Objection Reviewing Officer USDA Forest Service, Northern Region PO Box 7669 Missoula, MT 59807

Transcription

1 Objection Reviewing Officer USDA Forest Service, Northern Region PO Box 7669 Missoula, MT RE: Objections to the Draft Record of Decision and Final Environmental Impact Statement for the Bitterroot National Forest (BNF) Travel Management Planning Project dated April, The responsible official for this action is Julie King, Supervisor, Bitterroot National Forest. Due to dealing with a couple of deaths in the family, working full time, volunteering for the ON THE RIGHT TRAIL, the number of pages of the document, confusing maps and the length of time allowed we did not read the entire book. We fully endorse the Ravalli County Off Road User Association (RCORUA)/ Bitterroot Ridge Runners (BRR) objections along with the Blue Ribbon Coalition and the Montana Trail Vehicle Riders Association objections (we are members of all 4 organizations). Our comments will just address summer motorized travel. In our opinion the entire Final Environmental Impact Statement for the Bitterroot National Forest Travel Management Planning Project used flawed, inaccurate, skewed or deliberately misleading data! Apparently, with all the technology available, the BNF cannot even come up with the miles of roads, trails or acres involved as everything is approximately. In our opinion part of the reasoning behind the length of time it has taken to come out with the FEIS is so the BNF could close, decommission, destroy, or lose roads and trails without public comment. The first page of the document clearly states that the project is to address conflicts between motorized and non-motorized users, improve the quality of the recreational experience, and integrate resource considerations into the route system-change the existing motorized recreation designations to provide quality motorized recreation experiences while protecting natural resources and providing non-motorized recreation opportunities outside of Designated Wilderness. Also it is to ensure consistency with the 2005 Travel Management Rule. So who gets the quality of the recreational experience, definitely not the motorized community? On page 1.1 you state the National Forest System is not reserved for the exclusive use of any one group, nor must every use be accommodated on every acre;. Yet all the Alternatives for summer motorized use on roads (it also says trails but the data is falsified, as up until just recently all data for BNF states there is 26 miles of trails) gives the quite users 99.9% exclusive use of the approximately 850,626 Acres outside of Designated Wilderness (47%) (when using an average of 30 wide road/trails). The highest percent motorized use Alternative 3 is only % of the BNF outside of the DWA when using the 30 average with the data provided. Plus the Designated Wilderness was intentionally deleted from the project giving the impression (and skewed the data) to many that motorized and mechanical transport has much more acres to recreate on than quiet users. So on over 99.9% of the BNF the quiet users

2 cannot find a place to hike or ride their horses and not hear summer motorized use (which by the way is restricted to legal roads and trails, which I believe is never mentioned). On page 1-5 it mentions that the 2005 Travel Management Rule requires the designation of those roads, trails and areas that are open to motorized vehicles, using clear, nationally-standardized symbology, to be displayed on a motor vehicle use map. The BNF never has publicized a map with accurate and clear routes listed on it, the best map produced was the 1999 Revision. The 2005 Travel Map has many confirmed errors and is all but easy to read. Also it has been stated by other National Forest Officials that sometimes the maps are not produced as intended (examples: Beaverhead/Deerlodge errors in winter use areas & Salmon/Challis roads listed as closed to motorized use on the maps when they were intended to be open). If the map makers cannot follow the intentions of the officials and produce accurate maps, how is the public supposed to know what roads and trails are open or if they even exist. It also states that the FS expects to publish new maps annually with updated signs as necessary, yet when the errors are brought to the attention of the District Rangers or the Forest Supervisor, they say they can t do anything about them. Since the late 1960 s and early 1970 s the FS has deleted roads, jeep trails and even trails from the maps, sometime on the ground destruction of some of the roads has occurred or tank traps or gates at the beginning of the road were installed and miraculously the road or trail was no longer there (at least in the FS data base). The tables on page 1-6 and 1-7 are misleading as the fine print is often overlooked, and it is doubtful if any connector trails will ever be built. It also list roads as trails, which, in our opinion is deliberately misleading and skews the data. Many of the trails are not in existence and probably never will be due to lack of funding and the many current anti-motorized personal in the BNF, and they will not be included in the MVUM until NEPA is done (if ever). In the purpose and need for action, the second item listed is Improve the quality of the recreational experience. How can the recreational experience for motorized and mechanical means be improved when you are taking away the most scenic and enjoyable trail on the BNF (Trail 39). The quiet users have many other drainages to access the area or they can SHARE the trail. Very few quiet users use Trail 39, in the past 15 plus years of using Trail 39 we have met approximately less than 20 hikers on approximately the 45 to 50 times of riding the trail and maybe 15 horse users. Plus we and other members of RCORUA have spent many hours cleaning the water bars, sawing out the trail, hauling out trash and the water bars stored at the top of the trail for the BNF to use on other trails. Trail 39 has seen very little FS Maintenance due to the lawsuit filed by the Government Parasites Obstructionist Groups, so it has some erosion problems on it (as would any trail with little to no maintenance and moderate use). It is the only trail on the BNF that links Frog pond Basin, Copper Creek and Phillipsburg users to the East Fork of the BNF. Many of the motorized users travel over the trail during the summer and recreate in one or the other National Forest, if this trail is closed to motorize use and bicycles it would have economic impacts to the local communities and the disabled users. Nowhere, in the parts I read, does it mention the handicapped forest users, many of us are handicapped and use ATV s or UTV s as a means of access to our forest, we have talked to a lot of handicapped users that enjoy riding the

