Proposed Preferred Alternative for Tahoe National Forest Over-Snow Vehicle Use Designation

Proposed Preferred Alternative for Tahoe National Forest Over-Snow Vehicle Use Designation The following narrative and accompanying maps describe and depict elements of a preferred alternative aimed at minimizing impacts to sensitive wildlife, watersheds, soils, and wilderness-quality lands and conflicts between motorized and non-motorized winter recreational uses. The proposed alternative incorporates the best available scientific information, best management practices, site-specific information, and applicable regulatory requirements under the new over-snow vehicle (OSV) rule, Executive Orders 11,644 and 11,989, and other relevant laws and policies. We encourage the Forest Service to incorporate the elements of this alternative into its proposed action/preferred alternative. Snowlands Network and Winter Wildlands Alliance also have submitted a proposed alternative that focuses primarily on non-motorized, backcountry recreation and minimizing conflicts between recreational uses. Snowlands alternative complements our alternative, and we encourage the Forest Service to incorporate the elements of both into its proposed action/preferred alternative. I. Areas Designated Closed to OSVs Below we identify a range of forest resources that are adversely affected by OSV use. To minimize impacts to those resources as required under the executive orders the preferred alternative should close the areas surrounding these resources to OSV travel. The resources and areas identified below may in some instances overlap with each other or with existing or proposed closures included in the Tahoe s proposed action. In addition, they are not comprehensive, and the agency also must close other areas identified through the NEPA process and application of the minimization criteria, where OSV travel would not minimize impacts to forest resources or conflicts between recreational users. To the extent the Forest Service intends to designate any of the areas described in this section as open to cross-country OSV travel, it must (as with any and all designation decisions) show in the record how those designation decisions minimize impacts to the relevant resources. Similarly, to the extent the forest intends to designate OSV routes in those areas, it must (as with any and all route designation decisions) show in the record how those individual route designations minimize impacts to the relevant resources. Approximately 109,808 acres of the forest located in designated wilderness, semi-primitive nonmotorized areas, and Research Natural Areas already are closed to OSV use and would remain closed under the proposed action. In addition, the proposed action identifies three areas covering approximately 3,821 acres that would be closed to OSV use to protect winter recreation opportunities (High Loch Leven), cultural resources (Robinson Flat Cultural), and watershed (Independence Lake Donated Parcels). We support these existing and proposed closures and believe they are necessary to comply with applicable law and policy. Nevertheless, they would leave 80% of the forest open to cross- 1

country OSV travel and are wholly inadequate to protect forest resources and satisfy the Forest Service s duty to designate only those areas that will minimize impacts. A. Designated Wilderness The Wilderness Act requires the Forest Service to manage designated wilderness areas to preserve their wilderness character and prohibits motorized and mechanized travel. 16 U.S.C. 1133(b)-(c). In the 1984 California Wilderness Act, Congress designated 18,705 acres of the Granite Chief Roadless Area as wilderness (MA 080). 1 The area includes glacier carved valleys, red fir forests, granite formations, and pristine mountain meadows. OSV travel is prohibited in this area by law. B. Citizen-proposed wilderness Outside designated wilderness, national forests often include hundreds of thousands of acres of additional roadless and wilderness-quality lands. These lands provide a host of environmental and social benefits including clean air and water, critical wildlife habitat, climate refugia, and opportunities for primitive, non-motorized forms of recreation and serve as the cornerstones for ecological integrity, conservation biology, and climate change adaptation in our national forests. 2 Given their importance, a number of laws and policies obligate the Forest Service to consider managing these lands for conservation purposes and to preserve their wilderness character and associated benefits. 3 The Tahoe National Forest includes a number of roadless areas that have been and will continue to be proposed for wilderness designation. In particular, the areas identified below were part of the California Wild Heritage Bill of 2002. To preserve their suitability for potential future wilderness designation and minimize impacts to the rich wildlife, watershed, and other resources within their boundaries, these areas should be closed to OSV travel. 1. GROUSE LAKES 1 References to management areas (MAs) refer to the 1990 Tahoe National Forest Plan. 2 See, e.g., 66 Fed. Reg. 3244, 3245-47 (Jan. 12, 2001) (preamble to Roadless Area ConservationRule describing host of key ecosystem and other services of roadless forest lands); The Wilderness Society, Transportation Infrastructure and Access on National Forest Lands and Grasslands: A Literature Review (May 2014) (describing the values of roadless lands and the impacts of roads and access allowed by road networks to terrestrial and aquatic systems) (Attachment 1). 3 See, e.g., 36 C.F.R. 219.7(v) (as part of forest planning process, agency must [i]dentify and evaluate lands that may be suitable for inclusion in the National Wilderness Preservation System and determine whether to recommend any such lands for wilderness designation ); 36 C.F.R. 219.10(b)(iv) (forest plans must provide for... management of areas recommended for wilderness designation to protect and maintain the ecological and social characteristics that provide the basis for their suitability for wilderness designation ); 36 C.F.R. 294.12 &.13 (Roadless Rule prohibitions on road construction and timber harvesting designed to protect the values of inventoried roadless areas). 2

