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Old 10-02-2008, 08:46 PM   #1 (permalink)
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Exclamation IMPORTANT! Writing Effective Comments

Here is how to write an effective comment for the TNF DEIS.

I will have multiple posts with sample comments and ideas on what to write on.

My personal goal is to submit 1 comment each day for the entire public comment period. While you do not have to get that extreme, I BEG you to at least submit some comments.

PLEASE READ THIS CAREFULLY!




When the Forest Service receives comments from the public, there are three categories: (1) non-issue, (2) significant issue, and (3) non-significant issue.
Here is an example of how this works:

1. Non-issue:

Writing a comment saying "The route closures in Tahoe are BS and I disagree with them". (This would be classified as a non-issue - it is a general statement and is not a specific comment related to the proposal and its effects)

If you just say that you disagree with the closures and that it is BS, it is a NON-ISSUE in the eyes of the FS. It's read, but tossed aside.

2. Significant Issue:

Specific comments regarding the proposal, specific disagreements with the proposal, not yet decided by law, regulation, or policy, etc.

If you give arguments and reasons as to why routes in TNF should remain open, attack the wording, the research, the assumptions, etc. in the DEIS, it is a SIGNIFICANT and SUBSTANTIVE comment. THIS IS THE TYPE OF COMMENT YOU WANT!!!

3. Non-Significant Issue:

I support the BRC proposed alternative, (This would be classified as non-significant - general support for another comment already provided - as mentioned many times, the Forest Service does not count votes)

If all you do is say you support an organization and it's stance and comments, your comment will be listed as a "non-significant" letter

Please note, the term "non-significant" does not mean that the comment is simply thrown out and disregarded. It is a bureaucratic term. The Forest Service MUST read, review, and consider all comments. All the more reason to flood them with comments! Make them work!


Form letters are usually listed as "non-significant" That's why it's taking me some time to work out the letter generator. I need to make it where I just give "suggestions" on what to write.

Your letters CAN make a difference!

Just one letter from a person here on Pirate literally saved 300 miles of routes in Eldorado National forest.

Other things to keep in mind:

1. You DO NOT need to be a land-use expert or guru to submit a comment! DO NOT just leave it up to those guys! Everyone can and should send in comments.

2. Just becuase a route is on the preferred alternative DOES NOT make it safe!! Remember that the "other side" will be sending in comments to CLOSE routes!


KURT

Pirate4x4.com Land-use Editor

All comments need to be e-mailed to:

tnf_rte_desig@fs.fed.us
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Old 10-02-2008, 08:54 PM   #2 (permalink)
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What to write:

#1 Comments on Specific routes

This will most likely be the most common comment. Pick a route that you and your family uses and ARGUE as to WHY that route should remain in the system. Give as many examples as possible as to WHY it should remain open. DO NOT just limit your use to four wheeling, do you use the route to hunt, hike, bird watch, fish, camp, gold pan, rock hound, geocache, view nature, play lawn darts etc.....

Here is an example used in Eldo's DEIS:

I am writing in regards to my concerns with the Eldorado National Forest DEIS, specifically route 9N12 and including the spur routes 9N12A, 9N12AN, 9N12B, 9N12C, 9N12D all of which are located off Silverfork road above Kyburz.

I have personally camped with my family and friends on this routes and spurs for many years and I know the area very well. These routes allow us to have access to dispersed, primitive camping opportunities without being on roads that have a lot of through traffic. The dead end nature of the spur routes leads to very quiet, peaceful and safe locations to camp with my family, which includes two very young children.

In the many years that I have spent in this particular area, I have never seen any maintance done to these roads, other than my own club clearing the routes of trees that had fallen in the winter. Even without maintance over all these years, there has been no degradation on the roads surface. Many of these spurs lead to scenic overlooks, starting points for hiking and hunting and bird watching. It would be a shame to lose any of these routes. These are dirt roads, which should be maintenance level 2 roads and open to all motor vehicles including green stickers.

Please have route 9N12 street legal and OHV usable, as well as spur routes 9N12A, 9N12AN, 9N12B, 9N12C, 9N12D added to the chosen alternative and open to all vehicles.

