SAWS Action Alert
Comments due: May 28, 2010
Blue Mountains Forest Plan Revision
P.O. Box 907
Baker City, OR 97814
Team Leader: Katie Countryman (541) 523-1246
Plan Revision Website: http://www.fs.fed.us/r6/uma/blue_mtn_planrevision/index.shtml
Proposed Action document: http://www.fs.fed.us/r6/uma/blue_mtn_planrevision/proposedaction/
There is a lot that could be covered when commenting on this proposed action for the Malheur, Umatilla and Wallowa-Whitman National Forests. From cattle grazing to mining, but SAWS is only providing commentary on possible ÔÇ£newÔÇØ proposed closures as related to snowmobile access. If you are also a motorized wheeled-user, a mountain biker, rvÔÇÖer, miner, property owner, etc., then we strongly encourage you to reach out to your local and state level organizations for information and guidance. In addition, while there is a multitude of defined Management Areas (ÔÇ£MAÔÇØ) that do not allow snowmobiling, for example the 730,886 acres of existing designated wilderness (MA=1A), we are primarily going to address issues as related to Recommended Wilderness Areas (ÔÇ£RWAÔÇØ). There is another MA that is also an issue as well, the 21,213 acres defined as Research Natural Areas (ÔÇ£RNAÔÇØ). The plan for management of RNAÔÇÖs (MA=2B) states ÔÇ£G-80 – Motor vehicle use should not be authorized or allowed within RNAs.ÔÇØ
In terms of the processÔÇª..this is near the beginning of the process and it will not be finalized, at the earliest, until 2012. This part of the process is like a zoning plan. HereÔÇÖs the land, now how do we want to slice and dice it up into management areas to support the ÔÇ£needsÔÇØ, wants and desires of interested parties, and also follow Forest Service (ÔÇ£FSÔÇØ) rules and regulations. This part of the planning is not designed to address specifics within each of the MAÔÇÖs, but to determine how certain MAÔÇÖs, from the previous plans, need to be changed and if new MAÔÇÖs need to exist. After this comment period ends, then the FS will spend the next year reviewing comments and writing Alternatives to the current proposal. In 2011, they will publish a draft environmental impact statement (ÔÇ£DEISÔÇØ) that describes the proposed Alternatives and there will be another comment period.
It is in our best interest to provide as many comments during this stage of the planning process, to ensure the proposed alternatives in the DEIS contain at least one alternative that is acceptable to snowmobilers.
So, here we goÔÇªÔÇª.
OregonWild (OW) reports that ÔÇ£Our state lags far behind its neighbors in protecting natural areas. Only 3.7 percent of Oregon is designated as protected wilderness, compared to 10 percent in Washington and 13 percent in California.ÔÇØ
Oregon State Snowmobile AssociationÔÇÖs Executive Director and Board Members were recently in Washington DC for a Fly -in hosted by the American Council of Snowmobile Associations. Upon their return they provided a trip summary to SAWS reporting that consensus on ÔÇ£the hillÔÇØ is the same as OWÔÇÖs; ÔÇ£There is not enough wilderness in Oregon. The current levels are unacceptableÔÇØ. This consensus comes from names you are probably familiar withÔÇªSenator Ron Wyden, Representatives Earl Blumenauer and Peter DeFazio.
Now you know what we are up against. Are you willing to help stop these potential closures?
In this case, you might feel that we are fortunate that the Revision Team has concluded, ÔÇ£Although social desires exist for more wilderness areas across the Blue Mountains, there is not a social need to designate additional wilderness because current wilderness areas are not exceeding capacityÔÇªÔÇØ (page 33 of the Wilderness Need Evaluation). As a result of the FSÔÇÖs review they are recommending 16,350 acres to be managed as RWA.
That may not seem like a large number, in comparison to other proposed wilderness numbers we are used to seeing these days. Unfortunately, included in the 16,350 acres, are some key snowmobiling areas. And besides, SAWS does not support proposed new wilderness areas. We believe the current 109.5 million acres of existing Wilderness is plenty for the 3.5% of forest recreationists that visit current wilderness areas (http://www.fs.fed.us/recreation/programs/nvum/nvum_national_summary_fy2007.pdf).
DETAILS OF THE PROPOSED ACTION
In the Umatilla National Forest, there is 3,363 acres recommended for wilderness. All recommended areas are extending the current Wilderness boundaries to encompass neighboring acreage. The boundaries for the North Fork John Day Wilderness will be extended to encompass the popular extreme riding areas in the Vinegar Hill area, including a majority of Vinegar Hill itself and then northwest to Ben Harrison Peak (the summit will be closed for snowmobiling access). On the northwestern end of the Wilderness, they are recommending an extension of the current boundary to include all of the high country to the southwest of Olive Lake. The boundaries for the North Fork Umatilla Wilderness are being extended to encompass neighboring acreage, but SAWS was unable to obtain any local information about the riding available in the area.