Approximately 90% of the 17,280-acre Grouse Lakes area (MA 041) is managed for semi-primitive nonmotorized recreational opportunities and closed to OHV travel as a Vehicle Control Area. The hallmark of the Grouse Lakes Area is its great variety of geology, topography, scenery, diverse environmental communities and the remains of man's early explorations that include ancient Indian petroglyph sites. All the streams in the area are white water streams with numerous cascades and small waterfalls. Bald eagle, goshawk, and marten are found here. 2. CASTLE PEAK 16,250-acre Castle Peak (MA 044-10,784 acres, MA 033-4,932 acres) is a roadless area proposed for wilderness north of Castle Pass extending near Perazzo meadows. The Pacific Crest Trail, which is already closed to motorized and mechanized vehicles, goes through this area, and it leads to the Peter Grubb hut, a popular cross-country ski destination. Independence Creek, a proposed wild and scenic creek, begins in this area and is home to the only known spawning area for native Lahontan trout. The area also includes Perazzo Canyon Creek, a potential wild and scenic creek, which leads to Perazzo meadows, a nesting area for California endangered willow flycatchers that forage within the proposed wilderness. The Castle Valley portion of the proposed wilderness has been closed to OSV since 1981. 3. DUNCAN CANYON 2,880-acre Duncan Canyon (MA 091) is one of the very last remaining examples of untouched, old growth mixed conifer forest. Nearly all of the mid-sierra forests in this 5000 to 7000 foot altitude range have been severely impacted by logging and aggressive fire suppression. Logging was prevented in the canyon following the 2001 Star fire, except hazard trees along a popular running trail. Seven species of birds and four species of mammals found in Duncan Canyon are considered threatened, of special concern, or sensitive by the U.S. Fish & Wildlife Service, the California Department of Fish & Game, and/or the Forest Service. These include California spotted owl, northern goshawk, Sierra Nevada red fox, Pacific fisher, and American Marten. Even that most rare and elusive of Sierra carnivores, the wolverine, has been found in this area in the recent past. 4. NORTH FORK AMERICAN The North Fork American (MA 076, MA 081, MA 084, MA 082, MA 085) is an unroaded, 20,480-acre area encompassing the North Fork of the American River, a federal Wild & Scenic River and a Blue Ribbon Wild Trout stream. The American River hiking trail runs for half of the proposed wilderness. Its steep canyons, deep pools, cold rivers and old growth forests (proposed for Late Succession Emphasis in the 1996 Sierra Nevada Ecosystem Project report (a scientific review of the remaining old growth in the national forests of the Sierra Nevada provide habitat for Peregrine Falcon, California Spotted Owl, and Northern Goshawk. Sugar Pine Point RNA is within the area. 5. BLACK OAK The 12,160-acre Black Oak proposed wilderness (MA 087, MA 092, MA 098) is dominated by the North Fork Middle Fork American River, which consists of the river canyon and a few tributaries such 3