My club, the Kyburz Krawlerz, and myself personally would be willing to "adopt" this road system (9N12 and spurs), and work closely with the Forest Service to clean these precious campsites and maintain the roads.
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Old 10-02-2008, 09:03 PM   #3 (permalink)
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#2 Attacking the wording in the document itself and errors in process. Showing that the DEIS DOES NOT fit the NOI.

These are the types of comments that I will really be focusing on a lot becuase I only know a few routes in TNF personally..


I THINK this is the comment by Rick (WLD WUN) that saved us about 200-300 miles in ELDO:

Forest Supervisor Villavazo,

I am writing with my concern that the DEIS does not follow the NOI, in particular page 4, last paragraph states;

“maintenance level 2 forest roads will generally be designated as open to green sticker OHV use unless adverse environmental impacts or conflicts with others uses are identified (ENF LRMP, management practice 27, page 4-83)”


studying the preferred alternative map D it is obvious that this statement has not been met by the DEIS, generally maintenance level 2 roads in this area are closed to OHV use.

Since the DEIS must follow the guidelines of the NOI, the chosen alternative must generally have maintenance level 2 roads open to OHV use
and since no adverse environmental impacts or conflicts with other users are specifically cited in this document with these specific routes, ALL must have OHV use permitted unless a site specific report is obtained.
the following 268 maintenance level 2 roads on alternative D must be made Open to All Street-Legal and Greensticker Vehicles

07N01 08N27 08N66 09N17A 09N54 10N16BC 10N82 11N26H 11N69 11NY32 12N99 13N51 14N17 NSR1199A-B
07N02 08N29 08N67 09N17H 09N59 10N16D 10N83C 11N27A 11N69A 11NY34 12N99C 13N58 14N17B NSR1230D-A
07N03 08N31B 08N67A 09N17Q 09N62 10N16E 10N83J 11N28 11N70 11NY37 13N10 13N60 14N25B NSR1232-F
07N05 08N32 08N70 09N17S 09N68 10N17 10N83K 11N31 11N70C 11NY55 13N13 13N60A 14N36 NSR1358J-A
08N05L 08N36 08N71 09N17W 09N77 10N20 10N83M 11N32 11N71 12N22 13N14A 13N65B 14N38 NSR1393-A
08N11 08N38 08N72 09N20 09N79 10N25A 10N87 11N33 11N71A 12N22E 13N15A 13N65C 14N40A NSR1408-A
08N12 08N39 08N79 09N22B 09N84 10N25W 10N91 11N34 11N72 12N22F 13N20A 13N66 14N41 NSRELD-64-A
08N13 08N43B 08N83 09N25 09NY21 10N28W 10N94 11N35 11N72A 12N24A 13N22CA 13N67 14N42 NST1322-B
08N14 08N44 08N83C 09N25G 09NY26 10N43 10N94A 11N37B 11N73 12N25B 13N22CB 13N68 17N12K
08N15 08N45 08N84 09N30A 09NY32 10N44 10N95 11N37C 11N74 12N29F 13N22H 13N69B 17N12P
08N16 08N47A 08N87 09N30J 09NY37 10N50M 10NY09 11N39 11N77 12N30 13N22M 13N72A 17N12U
08N16A 08N50A 09N07 09N30JW 09NY46 10N50T 10NY10 11N39A 11N77A 12N30A 13N24A 13N73 NSR0930-C
08N17 08N50B 09N08 09N36 10N01 10N55C 11N09A 11N40B 11N83 12N30D 13N28F 13N76 NSR0930-L
08N20F 08N50D 09N10 09N40B 10N02 10N57 11N10A 11N43 11N96 12N32 13N28K 13N85 NSR0938-A
08N20FE 08N50H 09N11 09N41 10N03 10N58 11N11 11N52 11N99 12N32A 13N29A 13N86 NSR1013-A
08N23A 08N55K 09N12 09N41A 10N06 10N59 11N15 11N55 11N99A 12N37A 13N31 13N86A NSR1109A-A
08N23B 08N57D 09N14A 09N42 10N14G 10N65 11N16A 11N56 11N99E 12N40 13N41C 13N91 NSR1128E
08N23C 08N58C 09N15 09N42A 10N16B 10N66 11N21 11N63 11NY01 12N40A 13N42C 14N06 NSR1135-A
08N25C 08N58D 09N15A 09N46J 10N16BA 10N67 11N26C 11N64 11NY27 12N51A 13N44 14N08A NSR1170C-A
08N26 08N65 09N15B 09N51 10N16BB 10N71B 11N26E 11N64C 11NY30 12N60B 13N46 14N08J NSR1199A-A


