Ok-Wenn Travel Management Plan - Comments 1-20-15

Land issues, laws, restrictions, etc...

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Ok-Wenn Travel Management Plan - Comments 1-20-15

Postby Grumpy » Wed Jan 07, 2015 1:26 pm

Travel Management comments are due for the Ok-Wenn National Forest. That's our play area kids. I was contacted by Don Amador from BRC this morning, and now have him plugged in with Earl, Doug, and the rest of the crew to prepare his input to the FS. Let's get after it, we only have till the 20th of this month.
Last edited by Grumpy on Thu Feb 12, 2015 10:21 am, edited 2 times in total.
Dave
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Quote:
Originally Posted by Oregon80
-By driving a Scout, you my friend have recycled, which is more than those pansy Prius owners can say.
-I love driving a piece of history that was nearly lost.

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Postby Grumpy » Wed Jan 07, 2015 1:27 pm

E-mail from Don Amador:


Dave,
Have you looked at the impact of this proposed action to existing OHV use. I have many concerns, but I wanted to know if non-street legal
use of level 2 roads is occurring now and, if so, what percentage of the non-street legal OHV use does those level 2 roads provide?
It appears the Forest wants to close all level 2 roads to non-street legal OHVs…. just like the Mt. Hood did a few years ago. That is strange
because down here in CA… most all level 2 roads are open to non-street legal OHVs.
Link to Proposed Action
http://www.fs.usda.gov/.../FSE_DOCUMENT ... 825881.pdf
The Okanogan-Wenatchee National Forest is proposing changes to motor vehicle use on specific roads, trails and areas within the non-wilderness portion of the Forest. Winter -- over the snow motorized use -- will not be analyzed at this time and is not part of this proposal.
The proposed action is to close the Forest to cross-country motorized travel off the existing National Forest system road network, and existing National Forest system motorized trails, consistent with current designations of vehicle type and seasonal closures.
• All roads currently open for motorized use (maintenance levels 2-5) would remain open to highway legal vehicles.
• All motorized trails would remain open to the current vehicle designation (4x4, ATV (<50 inches wide), or motorcycle).
• All closed roads (maintenance level 1) would be closed to all motorized vehicles, unless part of a motorized system trail.
Motorized vehicles would be allowed to drive up to 30 feet from the edge of all open roads to park. As displayed on the proposed action maps, motorized access to dispersed camping within 300 feet of specifically designated roads would be permitted.
Motorized travel would be restricted to existing routes within those corridors and not permitted closer than 100 feet from water. An exception to the 100 foot set-back from water would apply for identified Respect the River sites.
Motorized travel off the identified system of roads and trails, and off established routes to access dispersed camping within corridors, would be prohibited.
Please provide written comments on the Proposed Action by January 20, 2015.
I am working on an alert for BRC and feedback is welcome!
Thanks, Don
Dave

Have Scout, will wheel...Someday...Maybe





Quote:

Originally Posted by Oregon80

-By driving a Scout, you my friend have recycled, which is more than those pansy Prius owners can say.

-I love driving a piece of history that was nearly lost.

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Postby Grumpy » Wed Jan 07, 2015 1:29 pm

BRC Action Alert:


BRC continues to review this proposal with local OHV enthusiasts and agency staff. At this time, there are five major areas of concern. Those issues are the closure of all level 2 and 3 roads to non-street legal OHVs, accuracy of the maps, and forest-wide closure of level 1 roads to OHVs.
Level 2 Roads - (often called 4WD or high clearance vehicle routes) are often the backbone of any OHV trail network as they provide non-street legal connectivity for ATVs and dirt-bikes between the trails and provide recreational opportunity for OHVs that are wider than 50 inches such as jeeps, SxS, and 4x4 pickups.
Level 3 Roads - When designated as mixed-use roads for use by all OHVs, they provide connectivity and recreational opportunity for larger vehicles.
Accuracy of Maps - BRC urges local OHV clubs and enthusiasts to review the maps to see if any trails or other routes were left off the map. If so, request the agency make corrections to the map. Also, review the maps to see what level 2 and 3 roads are needed for connectivity (for non-street legal OHVs) and recreational opportunity for larger non-street legal vehicles.
Level 1 Roads - Review the level 1 roads that are proposed for closure and urge the agency to convert important routes (that provide connectivity or have high recreational value) as "roads-to-trails" or to manage them as a motorized trail.
Water Buffers - BRC is concerned that this restriction (as written in such broad and undefined terms) could effectively ban a significant number of OHV routes, since routes often parallel water courses and/or cross them. Users should request the agency to better clarify this proposal so that designated routes are not inadvertently impacted by these 100 foot "non-motorized" buffers.
Please provide written comments on the Proposed Action by January 20, 2015.
The preferred comment method is online via this website:
Comment on Motorized Travel Management Proposed Action
You can also print and fill out this Comment Form, and mail it in.