Screwauger Canyon Creek. The Forest Service found the river canyon outstandingly remarkable for its botanical values, and the river and Screwauger Canyon were each found eligible for protection under the Wild and Scenic Rivers Act. Grouse Falls within this area is a Plan designated Special Interest Area. The proposed wilderness includes key wildlife habitat, with confirmed California Spotted Owl and Northern Goshawk inhabitants, bald eagle nests, and habitat for Pacific Fisher, Pine Marten, and Sierra Nevada Red Fox. 6. GRANITE CHIEF Western additions of 4,480 acres to the Granite Chief Wilderness Area in the Mt. Mildred area (MA 083) would provide additional access to the existing wilderness. Streams in this area such as River Creek feed the Middle Fork American River. C. Inventoried Roadless Areas In addition to and including the citizen-proposed wilderness areas described above, the Tahoe National Forest includes 146,761 acres of Inventoried Roadless Areas (IRAs) under the 2001 Roadless Area. To protect these areas critical ecological and social benefits, they should be closed to OSV travel. These management areas include Bald Mountain, West Yuba, and East Yuba. Note: The 1992 LMP refers to the Lakes Basin area (552 acres) as roadless, but does not show it on their 2001 map. Also, the Middle Yuba was inventoried under RARE I, but not RARE II. D. Research Natural Areas and other experimental areas Research Natural Areas (RNAs) are physical or biological unit[s] in which current natural conditions are maintained insofar as possible... by allowing natural physical and biological processes to prevail without human intervention. Forest Service Manual (FSM) 4063.05. RNAs are designed to, among other things, form a national network of ecological areas for research, education, and maintenance of biological diversity and serve as reference points for research and monitoring of natural processes, long-term ecological changes, and management techniques. FSM 4063.02. To satisfy these objectives, the following RNAs on the Tahoe National Forest should be closed to OSV travel: 1. Babbitt Peak The 1,747-acre Babbitt Peak RNA (MA 016) encompasses large and geographically isolated stands of Washoe Pine, among other distinctive features (http://www.fs.fed.us/psw/programs/rna/gtr_chapters_pdf/babbitt_peak_rna.pdf). 2. Sugar Pine Point The 640-acre Sugar Pine Point RNA (MA 085) provides numerous examples of the dynamics of mixed conifer forest succession (http://www.fs.fed.us/psw/programs/rna/gtr_chapters_pdf/sugar_pine_point_rna.pdf). 3. Lyon Peak/Needle Lake 4

The 700-acre Lyon Peak/Needle Lake RNA (MA 100) includes stands of mountain hemlock and other undisturbed plant communities, provides habitat for northern goshawk, Marten, wolverine, and Sierra Nevada red fox, and archeological resources. In addition, the higher elevations of the RNA include isolated peaks, rock walls, small cirques, talus slopes, and rocky basins, as well as the distinctive Lyon Peak/Needle Peak ridgeline. Needle Lake, a subalpine lake sculpted from glacier ice, is just below Needle Peak (http://www.fs.fed.us/psw/programs/rna/gtr_chapters_pdf/lyon_peak_needle_lake_rna.pdf). 4. Onion Creek Experimental Forest In addition to RNAs, we recommend that other experimental areas managed to protect their resource values be closed to OSV use. The 2,846-acre Onion Creek Experimental Forest (MA 075) Research Station studies the interrelationships between water, plants, soils, and climate with available historic climatic and hydrologic data, and provides pristine forest conditions with limited roading and historic management actions. C. Special interest areas (SIA) The Tahoe National Forest includes a number of special interest areas designated in the forest plan to preserve their unique and outstanding features and resources. SIAs are established to protect special or unique geologic, ecologic, or cultural features. Management of these areas must be consistent with the purposes for which they were designated, and OSV use should be prohibited. 1. Placer County Big Tree Grove Botanical Area (MA 107, 346 acres) This unique grove of giant sequoias represents the northern-most natural occurrence of the species in the Sierra Nevada. 2. Devils Postpile Geological Area (MA 014, 69 acres) This area features a large vertical pillar of basalt rock rising above the surrounding landscape. 3. Glacier Meadow Geological Area (MA 072, 84 acres) This area features a distinctive and unusual glaciated landscape of scoured and polished granite overlain by large boulders. 4. Grouse Falls Scenic Area (MA 104, 220 acres) This area has one of the highest cascading falls in California, 5. Sagehen Headwaters Ecosystem Study Area (MAs Sagehen 043 & Sagehen Basin 036, 79 acres) This area is located in a glaciated cirque basin and noted for its rich diversity of plant and animal species. 6. Meadow Lake Cultural Area (MA 037, 58 acres) 5

