Response Written to Forest Service 9 14 2016
Jamie Kingsbury, Forest Supervisor
Objection Reviewing Officer
Mt. Baker – Snoqualmie National Forest
Attn. 1570 Appeals and Objections
2930 Wetmore Ave
Everett, WA 98201
objections-pnw-mtbaker-snoqualmie@fs.fed.us
Responsible Official, Erin Uloth
Mt. Baker District Ranger
Mt. Baker –Snoqualmie National Forest
810 State Route 20
Sedro Woolley, WA 98284.
Re: Objection to Upper North Fork Nooksack River Access Travel Management (ATM) Project.
Pursuant to 36 C.F.R Part 218.5 we file this objection to the draft decision for the Upper North Fork Nooksack Access and Travel Management Project (herein referred to as “Nooksack ATM”). The Nooksack ATM project is in the Mt. Baker Ranger District of the Mt. Baker – Snoqualmie National Forest near Glacier WA. We are in particular looking to keep open FS Road 31, 3160 and 3170 commonly referred to as Canyon Creek with references to “Bear Paw” and “Excelsior”
Maintaining road access provides an infrastructure to snowmobile in the National Forest that can be enjoyed and utilized for recreation and thereby contributes to local economies. As snowmobilers this area is of special interest to us!
Our objection is based on the Draft Decision Notice: Nooksack ATM’s failure to meet its goal. We maintain that the rationales for scheduled closures such as the justification that the ATM are flawed arguments. We question the justification that closing certain roads to the general public is necessary.
We believe in the scoping of ATM process there was confusion on impact of the ATM on roads 3160 and 3170. Without knowledge that a shift in forest access was being considered, we think snowmobilers had little chance to make initial comment and object.
1. Local volunteer organizations and Snowmobile clubs are willing to help with maintenance on these roads.
2. The effect on the rural community economy of losing major snowmobiling areas due to a bar on the ability to groom routes and hurt access has not been effectively evaluated and dealt with in this process.
3. This clearly contradicts the ability for snowmobilers to access one of the few Alpine areas outside of the Wilderness boundaries in the Mt Baker Snoqualmie Forest Plan,
We assert that snowmobiling on accustomed and traditional grounds is further secured by keeping 3160 and 3170 open for access and grooming.
4. Formal agreements with partners specifically the Whatcom Snowmobile Association in proposing to close FSR 3160 and 3170 is dismaying. To make a change without consulting a long-time formal partner demonstrates a lack of consideration and respect. Failure to refer to existing Forest Service documents demonstrates a lack of due diligence. It’s also dismaying that Forest Service does not recognize the contributions to effective road upkeep that the Club has played in obtaining past road maintenance grants for brushing, ditch work on FSRs 31 and 3160 and for culvert replacement on Road 31 at MP 8.50 and 8.735. The closure of Road 3170 does in fact remove access to Bear Paw Lake Trail No. 4430 which is in conflict with the statement in draft decision that asserts there will be no loss of access to official trails.
We believe that agreements made with Whatcom Snowmobile Association were recognized in environment assessment documents that were incorporated into the Forest Plan. Thus we think officers of the Whatcom Snowmobile Association need to be involved in any future written agreements. Relying on just one e-mailed inquiry and failing to follow up to establish affirmative contacts for discussion demonstrates a disregard for courteous, cooperative governance.
We snowmobilers endured a three year closure of this area from 2012 to 2015. We hoped this experience would lead to a more proactive approach to keep this open, instead of emergency reactive type mode of behavior. With outdoors recreation being a multi-billion dollar industry, upon which many rural communities depend, such decisions are critical for them.
We look forward to the Forest Service keeping FS31, 3160 and 3070 roads open for public use.
Sincerely,
will help as well. Ronald Reagan's administration worked for 8 years to undo the mistakes of the Carter years. We have not had a friend in the Executive branch for 8 years now.