Here is one I wrote attacking the wording in the Document:

Dear Forest Supervisor,

In Chapter 3, page 48, this assumption in listed:

"Public education and enforcement of regulations will successfully limit public travel to designated routes."

This statement is incorrect and needs to be changed. There is no way to assume that public education and enforcement WILL successfully limit public travel to designated routes. In the DEIS, you state that there are many user created routes in existance. Travel over the forest floor has not been permitted in the past, yet, these routes have still been created with the Forest Service educating the public and enforcing the regulations. Public education and enforcment has not worked in the past, so you can not assume it will work under the proposed allternative.

Either this assumption needs to be removed from the DEIS or the word WILL needs to be changed to MAY.

Thank you for your time,

Kurt Schneider
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Old 10-02-2008, 09:08 PM   #4 (permalink)
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One note,

By no means do I consider myself an "expert" at this stuff. I do not pretend to be one either, but I know people that ARE....

These suggestions are just stuff that I picked up from people who know better than I do.

Also remember that the above comments were for ELDO, DO NOT cut and paste them.

If you have written in comments, I ask that you post them in this thread to give others examples and food for thought...


KURT
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Old 10-02-2008, 09:15 PM   #5 (permalink)
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Here are a few comments that I have sent into TNF:

Dear Forest Supervisor,

In the Tahoe National Forest DEIS under the "Background" section, it is stated:

"Over the past few decades, the availability and capability of motorized vehicles, particularly off-highway vehicles (OHVs) and sport utility vehicles (SUVs) has increased tremendously. Nationally, the number of OHV users has climbed sevenfold in the past 30 years, from approximately 5 million in 1972 to 36
million in 2000. California is experiencing the highest level of OHV use of any state in the Nation. There were 786,914 ATVs and OHV motorcycles registered in California in 2004, up 330 percent since 1980. Annual sales of ATVs and OHV motorcycles in California were the highest in the U.S. for the last 5 years.
Four-wheel drive vehicle sales in California also increased 1,500 percent to 3,046,866 from 1989 to 2002.

Unmanaged OHV use on national forest lands has resulted in unplanned roads and trails, erosion, watershed and habitat degradation, and impacts to cultural resource sites. Compaction and erosion are the primary effects of OHV use on soils. Riparian areas and aquatic dependent species are particularly
vulnerable to adverse impacts from OHV use. Unmanaged recreation, including impacts from OHV’s, is one of “Four Key Threats Facing the Nation’s Forests and Grasslands.” (USDA Forest Service, June
2004). "

With this data it is clear that the public now demands more public lands and areas in which to recreate with their OHV's. One problem listed in the DEIS is that there are many unmanaged "user created" trails within the forest. This is further testament that the OHV public needs and demands more of it's public lands for this type of recreation.

In contrast to these facts, all of the alternatives, with maybe the exception of the no action alternative, are removing routes from Tahoe National Forest. This does not make any sense at all. As demand increases, you are limiting the supply.

There needs to be an alternative that adds managed routes in to the system to correspond to the public will. If the forest service does nothing but remove the current routes, you are stuffing the ever-growing OHV use into a smaller area which will create even more damage.

While I realize that creating new routes maybe expensive to build and maintain, there is currently a strong OHV volunteer movement in this area of the Sierras. As the founder of one such volunteer organization, I am positive that there are a vast number of people willing to help the Forest Service create new, managed routes in such a way to mitigate any damage.


Thank you for your time,

Kurt Schneider


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Old 10-02-2008, 09:17 PM   #6 (permalink)
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Dear Forest Supervisor,

In that the Tahoe National Forest DEIS documents are so large, November 26th, 2008 is not a reasonable cut off date for the public comment period.