NF John Day RWA Map:
In the Wallowa-Whitman National Forest, there is 10,770 acres recommended for wilderness. All recommended areas are extending the current Eagle Cap Wilderness boundaries to encompass neighboring acreage. The proposed revised boundaries include the geographic areas of Baker Mountain (7080ÔÇÖ), Huckleberry Mountain, Fox Point (6800ÔÇÖ), Bald Knob (6529ÔÇÖ) and more. The FS stated that these boundaries are being recommended for adjustment to ease management of the current Wilderness boundaries.
Wallowa-Whitman RWA Map:
In the Malheur National Forest, there is 2,217 acres recommended for wilderness. All recommended areas are extending the current Strawberry Mountain Wilderness boundaries to encompass neighboring acreage. This country is not considered extreme snowmobiling country, but it is a highly popular area. Of critical concern is an encroachment of the land near FS Rd 1640. While the road itself will remain outside of the proposed boundaries, it will mean that all riding to the view point ÔÇ£at roadÔÇÖs endÔÇØ will only be allowed on the roadway (with standard buffers, of course). Our biggest concern with this closure is, if RWAs will be managed as de-facto Wilderness, that compliance to the revised boundaries will be problematic. Additionally, the majority of the existing boundaries already appear to run along manageable ridge lines.
I know this is getting long, but there really is more worthy important information to share with youÔÇª.
A little explanation and commentary of specific management areas that are deemed unacceptable for Motorized Use (winter), per the proposed action on page 81:
1A Congressionally Designated Wilderness Areas ÔÇô Currently 730,886 acres – no explanation needed. However, an interesting idea was clarified by the Wallowa-Whitman Forest Supervisor, Steven Ellis. When asked about how or if a Wilderness Designated boundary could be moved inside the current boundary, he indicated that he couldnÔÇÖt imagine how that would be possible, and if it was, then it would only happen if a corresponding boundary was extended beyond the current boundary. In essence, there is clearly a no-net loss plan when addressing Wilderness. ItÔÇÖs too bad that a no-net loss plan does not exist for recreation!
1B Preliminary Administratively Recommended Wilderness Areas ÔÇô This is land that is pulled from the existing inventory of areas with wilderness potential* (Appendix C of the current Forest Plans). There is a review process and the Regional Forester makes a recommendation.
*A map of the 2008 Inventory for Areas with Wilderness Potential is available here:
The planning team published their Wilderness Need Evaluation document and you can view it here:
The current practice by the Forest Services in Region 1 (our forests are in Region 6) is to manage these areas as if they had already been designated Wilderness by Congress. So our question to the planning team, was, ÔÇ£How does the FS in the Blues intend to manage areas classified as an RWA?ÔÇØ They would not come right out and say that snowmobiling wouldnÔÇÖt be allowed. So, we pressed further and we claimed that if snowmobiling had been happening on these tracks of land, and the land was still found to meet the wilderness quality criteria, essentially, that snowmobiling did not reduce or impact wilderness qualities, then why would snowmobiling be excluded under a RWA? While they did concede that they could see our point, they were not willing to provide an answer either way. Either way, SAWS does not want to see more RWAÔÇÖs, because that is one step closer to designated wilderness
There is some congressional pressure to change the way RWA are managed within our forests. You can read more about that at Blue RibbonÔÇÖs website: http://www.sharetrails.org/releases/?story=695&filter=media Only Greg Walden, Representative, District 2, signed the letter sent to Tom Tidwell, Chief, United States Forest Service. The letter urges Mr. Tidwell to not use his power or the power of his agency (USFS) to usurp Congressional authority by allowing management of RWA as de-facto Wilderness.
1C Wilderness Study Area ÔÇô Only one area noted on the map. ItÔÇÖs located on the south eastern edge of the Hells Canyon Recreation area. SAWS is opposed to new proposed WSAÔÇÖs.
2A Designated and Eligible Wild and Scenic Rivers ÔÇô No comment.
2B Research Natural Areas ÔÇô There is 13,326 acres of new RNAÔÇÖs proposed. (See page 72 of the proposed action document for a table.) Per the table there are 5,499 acres in Malheur, 919 acres in Umatilla and 6,908 acres in Wallowa-Whitman. Because these are stated to be managed for ÔÇ£no motor vehicle useÔÇØ, SAWS opposes these new RNAÔÇÖs. Please note that some of the areas which are identified on the planning revision map show several RNAÔÇÖs within the Wilderness boundaries.
2E Historical Areas ÔÇô No comment.
2I Starkey Experimental Forest and Range ÔÇô No comment.
2J Municipal Watersheds ÔÇô No comment.
2K Riparian Management Areas ÔÇô The currently available maps and documents do not indicate any of these areas in the Blue Mountains.
