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FOREST PLAN REVISION: STAYING ENGAGED
Column by Don Amador, BRC Western Representative

As National Forests throughout the country begin their Forest Plan Revision efforts, BRC believes that commitment by the OHV community to remain engaged with their particular Forest(s) during this and subsequent programmatic and site-specific planning efforts is critically important.

Robust participation by BRC and other national/regional OHV groups in the 2012 Planning Rule's public comment period helped create the Rule's recognition of developed recreation (including OHV) as an important factor in the decision-making process. BRC and its partners have expressed many concerns about the Rule, but our experience thus far with its application has had some positive moments. We are seeing glimpses of a refreshing, pragmatic focus to reflect actual use patterns, including in areas with possible wilderness characteristics, rather than designations driven solely by blind ideology.

Still, our work is far from done. Indeed, it has just started. Although the agency has improved the "recreation" narrative, a review of the Notice of Intent (NOI) filed by the Sierra, Inyo, and Sequoia National Forests (early adopter forests) to revise/amend their land and resource management plans proves the import of users attending meetings and staying actively involved. In fact, the agency's motto is to "Learn Locally and Advise Nationally."

BRC reminds users that each plan revision process is different and should be analyzed as such by reviewing parties. BRC recommends that motorized trail enthusiasts review all sections such as timber, wildfire, at-risk species, and recreation with a travel management (TMR) focus on how the desired conditions, strategies, and conditions could potentially impact motorized use on roads, trails, and areas.

For example, BRC recently commented on the Draft Environmental Impact Statement Proposed Revised Land Management Plans for the Blue Mountains National Forests (DEIS) located mostly in Oregon. BRC found their travel management strategies were too narrowly focused on the closure/decommissioning of ML 2 roads or the reclassification of ML2 roads to ML1 roads. BRC recommended the agency should expand their strategies to include the reclassification of ML3 roads to ML2 roads, the reclassification ML2 road to motorized trails or manage appropriate ML2 roads as "roads managed as trails," and to manage appropriate ML1 roads as "motorized trails."

LINK TO BRC BLUE MOUNTAIN COMMENTS
http://bit.ly/bluemtns_comments

To enhance single-track and narrow trail opportunities, BRC recommended the strategies of converting "roads-to-single track trails," or "roads-to-motorized trails less than 50 inches in width," and "roads managed as motorized trails greater than 50 inches in width" as tools to help it achieve its budget objectives while still providing a substantive and high quality recreational route network.

After an initial review of the Early Adopter Forest's NOI, BRC is concerned the proposed action's plan to apparently create "quiet recreation" expectations on all landscapes including both motorized (non-quiet) and non-motorized land classifications could be problematic on a number of fronts.

LINK TO EARLY ADOPTER FOREST'S INFO
Forest Service

In most of the non-recreation sections such as timber and fire management, there is little, if any, mention of mitigation to protect designated trails or other recreation facilities in project areas. For example, it is often the case that pre and post-fire or timber projects seldom substantively mitigate impacts to engineered trails. Those impacts include obliteration of the trail or removal of water control structures such as rolling dips and catch basins. Those soil erosion measures can often cost $15,000 to $20,000/mile to install (or replace). Other sections such as at-risk species, water quality, and ecosystems have the same recreation mitigation deficiencies.

BRC believes there continues to be some serious hurdles or challenges to current and future planning efforts on Forest Service lands due to loss of practical and institutional knowledge because of the ever growing number of retirements, endless litigation, unfilled staff positions, impacts to relationships because of the agency's "move to promote" human resources' plan, and conflicting regulations that prevent substantive fire/fuel treatments. It would be naïve to overlook the fact that good words and even good intentions have too often failed to penetrate the bureaucracy and reach the ground, particularly for the recreation enthusiast.

Again, users must remain engaged and occupy a seat at the table for the foreseeable future. Sitting on the sideline is not an option.


* To review BRC's role in the FS Planning Rule, please visit the link HERE.
 
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