In order for the public to respond and comment on the document, it needs to be extended by at least another 30 days.


Thank you for your time,

Kurt Schneider
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Old 10-02-2008, 09:19 PM   #7 (permalink)
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Dear Forest Supervisor,

In reading the DEIS, there is one major missing component. In an Environment Impact study, there needs to be data and research done on the impact of wheeled, motorized recreation. If there is no detailed description of the activity, grounded in facts and research, then the document needs to be completely re-written. In the Eldorado DEIS, there is no description at all of wheeled motorized recreation.

If this research is not done, the document is assuming damage is being done to the environment. There needs to be research done by a neutral party what damage may be done by different types of vehicles an on different terrains and in different conditions in the forest.

For example, what if any damage is done by a 4,000 pound Jeep over a granite slab, compared to a graded dirt road, taking into account the weather. Is there a different amount of damage if a wheeled pick-up truck travels over 6 inches of snow compared to 12 inches and compared to 24 inches? Different types of snow would also have to be examined. A route with 3 inches of solid iced over snow would give a vehicle much less ground contact, than 12 inches of powder.

Also the amount of horsepower and torque must be included. By addressing this, the DEIS is lumping all types of motorized vehicles into one group. Would not a dirt bike with more horsepower and torque create more damage than a four wheel drive Jeep which would not spin it's tires as much?

The damage created by OHV use is assumed in the document. It needs to be proven and backed with studies and evidence.

Thank you for your time,

Kurt Schneider


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Old 10-02-2008, 09:22 PM   #8 (permalink)
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Many more sample comments that were written for ELDO can be found in this thread:

/forum/land-use-issues/607421-post-yer-comments-do-now.html

As we wrote the comments, they got better and better, so please read through the entire thread and look at the comments toward the end.

IMO, 5 small letters are better than 1 long letter with 5 points. Make the forest service work!

I hope I did not slam everyone with too much info at once, just trying to help.

KURT
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Old 10-02-2008, 09:35 PM   #9 (permalink)
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Tom Quinn did say he wants details.

He wants to know why you think something should be opened, stay open, change maintenance status or road status.

I was very impressed with his demeanor. He was so reasonable. Everything he said made sense, and he articulated well.

Not once did someone tell us "it's in Chapter three"
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Old 10-03-2008, 09:52 AM   #10 (permalink)
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Make sure you also show the FS how you use routes in the winter, or at least during the period that they are proposing for the winter closures!

Winter closure comments are REALLY needed.

Thnk about it, they close us down for 3 months in the winter even if the roads are dusty! AND they can extend that closure!

To add to the insanity, they set a precedent last year by closing the forest becuase of "fire" danger!
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Old 10-03-2008, 10:20 AM   #11 (permalink)
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Something important to note: SOME letter is almost always better than NO letter.

No it's not a vote, but every letter we send does send a message, even if it winds up in the 'non-substantive' pile. I had this discussion with my club yesterday -- don't be afraid to write a letter. There is no WRONG way -- but there are better ways, as discussed above in this post. It can be as simple as "I recreate regularly on the Tahoe on these specific routes, and have for years. I don't see why Route Dez should close these routes that provide access to the back-country. Please support a shorter winter closure only as necessary based on conditions on the ground.

Even if writing isn't your strong suit, put pen to paper and get 'er done -- your recreation depends on it.

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Old 10-03-2008, 11:08 AM   #12 (permalink)
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Quote:
Originally Posted by randii View Post
Something important to note: SOME letter is almost always better than NO letter.

No it's not a vote, but every letter we send does send a message, even if it winds up in the 'non-substantive' pile. I had this discussion with my club yesterday -- don't be afraid to write a letter. There is no WRONG way -- but there are better ways, as discussed above in this post. It can be as simple as "I recreate regularly on the Tahoe on these specific routes, and have for years. I don't see why Route Dez should close these routes that provide access to the back-country. Please consider winter closure in specific areas only as needed, and based on conditions on the ground. fixed

Even if writing isn't your strong suit, put pen to paper and get 'er done -- your recreation depends on it.