3A Non-motorized Undeveloped ÔÇô Revision Team members indicated that no new areas of this nature are proposed. Additionally, no changes are planned for areas currently managed under this designation.
RECOMMENDATIONS FOR COMMENTS
The following is an excerpt directly from the FS website:
ÔÇ£All comments are read and considered, but only substantive comments that are within the scope of forest plans are useful in designing alternatives to the proposed action. So how do you make a substantive comment about forest plans? Tell us what you like about the proposed action and why, what we left out that you would like to see in the revised forest plans, or what you think should be changed and why.ÔÇØ
For more general comment guidance, please visit their website:
Please ensure that you have a thoughtful and unique opening paragraph. Any comments provided by form letter will be counted as one comment ÔÇô regardless of how many of the letters they receive. DonÔÇÖt forget to provide your name, phone number and mailing address.
In addition to personal comments, SAWS encourages you to include some or all of the following points in your comment letter:
- The FS has stated that the proposed RWAÔÇÖs are a result of the need for better boundaries. The stated intent at the Portland public meeting was they are moving them to align with geographic markers ÔÇô ridge, creeks, etc., for ease of enforcement and management. However, SAWS feels that if the FS could simply provide GIS files that snowmobilers could download to GPS units then we would all know where the boundaries are and there would be no need to move boundaries. We would like to encourage the FS to use the advance technologies already used by snowmobilers, hunters and hikers in the management of existing areas, without the unnecessary creation of new areas.
- The RWA near the NF of the John Day Wilderness and the Strawberry Wilderness could all but eliminate tourism to the towns of John Day and Sumpter during the winter months. This should be show-stopper. OregonÔÇÖs economy is one of the worst in the nation and is showing no signs of immediate improvement. Eliminating a key tourism industry for several towns to simply make the management of a boundary easier seems unethical and of questionable logic.
- Wilderness is forever. Per Forest Supervisor, Steven Ellis, there is a no-net loss policy on Wilderness. Once land has been Congressionally designated as Wilderness, any recreational and tourism revenues generated by the excluded forest users ÔÇô mountain bikers, motorized users, dispersed RV campers, etc., will be lost forever as well. We predict this loss in tourism dollars to be felt the most during the winter months ÔÇô due to the loss of snowmobiling. Cross-country skier visits to these forests is not likely to increase with additional Wilderness areas available, but snowmobiling visits will most definitely decline ÔÇô as will the year-round economic stability of several communities.
- Snowmobiling does happen on groomed trails, but the true and enduring value of snowmobiling is in our ability to ride cross-country. To travel across the forests ÔÇô without the limitation of trails, intersections, or signage. To explore and discover the back country when it is enveloped in a blanket of white. When asked to provide maps of our riding areas, our best response is look at a map and treat anything in Oregon, above 3000ÔÇÖ, as our riding area. It is our wish to have the forests within The Blue Mountains to provide and support the recreation of snowmobiling ÔÇô on ALL forest lands that are not designated as Wilderness or watersheds.
- When referencing science, we ask that you include in your analysis the multitude of studies and reports that specifically address snowmobiles. Including, but not limited to, Musselman 2007 (impact to water quality); Response of White-Tailed Deer to Snowmobiles and Snowmobile Trails in Maine, conducted by wildlife scientists for the Maine Cooperative Wildlife Research Unit and the Maine Department of Inland Fisheries and Wildlife; Michigan DNR report from May 2005 (snowmobiling and wolves); and to recognize that snowmobiles traveling on trails or cross country, with adequate snowfall, leave behind no evidence of their presence once the season changes and the snow melts. Often, evidence of a snowmobileÔÇÖs presence will disappear within hours ÔÇô as quickly as the snow falls.
- The Multiple-Use Sustained-Yield Act of 1960 declares, ÔÇ£That the purposes of the national forest include outdoor recreation, range, timber, watershed and fish and wildlifeÔÇØ. We do not believe that the term outdoor recreation was intended to exclude winter over-the-snow recreation. With that point in mind we strongly encourage the development of an alternative that includes no net loss to currently available snowmobile trails and acreage in The Blue Mountains.
WeÔÇÖd like to wrap up this Alert with the following quote by Maureen Dowd:
“The minute you settle for less than you deserve, you get even less than you settled for.”
The irony of quoting a liberal journalist in this Alert is not lost on us, but the words are very accurate for this scenario. If you feel that 16,350 acres is not too much to give away now, we suspect that significantly more than 16,350 acres will be at risk before this is all said done.
SAWS expects that the FS will be under a great deal of pressure to expand wilderness ÔÇ£protectionsÔÇØ during this planning process. We encourages you to ask questions, write your comment letters, and then stand by prepared to write even more letters to protect our continued access to the forests of the Blue Mountains.
Susie Rainsberry & Todd White, Oregon SAWS Representatives
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