This area contains the remnants of the former boom-and-bust gold mining town of Summit City, as well as extensive evidence of prehistoric use. 7. Mason Fen Ecosystem Study Area (MA 036, 30 acres) This area contains large minerotrophic peatland (fen), springs, and spring habitats, and is used for current research. 8. Independence Zoological Area (MA 035, 2,093 acres) This area was designated to protect native Lahontan trout in Independence Creek. D. Designated and proposed Wild and Scenic River corridors Congress enacted the Wild and Scenic Rivers Act in 1968 to protect free-flowing rivers and streams with outstandingly remarkable scenic, recreational, geologic, fish and wildlife, historic, cultural or other similar values... for the benefit and enjoyment of present and future generations. 16 U.S.C. 1271. Agencies must manage rivers included within the National Wild and Scenic Rivers System or being considered for inclusion to safeguard their special character. Id. 1283(a). The following river segments are federal or state Wild and Scenic Rivers, with a ½-mile corridor of management protection, or have been proposed for wild and scenic designation. OSV travel should not be allowed within those corridors to safeguard the rivers outstanding values and riparian areas. 1. North Fork, American River In 1978, Congress designated approximately 38 miles of the North Fork of the American River as a Wild and Scenic River due to its outstanding scenery, remote recreation opportunities, outstanding water quality, and historic gold mining values. 2. Lower Fork, South Yuba River In 1999, the California legislature designated the Lower Fork of the South Yuba River (MA 042) as a California Wild and Scenic River. With its gushing waters, deep emerald swimming holes and forested natural beauty, the river is central to the lives of many Nevada County residents, who seek quiet recreation in its natural beauty. 3. California Wild Heritage Bill creeks and rivers a. Sagehen Creek This creek was recommended for wild and scenic designation in the Forest Service s 1999 Eight Eastside Rivers ROD. It has Outstandingly Remarkable values in the form of fens, two class I threatened or endangered species, and unique wildlife values. b. Upper Independence Creek 6

The Forest Service s 1999 Eight Eastside Rivers ROD found that this creek (MA 035) has outstanding remarkable values, but did not recommend it for wild and scenic designation because the entire upper watershed was designated as an SIA, and thus would be protected well beyond the half-mile W&S corridor. c. Downie River and tributaries As described in the California Wild Heritage bill, this potential wild and scenic river system is described in detail in the 2002 Boxer Bill and includes portions of the Downie river and its tributaries such as Empire creek, Lavezzola creek, and Paulie creek. The Downie River, Empire Creek, Lavezzola Creek and Pauley Creek are beautiful and valuable streams surrounded by old-growth and ecosystem values, and provide clear flowing water to the North Fork of the Yuba, a clean drinking water source of the community. E. Areas of high value for non-motorized recreation Noise, air quality, viewshed, and other impacts associated with OSV use can greatly diminish the experience of non-motorized users. 4 To satisfy the executive order requirement to minimize those conflicts, areas of high value for non-motorized recreation should be closed to OSV travel. The proposed alternative submitted by Snowlands Network and Winter Wildlands Alliance focuses on identifying these areas. These areas may occur across all Recreation Opportunity Spectrum (ROS) categories, including roaded natural, rural, and urban areas that may have a wholly different character in the winter and provide excellent winter recreation opportunities. These high-value non-motorized areas on the Tahoe include: Expansion of the existing OSV closure at Castle Peak, Andesite Ridge, and Basin Peak to address the high demand for winter non-motorized recreation opportunities at Donner Summit Expansion of non-motorized areas immediately south of Donner Summit, in the vicinity of Benson Hut Creation of a new non-motorized area around Loch Leven Lakes near Donner Summit OSV closures and/or restrictions that promote shared use and non-motorized recreation opportunities in the Sierra Buttes and Lakes Basin near Bassetts and Sierra City In addition to specifically identified high-value areas, OSV travel should be prohibited on the approximately 119,100 acres of the Tahoe National Forest categorized on the ROS as primitive or semiprimitive non-motorized. While the ROS categories are not designed to address winter recreational uses, they nonetheless identify areas of the forest with opportunities for high-quality non-motorized forms of recreation. To protect those opportunities and minimize user conflicts, these areas should be designated closed to OSV travel. 4 See Appendix 2, Snowmobile Best Management Practices, pp. 5-8. 7