Randii

Quted for truth with a bit of a twist.....
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Old 10-03-2008, 03:25 PM   #13 (permalink)
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Here is an additional document of "effective letter writing strategies " from your Friends at FOTFA:

Quote:
Effective letter writing:

We have learned that there are three types of comments needed to obtain a positive outcome a DEIS Process.

Everyone can do the first and is the one all the big organizations recommend for those who don't know what to do. Luckily it's also the easiest and does not require any research or special knowledge:

1)Every citizen's letters:

Write a letter to the Forest Service, emotional if need be, be respectful, but firm making it clear you find what is going on to be unacceptable and life changing. The letter should, at a minimum detail how a trail will be missed, how long you have been using it, how you use it and with whom; detail your activities on the trail, be it camping, fishing, hunting, all the standard uses of the forest; seasonal uses, do you go there more than once a year for the fall colors, the spring bloom, snow shoeing? Emphasize seasonal usage, especially snow.

As you may be aware the Eldorado National Forest is implementing at a "minimum" an inflexible three-month closure of the forest to OHV travel. Tahoe is attempting to follow suit and make the same decision regarding seasonal use.

Clearly connect your use of the forest to your vehicle. Stay away from detailing any usage that is not environmentally sustainable.

This is the category of letters the Forest Service should receive the most of - the letters need to show varied and mass usage of the forest. A separate letter must be written for each and every trail from each user to have the best effect, no matter if the trail in question is on the preferred alternative or not. This is because another letter will be written by someone on the other side wanting to close the very same trails because they don't think the trail should be there. There may be various letter generators on the web, but the personal touch is best.


2)Workshop comments:

The second is to write the type of comments we learned how to write in the class last year with the Eldorado (I need a refresher of those procedures). This time the instruction will be expanded to cover not only how to write a "substantive" comment the forest service will be obligated to seriously consider, but also how to set the comment up so it may stand up to an administrative appeal, if not a legal appeal as well.

These comments are formulated in direct relation to specific citations and verbiage in the document.

When a statement is made in the document, one must actually demand the misstatement be corrected or removed from the document. It is not enough to point out the error, you must "tell" the Forest Service to do something. That "something" must also be something they legally can do. You will not see this revealed in their answers to the publics comments in the Final EIS, but the record is there for an appeal, both administrative and legal appeal cases.



3) Professionally written comments:

The third is to pay professional(s) to write comments none of us would or could consider. Using the professionals experience to draw out the problems within the DEIS document. There should be a lot of technical, but not necessary correct statements in the document, these types of statements the Forest Service make need to be deleted from the document or corrected to say OHV has no effect on whatever they are talking about, be it water, soil, plants, animals, birds, fish, etc. This requires a higher level of knowledge of the "studies" and prior decided documents.

If no one challenges the document, the document becomes fact. Facts can be changed, but not easily.

Prior insufficiently challenged documents, now facts, that make this process that much harder:
Tahoe National Forest Plan
Sierra Nevada Forest Plan Amendment
Sierra Nevada Framework
National Travel Management Plan (TMP)
Region 5 management practices that conflict with the National Travel Management Plan.
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Old 10-07-2008, 08:41 AM   #14 (permalink)
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So who has submitted comments so far?
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Old 10-07-2008, 09:26 AM   #15 (permalink)
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I'll be working on some soon! I still have much more to read Really Dam shaking head
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Last edited by rockwrangler; 10-07-2008 at 09:26 AM.
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Old 10-07-2008, 10:04 AM   #16 (permalink)
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Originally Posted by Kurtuleas View Post
So who has submitted comments so far?
Iíve sent about 10 comments on specific issues. I also am coming up with some questions for tonightís meeting in Truckee and some for Thursdays in Auburn.
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Old 10-08-2008, 12:18 PM   #17 (permalink)
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And, the comments and letters are working....KEEP IT UP!!!!!
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Old 10-08-2008, 12:21 PM   #18 (permalink)
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Would be an effective comment...
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97 CTD, extra cab, on 35's
90 toy, 42s, full hydro, cases, 4;7's, detroits, one tons
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Old 10-08-2008, 01:10 PM   #19 (permalink)
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Would be an effective comment...

Appropriate yes, effective....mmmmmnotsomuch
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