review process.┬á The omitted areas from Alternative C are known as the Needles and Secech roadless areas.┬á Both are classified as RWAÔÇÖs.┬á On February 21, 2006, the Valley County commissioners voted unanimously to remove all of the RWAÔÇÖs from that status in their county and have submitted these recommendations to the governor for review.┬á This was done under the State of IdahoÔÇÖs Roadless Review process.
- The Needles and Secech roadless areas were set aside as recommended wilderness in the 1988 forest ÔÇ£Land and Resource Management PlanÔÇØ.┬á There is evidence in this document that snowmobiling was allowed in the area up until this point, because ÔÇ£trail biking (both motorized and non-motorized)ÔÇØ is identified as an established use.┬á Forest Service policy allows use in areas of recommended wilderness that do not compromise future designation by Congress.┬á Snowmobiling is one of those uses, as it has been given a unique and separate classification from other OHV by the Forest Service to be used in their travel planning process.
- The range of alternatives is inadequate.┬á Snowmobile access changes proposed in Alternatives B and C are minor compared to the area currently open (Alternative A).┬á However, the change in Alternative D, the non-motorized proposal, has a whopping reduction of 18.5%.┬á The lack of any real range of alternatives is a major flaw in this analysis.┬á No alternative adequately addresses the increasing demand for snowmobiling, the need to disperse use to keep a quality experience, and the economic importance of snowmobiling.┬á In 2003 nearly 40,000 people were snowmobiling in the PNF.┬á That figure dropped in 2004 and 2005 because of poor snow conditions, but rebounded this winter because of the normal snowpack.┬á Based on the large number of vehicles that overflowed parking lots onto the roadsides, it appears that the PNF may have set a new record.┬á No alternative in the DEIS responds to that level of demand.┬á This needs to be corrected and a real range of alternatives presented, including ISSAÔÇÖs proposal and changes in the Forest Plan necessary for its consideration.
- Alternative D is completely unacceptable.┬á Alternative D proposes to slash motorized access by 18.5%.┬á The impacts of non-motorized users is largely ignored in the DEIS and they are treated as neutral with respect to pollution, lynx and other wildlife.┬á Yet they too compact snow, affect connectivity, and defecate in the woods.┬á Many studies in fact have shown that wildlife is far more stressed by non-motorized users than motorized users.┬á Their movements more closely resemble those of predators and thus are more likely to produce a violent flight response to non-motorized human presence than snowmobile use which announces their presence with sound.
The numbers of winter non-motorized users is relatively small in comparison to snowmobilers. According to the National Visitor Use Monitoring Study for the PNF in August 2003, snowmobile use was nearly twice that of cross-county skiing and snow shoeing combined.┬á Even so, a number of areas are already set aside for exclusive use by skiers and snowshoers including:┬á North/North, Squaw Point, Jughandle, Little Ski Hill, and Ponderosa State Park.┬á The snowmobile community has agreed to two additional closures at Bear Basin and Lick Creek, although we differ with Alternatives B and D on their size and conformity.┬á Non-motorized users can access every other acre of land in the PNF, including 792,000 acres of congressionally designated wilderness.
Alternative D ignores the economic impact of its major reduction of snowmobiling on local counties and communities.┬á It also fails to respond to the increasing demand for snowmobiling opportunities and the need to disperse use.┬á
- Alternatives A & B are unacceptable.┬á While Alternative A, the existing situation is preferable to the other alternatives, it doesnÔÇÖt respond to changing conditions and needs.┬á With respect to both Alternatives A and B we know that recommended wilderness doesnÔÇÖt mandate that motorized and mechanized use be excluded.┬á We know that much of the identified lynx habitat was delineated in error and that new science opens the doors to more realistic use of actual lynx habitat.┬á We now have new information on economic impacts of motorized winter recreation that places it in a new light with respect to its importance to local communities and their economies.┬á These alternatives simply fail to respond to changing times and new information, and are, therefore, not acceptable.
- The mileage of Groomed Trails must not be reduced.┬á Alternatives A, B, C, and D call for 245.3, 225.9, 237.1 and 225.9 miles of groomed trail respectively.┬á Alternatives B through D all involve a loss.┬á This is unacceptable.┬á The current miles of groomed trails should be retained and any loss in one location offset by increases elsewhere.┬á We need groomed trails to disperse increasing use.┬á Grooming is done at no expense to the PNF and is a useful tool to direct and manage use.
- It appears that the staff is making decisions without regard to Forest policy, as evidenced in the DEIS.┬á In other words, the chickens are running the henhouse.┬á They have failed to research historic use when considering the ISSA proposal.┬á They have failed to follow their policy on their Lynx amendment.┬á They have not analyzed the potential impacts that OHV use, both winter and summer, will have on forest ecology.┬á They have failed to address previous errors that were committed due to bad science, such as claiming part of the forest as Mountain Goat habitat when in reality none have been seen in the area since 1970.┬á┬á
Please forward this to anyone that rides a snowmobile, regardless of where they ride. The PNF near McCall, Idaho is a high demand winter destination for snowmobilers across the western United States. Ask them to write the Forest Service.┬á The Forest Service needs to know that snowmobilers are not willing to be ignored.┬á
The Idaho State Snowmobile Association contributed greatly to this alert.
Thank you all for your interest in and dedication to protecting YOUR right to ride.
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 ┬® 2006 Snowmobile Alliance of Western States. All Rights Reserved.
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