Finally, the Forest Service should provide adequate buffers around important non-motorized areas and trails where OSV travel is prohibited to minimize noise and other impacts. On the Tahoe, this includes a buffer around the Pacific Crest Trail. F. Important wildlife habitat OSV use can have significant adverse impacts on a number of wildlife species. 5 To satisfy the executive order requirement to minimize harassment of wildlife and disturbance to wildlife habitat, important wildlife habitat which may include nesting and denning areas, ungulate winter range, migratory corridors, watersheds/waterbodies containing important spawning habitat, designated or proposed critical habitat, and habitat identified in a recovery plan should be closed to OSV travel. Some of these areas on the Tahoe are identified below. 1. Deer winter range and emphasis areas Ungulates such as deer and elk can be significantly adversely affected by OSV use, particularly in sensitive winter range. 6 It has been widely documented that snowmobile activity disturbs wintering ungulates through physiological stress resulting in increased movements and higher energy expenditures 7. It is critically important to restrict OSV activity in deer winter range and emphasis areas in order to protect these populations. We suggest closing these areas to all winter motorized activity or limiting OSVs to designated routes if full closure is not possible. 2. Denning sites or suitable habitat for carnivore such as wolverine, marten, and Sierra Nevada red fox Denning sites and suitable winter range for these carnivores should be carefully monitored and closed to OSV use as necessary to minimize impacts to the species and their habitats. In addition, OSV designation decisions should analyze and minimize impacts to small mammals that serve as prey for these carnivores. Wolverine There is occurrence data for a single California wolverine on the Tahoe National Forest. This rare and exceedingly far-ranging species is sensitive to human disturbance and requires large, connected, and relatively undisturbed blocks of habitat. 8 While wolverines are extremely rare in California, evidence of the presence of at least one animal on the Tahoe NF indicates connectivity between the western Rocky 5 See Appendix 2, Snowmobile Best Management Practices, pp. 9-12. 6 See Appendix 2, Snowmobile Best Management Practices, p. 11. 7 Canfield et al. 1999. Effects of recreation on Rocky Mountain wildlife: A review for Montana. Montana Chapter of the Wildlife Society, pp 307. 8 See Appendix 2, Snowmobile Best Management Practices, p. 10. 8