For more information contact Jennifer Zbyszewski, Interdisciplinary Team Leader at: okawen-travel-management@fs.fed.us
Dave

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Quote:

Originally Posted by Oregon80

-By driving a Scout, you my friend have recycled, which is more than those pansy Prius owners can say.

-I love driving a piece of history that was nearly lost.

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Postby Grumpy » Wed Jan 07, 2015 3:32 pm

Thank you for the opportunity to comment on the Travel Management Plan for the Forest. It is important for all stakeholders to have input into a document that will affect how they use the Forest for years to come. Economic, recreational, and lifestyle impacts all need to be taken into account. Past management decisions have had major impacts on how the Forest is used, to the detriment of some major contributors to the local economy, such as timber production. I will leave that to those more qualified. My concerns are the affect the plan may have on the recreation industry and those who use the Forest for their chosen forms of recreation.
Motorized recreation has been a major part of Forest use for several generations, and a major contributor to the stability of the local economy. Those who come to the area spend thousands of dollars on lodging, food, fuel, and vehicle parts and accessories. This use has, over the years, contributed greatly to the recreational growth around the Forest, and is one of the more outstanding facets of life here. This should be considered one of the legitimate, planned uses of the Forest.
A number of things in the plan need to be addressed that could, in the long run, adversely affect those of us who choose to use a 4x4, ATV, or motorcycle. Following are my comments on a few items of concern.

Level 1 Roads – Many of these roads need more review as the provide connectivity in the system or do, in fact, have high recreational value. I would urge they be considered for management as trail in many cases.

Level 2 Roads – These roads can, and often do, constitute the backbone of any OHV trail network, and provide non-street legal vehicles access to other system trails, and recreational use for larger 4x4 vehicles.

Level 3 Roads – These should be mixed vehicle use to provide connectivity to all portions of a trail system, and are also key to larger vehicles being able to access trails.

Water Buffers – This is vague in its wording. A large number of our trails run along water courses, and cross in many places. I believe more clarification is in order here. The fear is that this could be used to close trails and disrupt how we use our trails. There are methods to mitigate any crossing issues, and these need to be looked into in more depth. More work is needed here.

Manastash Trail – Now that The Nature Conservancy owns land above Cle Elum that includes part of the Manastash Trail, there are concerns over what their plans are, and how they will affect our ability to ride the trail. This needs to be addressed to the satisfaction of all involved.

Involvement of local officials – I have been seeing, in my conversations with other OHV users in other areas, some lack of consideration where local government bodies are concerned. These will be some of the most affected by any decisions made, and their input is critical to how the plan comes together.

Trails missing from maps – There are trails missing, most notably the Raven’s Roost trail. This alone should be cause for delay in some of the process. This is one of the most important parts of the process, and leaves one to wonder how good these maps may be. Hard to make decisions when lacking some vital information. Much more work needed here.

In closing, let me say I look forward to seeing the progress on this project, and will be watching along with many others. It is my hope that all sides will be included on equal footing, and comments weighed on their merits.

Dave Walters
4x4 Owner
Kennewick, WA
Last edited by Grumpy on Thu Jan 08, 2015 2:59 pm, edited 1 time in total.
Dave

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Quote:

Originally Posted by Oregon80

-By driving a Scout, you my friend have recycled, which is more than those pansy Prius owners can say.