3 Chain of Lakes trail for the scenic views, the wildlife viewing (yes we get to see even Mountain Goats), access to Fish Lake and the hunting opportunities provided When you use flawed or junk science with biased personnel you get junk data. There has been studies that hikers and horses have more impact on the soil (compaction) than motorized users and other studies that motorized use has less impact on wildlife than quiet users. Motorized users don t eat the rare and sensitive plants, do not transport any more invasive/ noxious weeds than quiet users and their animals (both horses and dogs) and probably have less impact on cultural resources as less time is spent in the area. And if the factual information is used, motorized use would probably have less impact on the fisheries and water resources as well (as we are restricted to legal trails and roads, we have less access to streams and lakes and most of our trails are away from steams also). If motorized use is responsible for the spread of noxious weeds how did the Designated Wilderness Areas get the noxious weeds? 1.34 The BNF created the confusion of where and when motorized use can occur, the officials in charge at the time of the 2005 FVM publication admitted there were errors but claimed they could not release a corrected map until Travel Planning was done states unauthorized routes not engineered or constructed to FS standards, yet in our experience most unauthorized routes are actually old FS roads or jeeps trails from before 1964 and have been sustainable with little to no damage to the land. While the quiet users can make new trails next to streams and thru sensitive areas as they are allowed 100% access to the forest with no restrictions and these trails are not engineered or constructed to FS standards. I am not sure if RCORUA was provided a map by the FS as I used several maps I had for the club members to mark trails on and then transferred them to one map that was turned in to BNF. 1.4 The BNF has very limited timber management anymore and what it does do is often to the determent of the forest and public. Example: the current work being done in the McCart area of the East Fork, many of the healthy live trees are being removed leaving most of the dead trees and much of the debris is stacked near the dead trees so when it is burned it will undoubtedly climb the dead branches and create a forest fire. And this work is to provide fire safety for the communities, so much for common sense. Big Game security and Habitat is another misconception of the FS and the Fish and Game, closing roads and trails for elk security has done nothing, the elk have mostly moved closer to open roads and private ground. As a hunters for over 40 years (over 80 years together) we have seen this happen, we believe it is partly due to the predators and mostly due to lack of cover and food supply due to the let it burn policy the FS has used and fueled by the lack of Forest Management (thinning, logging and removing the dead and diseased trees).when there are no trees (black dead trees provide no shade) and only black scarred ground, the snow melts earlier and the run off is earlier and faster causing much sediment in our streams and rivers followed by algae growth for years. This is also bad for the fish as the riparian areas take decades to recover, many of the streams now dry up during the summer or the steam flow is low and with no cover on the banks the water heats up. The FS deemed the Sapphire WSA and the Blue Joint WSA unsuitable for Wilderness Designation years ago, the only reason they have not been removed is again the Obstructionist Government Parasites and their endless lawsuits and the lack of