Mountains and the Sierra Nevada 9, and the California Wolverine is a Region 5 Sensitive Species. Although it is likely that there is currently only one wolverine in California, the possibility remains that more could follow. Given the possibility of wolverines in this landscape, and the long-term impact of any travel plan, it is important to consider how OSVs may impact this species. There is scientific uncertainty about the exact effects of snowmobiles on wolverines. However, compelling anecdotal evidence suggests snowmobile use displaces wolverines and may reduce reproductive success, especially when it occurs within potential wolverine denning habitat. American Marten American marten currently is a management indicator species on the Tahoe, as well as a California Species of Special Concern. As marten are active throughout the winter and present in areas where snowmobiling occurs, it is important for the Tahoe National Forest to take steps to mitigate OSV impacts on this species. Martens travel on top of the snow but also utilize the subnivean zone, especially during very cold weather. Limiting the size of play areas, or restricting OSVs to designated routes, are two tools that can be used to protect subnivean habitat. We also recommend implementing trail closures or rerouting portions of trails within ¼ mile of marten den sites. In addition, we recommend limiting OSV activity within suitable marten habitat. Sierra Nevada Red Fox The Sierra Nevada red fox also is a management indicator species on the Tahoe, as well as a Forest Service Region 5 sensitive species, and a California threatened species. This species is found at or around 6,500 feet in elevation and prefers areas with forest cover 10. They avoid open areas and dense forests. Recent sightings have been concentrated in high elevation areas near Lassen Peak and Sonora Pass but the extent of their current distribution is unknown. While very little is known about this species, the travel planning process presents an opportunity to minimize impacts from winter recreation on Sierra Nevada red fox. 3. Threatened and endangered fish and amphibians Sierra Nevada yellow-legged frog, Mountain yellow-legged frog, and Lahontan cutthroat trout These three species are federally listed as endangered (Sierra Nevada and Mountain yellow-legged frogs) or threatened (Lahontan cutthroat trout) and the Tahoe NF must avoid negatively impacting these species when designating routes and areas that are open to winter motorized use. Although direct mortality to fish and amphibians from OSVs is unlikely, the indirect effects of OSV exhaust and associated pollutants pose a concern. Pollutants from snowmobile emissions are deposited upon and accumulate 9 Moriarty et al. 2009 Wolverine Confirmation in California after Nearly a Century: Native or Long- Distance Immigrant? Northwest Science 83: 154-162. 10 Perrine, et al., 2010. Sierra Nevada Red Fox (Vulpes vulpes necator) A Conservation Assessment. USDA Report 9

within the snowpack throughout the winter 11. During spring snowmelt these accumulated pollutants are released, causing elevated acidity levels in surrounding waterways and resulting in higher death rates for aquatic insects and amphibians. Additionally, we suggest closing all Sierra Nevada and Mountain yellowlegged frog habitat to OSV use if there is not sufficient snow to buffer vegetative habitat. 4. California spotted owl and goshawk Long-term exposure to vehicle disturbance (noise and vehicle movement) can have a deleterious effect on the reproductive success of forest raptors (e.g., California spotted owl, goshawk). 12 Consequently, we recommend maintaining a limited operating period (LOP), prohibiting OSV activity within approximately ¼ mile of the PAC during the breeding season (March 1 through August 31 for spotted owl; February 15 through September 15 for goshawk), unless surveys confirm that California spotted owls and/or goshawks are not nesting. Prior to implementing activities within or adjacent to a California spotted owl and/or goshawk PAC and the location of the nest site or activity center is uncertain, surveys should be conducted to establish or confirm the location of the nest or activity center. 5. Willow flycatcher The Willow Flycatcher, a California Endangered species, has declined precipitously in the Sierra Nevada since the middle of the twentieth century. Once considered common throughout much of the Sierra Nevada, the Sierra population was estimated to have dwindled to just 300-400 individuals in the late 1990s. The degradation of meadow habitat, such as along the Little Truckee river, is a major problem for the species and this arises from trampling by livestock, road construction, recreation activities, and climate change. G. Municipal watersheds OSVs release various pollutants into the snow, which accumulate and can be released during spring snowmelt as pulses into the soil, groundwater, and surrounding surface waters. 13 To safeguard drinking water supplies, municipal watersheds, including public and semi-public utility watershed lands, should be closed to OSV use and buffered as necessary to protect water quality. H. Other areas with sensitive or impaired resources Other areas with sensitive or impaired resources also should be closed to OSV travel to minimize impacts. Those areas and resources may include, for example, water bodies, wetlands, riparian areas, meadows, and alpine habitat, and they should be protected with buffers of at least 150 feet or of a sufficient size to minimize impacts to water quality, soils, vegetation, and wildlife. 1. Critical Aquatic Refuges 11 Ingersoll, G. 1998. Effects of snowmobile use on snowpack chemistry in Yellowstone National Park. 12 Hayward, et al. 2011. Impacts of acute and long-term vehicle exposure on physiology and reproductive success of northern spotted owl. Ecosphere. June 2001 Volume 2(6) 13 See Appendix 2, Snowmobile Best Management Practices, pp. 12-14. 10

