Date submitted (UTC): 1/19/2015 5:12:17 PM
First name: Byron
Last name: Stuck
Organization: WOHVA
Title: President
Official Representative/Member Indicator: Official Representative
Address1: 7260 86th Ave SE
Address2:
City: Mercer Island
State: WA
Province/Region:
Zip/Postal Code: 98040
Country: United States
Email:
President@WOHVA.org
Phone:
Comments:
January 19, 2015
Response to Okanagan-Wenatchee National Forest Motor Vehicle Use Maps and Proposed Actions
Thanks very much for the opportunity to submit comments. While we'll officially be submitting a joint letter from
WOHVA and the NMA, I wanted to assure these comments came in on time with this submittal. Our comments
are organized by proposed action:
Proposed Action List
Prohibit cross-county motor vehicle use off of existing system of roads and trails.
At first blush this policy would seem reasonable ?the goal is to prevent damage to a fragile ecosystem that can
occur from repeated incidence of cross-country travel. With repeated incidence in a concentrated manner a
new trail or road is established. This impact occurs in non-motorized areas as well. Therefore, ?no crosscountry
travel? should be applied to all summer-time recreational user groups. It can be argued that crosscountry
travel of any summertime-recreationist has minor short term and insignificant long term affect for a
given occurrence when intermittent and non-concentrated. If a ?no cross-country travel? policy cannot be
applied equally to the entire forest and imposed on all summertime-recreationists, then the policy should not be
adopted at all.
Alternatively, it may be more reasonable to assume that said trails or roads are an indicator of high user
demand coupled with management which has not delivered on that demand. Prohibitive policy will not yield the
desired outcome but providing opportunities will entice users onto managed pathways; responsible motorized
recreationists will typically behave in a manner congruent to Tread Lightly! principles and stay on established
trails and roads.
All maintenance level 1 roads would be closed to motorized vehicles, unless currently part of a motorized
system trail, in accordance with Forest Service Handbook direction (FSH 7709.58, 10,
12.3).
The main problem with this policy is that ML-1 roads would be lumped into a classification of native,
undisturbed areas which is an utter misclassification. These are actually recreational opportunity for the
motorized users. Offroad motorists enjoy riding on primitive roads and singletrack trails. These road types can
be used as connectors to camping areas thus creating shorter and easier loops that are suitable for younger
and less skilled riders or those with disabilities. ML-1 roads are primitive and these can evolve into single track
through natural progression. Offroad motorcyclists enjoy and seek out singletrack trails.
Where existing ML-1 roads are used, even minimally, they should remain open to motorized travel and be
placed onto the proposed MVUMs. Realizing the breadth of identifying every ML-1 road, it may be
unachievable in one calendar year or prior to publishing deadlines. Given this, all ML-1 roads should remain
open to motorized use as default practice rather than a ?blanket closure? policy.
Allow motor vehicle use up to 30 feet from the edge of all open system roads for parking, and up to 10 feet off
the side of motorized trails to allow safe passage of other vehicles, as long as resource damage does not
occur.
In principal this sounds like a great model, but in practice it introduces major issues for summertime usergroups.
Regarding the 30? parking limitation: No comments at this time.Regarding the 10? trail limitation: For motorized users, there may be a need to go around a blockage rather
than turn back due to mileage and or time of day (lack of fuel, darkness). In such times, a temporary go-around
is utilized until the barrier is remedied by USFS crew or volunteer effort. This example is not as likely to occur
to someone driving a high clearance vehicle as this group often carries chainsaws by default and addresses
the situation as a volunteer log-out opportunity. Needless to say, a 100? conifer laying across a trail is likely
going to require deviating more that 10? from the trail when traveling by motorcycle. Other obstructions, such
as slides, also do not adhere to a 10? radius policy. Another issue for motorized users is preventing vandalism
or even theft of their motorcycle or ATV (which can result in stranding and is a safety hazard) while exploring
for mushrooms or berries or while hunting. These users are forced to hide their equipment, sometimes
hundreds of feet from the trail, in order to adequately hide their equipment. Another reason for riding off-trail is
when a motorist and equestrian encounter one another. It can be beneficial to the horse and its rider for the
motorcyclist to deviate off the path by several yards and allow horse and rider to pass. The 10? restriction
should not be applied as a prohibitive policy but rather as a best practices guideline with continued delivery in
educational outreach programs made to ORV dealers, through on-the-ground ORV ranger contacts,
informational posters, leaflets, etc.
Allowing managed motor vehicle use within 300? of currently open roads but not closer than 100? of water
(actual proposal truncated by author).
Certainly, hundreds of dispersed camping sites exist today that are reachable by user-defined roads that are
?currently open? yet not on any MVUM. Not allowing dispersed camping access via user-defined roads in
existence at present time will likely result in overcrowding at other sites. Concentrated camping lends itself
away from a semi-primitive experience and is a detraction from a quality outdoor experience overall for anyone
wishing to enjoy dispersed camping in non-wilderness areas.
Amend the Okanogan and Wenatchee National Forest Plans to make them consistent with the
Travel Management Rule as follows (actual amendment omitted by author).
There are separate amendments for Okanogan and Wenatchee NFs but the language is nearly identical: they
close the forest to motorized access by default and open only where described in the MVUMs.
This approach will cause excessive administrative costs and lengthy timeframes through implementation of
?Project-specific NEPA decisions may be made to open, close, or restrict trails based on the
goals of the management area with changes displayed on the subsequent motor vehicle use
map.? Subsequently, an underserved user group is short-changed even further: motorized recreationists
contribute in cash equally to non-motorized groups through tax paying programs. The motorized group is well
known for volunteer contributions and effort assisting in trail maintenance. These very hours are recognized
through grant submittals by the USFS to obtain matching funds through NOVA and RTP programs.
A policy that closes the forest to motorized vehicle (over-snow not included) travel ? except where specifically
designated as open ? significantly reduces recreational opportunity to the least-served user groups of the
Forest by default. There are arguments indicating motorized travel has the greatest negative impact to wildlife
when compared to other outdoor recreation activities. These can be countered with arguments of equal validity
indicating human contact while on foot has the highest negative impact to wildlife. Note that the very sound of a
motor vehicle alerts wildlife of a presence in the forest ? long before that presence is within menacing
proximity. This cannot be said for hikers, mountain bikers nor equestrians. Because of this, a blanket closure
policy affecting only the motorized community incorrectly identifies them as the most offensive user group to
wildlife.
In summary it should be evident that the Northwest Motorcycle Association and Washington Off Highway
Vehicle Alliance opposes applying an overarching policy that closes access to the Forest by default. It is a
barrier applied to an already meager allotment of trail mileage. The organizations believe such closure will not
deliver the results anticipated and strongly recommend increased investment in user education programs. We
will gladly collaborate with the Okanogan-Wenatchee Forest Service in development of such user education
programs. In any event, NMA and WOHVA believe accurate and up-to-date maps are key in providing a safe
and fun motorized outing. To that end, NMA and WOHVA have reviewed the maps which were published on
December 22, 2014 by the Okanogan-Wenatchee Forest Service Motorized Travel Management Project office.
We have found the Forest has delivered a NET LOSS of trails in the currently proposed MVUMs and
recommend the Ranger Districts within the Forests review the table below. Following the advice and comments
in the tables will help the Forest meet the needs of the motorized recreating public.
Please feel free to contact WOHVA if you have questions. A more complete submittal will be coming
momentarily with a table of specific trail and road comments by forest district.sincerely,
Byron Stuck
President, WOHVA
Washington Off Highway Vehicle Alliance
President@WOHVA.org