4 Congress acting on it. When the Selway Bitterroot Wilderness Area was created Congress and the FS recognized that the Nez Pierce Road needed to be open to motorized use and would not harm the wilderness characteristics of the area, the same holds true with the trails existing in the WSA s, especially if some maintenance is allowed. Most of the Forest Plan Management Areas data in 1.4 is highly misleading and has skewed information Even though the geographic scope of the TMPP is described as outside of the DWA, the DWA s need to be considerate as it includes over 47% of the BNF exclusively for the use of quiet users, a very small percent of the population visit the DWA s. Chapter 2 again used skewed data and it seems like the ID Team had to start all over as BNF got a new Supervisor (during the 10 year process) that dictated that the IRA s and WSA s were to be considered as DWA s. On page 2-22 it states that motorized use could adversely affect Cultural Resources, in our 60 plus years of using BNF we have seen a lot of slob hikers and horsemen that do major damage to cultural sites and the forest but they are not restricted at all. 2.4 The BNF has very few qualified personal left, even all the District Rangers have jumped ship the last couple of years, two since the release of the FEIS. Many of the top jobs are held by acting personnel, which in many cases, due not have the experience or knowledge in the field they are acting in. The second paragraph says the emergency closures of roads, trails or areas is up to one year, but trail emergency closure has been at least 7 years with no reason except to protect a cultural site. Again the hikers and horsemen still have access to the trail with no restrictions, biased to say the least Is this not about the quiet users access to the trail heads. If the approximately 504 miles of roads that are currently open were closed, the vehicles the quiet users use to get to the trail heads, wilderness and camping or hunting spots would affect them as much as, if not more than the motorized community! Also the 3 rd paragraph contradicts itself, it says the elk populations have increased dramatically then later in parenthesis says until recently. If we are not mistaken the elk counts do not reflect a dramatically increase since 1987 and most of the population has moved to private lands and near public roads (several herds now live year round near Highway 93, but your data says they avoid open roads). We have seen a dramatic decline in Elk herds on the BNF since the fires of 2000 and increase in the destruction (decommissioning) of roads in the following years. 3.1 Maintaining roads: again before the Obstructionist Government Parasites started their endless lawsuits, when logging was allowed and profitable, the BNF was able to maintain the roads. The BNF had a lot of equipment and qualified operators that knew how to grade roads and the studies and science back then said that properly maintained roads produced less sediment and we never saw the washed out roads we now see. RCORUA members has contributed over 8000 hours of trail maintenance and cleanup since 2006 saving the BNF Thousands of dollars in man-hours, we even organized the removal of several cars from Gird Creek Area along with a 30 cubic yard dumpster of garbage that RCORUA members pulled out of the gullies. The BS about the BNF not having adequate tracking mechanisms in place when the roads were destroyed after 1990 is just another of the misleading information in the

5 FEIS. The BNF had a list of roads and trails (that was available to the public) listing all the roads and trails on the BNF and what use was allowed, and if we are not mistaken when a road was built it was added to the data base, when it was gated or had a tank trap installed the listing was changed in the data base. So did BNF conveniently lose the data or what? On Access Travel Management, from the table supplied of the 2576 miles of roads (approximately the miles of roads left on BNF open to motorized use) 1043 miles are closed to highway legal vehicles yearlong or over 40% and only less than 1% is open to all highway vehicles seasonally, where is the to provide quality motorized recreation experiences in this table. Land Management Project Planning and Minimum Transportation System looks like it may say some projects were not included in the Travel Management and minimum road analysis across the forest, does this not falsify some of the data used in the FEIS. Skimming thru the rest of the FEIS I did not see anywhere where Handicapped & elderly users were addressed, there are many handicapped & elderly ATV and UTV riders on the BNF. Some cannot use an ATV due to deformed or missing hands for fingers and have to use a UTV, yet the BNF just dismisses them as non-coincidental. They are just as important as the quiet users and many of them were disabled defending our country. However the main thing lacking in this document is the complete absece of "COMMOM SENSE". The map disc provided (separately) is very flawed and hard to read (maybe on purpose), it is hard to tell the difference between existing and proposed ATV Routes. Plus many of the ATV routes are actually existing roads. Just a couple of errors: Road/ATV is already decommissioned (destroyed) and is non-existent and goes thru private property but is shown as an existing ATV route. Jim and Marsha Waliser 199 Cordial Lane Hamilton, MT 59840