2. Meadow Management Zones 3. Little Truckee River This area (MA Henness 018) is undergoing restoration. It is adjacent to Perazzo meadow, which is a nesting site for endangered willow flycatchers. 4. Other important river segments and riparian habitats a. Canyon Creek Canyon Creek provides habitat for California spotted owl and northern goshawk. The Forest Service s 1999 22 Westside Rivers Report and Record of Decision considered Wild and Scenic designation as the best management option to protect the outstandingly remarkable values of the 30 mile-long freeflowing river. b. North Yuba River The North Yuba River boasts outstanding fisheries, heritage resource values, and scenic and recreation values. Bald eagle uses the corridor, along with California spotted owl. The Forest Service s 1999 22 Westside Rivers Report and Record of Decision considered the North Yuba river as a worthy addition to the Wild and Scenic system. I. Low-elevation and other areas lacking reliable or adequate snowpack Subpart C recognizes that OSV designations are to be made where snowfall is adequate for that use to occur. 36 C.F.R. 212.81(a). Particularly with climate change already leading to reduced and less reliable snowpack, low-elevation and other areas that lack reliable or adequate snowpack should be closed to OSV use. An example would be Chalk (MA -065) where there is a key winter deer range, and California spotted owl PACs are in the area. To the extent those areas are not closed, minimum snow depth requirements must be enforced and monitored. II. Discrete, specifically delineated open areas Once the Forest Service has determined which areas should be closed to OSV travel to satisfy the executive order duty to minimize resource damage and user conflicts, it must determine which discrete, specifically delineated areas to designate as open to cross-country OSV travel. Those areas must be located to minimize environmental damage and conflicts with other recreational uses, and they must be smaller than a ranger district. Open areas should have easily enforceable boundaries using topographic or geographic features such as a ridgetop, highway, or watershed boundary. Where possible, open areas should be bounded by natural features (topography and vegetative cover) to provide visual and acoustic barriers. Finally, the Forest Service should consider other mitigation measures and best management practices to further minimize impacts associated with cross-country OSV travel, as described in more detail in section IV, below. 11

III. Route Designations Designated OSV routes also must be located to minimize resource damage and user conflicts. To satisfy that requirement, the Forest Service should make its route designations based on the following best management practices, which are addressed in the Winter Wildlands Alliance publication attached as Appendix 2: Locate designated routes away from the high-value and sensitive resource areas described above Not exceed motorized route density thresholds based on best available scientific information in suitable habitat for relevant wildlife Locate routes to maintain large un-fragmented, undisturbed, and connected blocks of habitat where OSV use is prohibited Allocate unplowed roads fairly between designated OSV routes and non-motorized routes closed to OSV use Where necessary to designate an OSV route through a non-motorized area, locate and manage the route to minimize disturbance by imposing speed and idling limitations and ensuring that use is restricted to the trail itself Locate routes designated within open areas especially groomed routes to minimize environmental damage and conflicts with other recreational uses IV. Other Mitigation Measures & Best Management Practices To further minimize impacts associated with area and route designations, the Forest Service should incorporate the following mitigation measures and best management practices into its OSV use plan, which also are addressed in Appendix 2: Encourage, incentivize, or require Best Available Technology for OSV noise and emissions controls, particularly in sensitive or high-conflict areas Where possible, designate separate trailhead/parking/staging areas for OSV open areas and high-demand OSV routes, and locate those areas away from the high-value and sensitive resource areas described above Clearly identified season of use restrictions based on wildlife needs, water quality considerations, average snow depth figures, and other relevant information, with those restrictions serving as bookends, and minimum snow depth requirements providing an additional limitation on use Require minimum snow depths of at least 12 inches for OSV travel on designated trails and at least 18 inches for off-trail OSV travel, or sufficient depth to protect water quality, soils, and vegetation. Minimum snow depths should be consistent throughout the region to avoid enforcement difficulties Ensure adequate design and maintenance of designated routes, including bridges, culverts, and roadbed to reduce hydrological and erosion impacts during spring run-off Restrict use by class or type of over-snow vehicle as necessary to minimize impacts Provide public education and outreach 12

Monitor and enforce closed routes and areas, seasonal restrictions, and minimum snow depths Establish an adaptive management framework that utilizes monitoring to determine efficacy of current management 13