SAWS Alert: Blue Mountain Forest Plan Revision - 16,350 Additional Acres Proposed For Recommended Wi

Comments due: May 28, 2010

E-mail: blue_mtn_planrevision@fs.fed.us

Online Comments: http://www.fs.fed.us/r6/uma/blue_mtn_planrevision/proposedaction-comments.shtml

Mailing address:

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/

Map: http://www.fs.fed.us/r6/uma/blue_mtn_planrevision/proposedaction/BMFPR-PA-Management-Areas-map.pdf

Introduction

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 "new" proposed closures as related to snowmobile access.

If you are also a motorized wheeled-user, a mountain biker, RVer, miner, property owner, etc., then you are strongly encouraged 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 ("MA") that do not allow snowmobiling, for example the 730,886 acres of existing designated Wilderness (MA=1A), SAWS is primarily going to address issues as related to Recommended Wilderness Areas ("RWA"). There is another MA that is also an issue as well, the 21,213 acres defined as Research Natural Areas ("RNA"). The plan for management of RNAs (MA=2B) states "G-80 - Motor vehicle use should not be authorized or allowed within RNAs."

In terms of the process, 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. Here's the land, now how do we want to slice and dice it up into management areas to support the "needs," wants and desires of interested parties and also follow Forest Service ("FS") rules and regulations. This part of the planning is not designed to address specifics within each of the MAs, but to determine how certain MAs, from the previous plans, need to be changed and if new MAs 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 ("DEIS") 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. 

OregonWild (OW) reports that "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."

Oregon State Snowmobile Association's 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 "the hill" is the same as OW's; "There is not enough Wilderness in Oregon.  The current levels are unacceptable." This consensus comes from names you are probably familiar with: Senator 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, "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 capacity."  (page 33 of the Wilderness Need Evaluation). As a result of the Forest Service's 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 percent of forest recreationists who 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 are 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:
http://www.fs.fed.us/r6/uma/blue_mtn_planrevision/proposedaction/PARWA_NFJohnDay.pdf

NF Umatilla RWA Map:
http://www.fs.fed.us/r6/uma/blue_mtn_planrevision/proposedaction/PARWA_NFUmatilla.pdf

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 (7080 feet), Huckleberry Mountain, Fox Point (6800 feet), Bald Knob (6529 feet) 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: http://www.fs.fed.us/r6/uma/blue_mtn_planrevision/proposedaction/PARWA_EagleCap.pdf

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 "at road's end" 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.

Malheur RWA Map:  http://www.fs.fed.us/r6/uma/blue_mtn_planrevision/proposedaction/PARWA_StrawberryMt.pdf

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 - 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 couldn't 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. It's too bad that a no-net loss plan does not exist for recreation.

1B Preliminary Administratively Recommended Wilderness Areas - 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: http://www.fs.fed.us/r6/uma/blue_mtn_planrevision/proposedaction/PotentialWildernessAreas_36x38.pdf 

The planning team published their Wilderness Need Evaluation document and you can view it here: http://www.fs.fed.us/r6/uma/blue_mtn_planrevision/proposedaction/Wilderness%20Need%20Evaluation.pdf

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, "How does the FS in the Blues intend to manage areas classified as an RWA?" They would not come right out and say that snowmobiling wouldn't 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 RWAs, 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 BlueRibbon's 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 - Only one area noted on the map. It's located on the south eastern edge of the Hells Canyon Recreation area. SAWS is opposed to new proposed WSAs.

2A Designated and Eligible Wild and Scenic Rivers - No comment.

2B Research Natural Areas - There are 13,326 acres of new RNAs 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 "no motor vehicle use," SAWS opposes these new RNAs. Please note that some of the areas which are identified on the planning revision map show several RNAs within the Wilderness boundaries.  

2E Historical Areas - No comment.

2I Starkey Experimental Forest and Range - No comment.

2J Municipal Watersheds - No comment.

2K Riparian Management Areas - The currently available maps and documents do not indicate any of these areas in the Blue Mountains.

3A Non-motorized Undeveloped - 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:

"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."  

For more general comment guidance, please visit their website: http://www.fs.fed.us/r6/uma/blue_mtn_planrevision/documents/HowDoIMakeCommentsThatGetUsed.pdf

Please ensure that you have a thoughtful and unique opening paragraph. Any comments provided by form letter will be counted as one comment-regardless of how many of the letters they receive. Don't 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 RWAs 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-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 advanced 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 a show-stopper. Oregon's 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-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-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, 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 without the limitation of trails, intersections or signage. To explore and discover the backcountry 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 3000 feet as our riding area. It is our wish to have the forests within the Blue Mountains to provide and support the recreation of snowmobiling 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 snowmobile's presence will disappear within hours-as quickly as the snow falls.

• The Multiple-Use Sustained-Yield Act of 1960 declares, "That the purposes of the national forest include outdoor recreation, range, timber, watershed and fish and wildlife." 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.

Conclusion

We'd 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 "protections" 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.