-I love driving a piece of history that was nearly lost.

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Postby Grumpy » Wed Jan 07, 2015 4:56 pm

Paragraph about trails missing from maps added above closing...
Dave

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Quote:

Originally Posted by Oregon80

-By driving a Scout, you my friend have recycled, which is more than those pansy Prius owners can say.

-I love driving a piece of history that was nearly lost.

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Postby Grumpy » Wed Jan 07, 2015 5:53 pm

I will be sending this tomorrow. We need to have the club draw up a letter, as well as as many of you as we can get. If you don't submit comments, you won't have standing when the objection process starts, so let's get after it kids...
Dave

Have Scout, will wheel...Someday...Maybe





Quote:

Originally Posted by Oregon80

-By driving a Scout, you my friend have recycled, which is more than those pansy Prius owners can say.

-I love driving a piece of history that was nearly lost.

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Grumpy
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Postby Grumpy » Thu Jan 08, 2015 12:37 pm

Project #28730 / Letter ID #28730-623-34 Submitted 1-8-2015
Dave

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Quote:

Originally Posted by Oregon80

-By driving a Scout, you my friend have recycled, which is more than those pansy Prius owners can say.

-I love driving a piece of history that was nearly lost.

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Grumpy
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Postby Grumpy » Fri Jan 09, 2015 9:57 pm

Dave

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Quote:

Originally Posted by Oregon80

-By driving a Scout, you my friend have recycled, which is more than those pansy Prius owners can say.

-I love driving a piece of history that was nearly lost.

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Postby oddball » Sun Jan 11, 2015 3:17 pm

Comment sent #28730-623-54.

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Postby Grumpy » Sun Jan 11, 2015 4:56 pm

Only 20 since I posted mine..wow :|
Dave

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Quote:

Originally Posted by Oregon80

-By driving a Scout, you my friend have recycled, which is more than those pansy Prius owners can say.

-I love driving a piece of history that was nearly lost.

User avatar
Grumpy
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Postby Grumpy » Mon Jan 12, 2015 11:13 am

There is a discrepancy in your website on dates for comment closure. The project page asks for the 1-20-2015, while the comment page itself asks for 1-13-2015. It is my opinion that because of this, an addendum giving an extension is in order.

We did not see adequate public notice of this project in the local media. For this reason, we feel an extension of comment is required.

We also request an extension based on lack of published documents for this project.

Dave Walters
Land Use Coordinator
Tri Cities Peak Putters
Kennewick, WA
509-734-8694
Dave

Have Scout, will wheel...Someday...Maybe





Quote:

Originally Posted by Oregon80

-By driving a Scout, you my friend have recycled, which is more than those pansy Prius owners can say.

-I love driving a piece of history that was nearly lost.

Wrench
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Postby Wrench » Mon Jan 12, 2015 5:22 pm

The comment page now states 1-20-2015.
Paul
'84 XJ, '19JL

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Postby Grumpy » Mon Jan 12, 2015 5:52 pm

Yup, just got an e-mail telling me they fixed that little issue. Still think they owe us some time and further explanation on where the hell the documents are. A couple of us been looking all over the web page, and we ain't seein' a thing. More e-mails about to be launched...
Dave

Have Scout, will wheel...Someday...Maybe





Quote:

Originally Posted by Oregon80

-By driving a Scout, you my friend have recycled, which is more than those pansy Prius owners can say.

-I love driving a piece of history that was nearly lost.

User avatar
Grumpy
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Postby Grumpy » Tue Jan 13, 2015 7:43 pm

1. This is Subpart B of the Travel Management Plan. Therefore it can only be used as the authority to close unclassified (non-system) roads and trails to stop cross country travel. The proposal to close ML1 roads is inappropriate because they are system roads. According to your own regulations, system roads cannot be closed under Subpart B. They must be retained on the road system until after Subpart A is complete and project level NEPA is performed on these roads.

2. ML1 roads are often where the best firewood is available, so these roads must be left open for woodcutters to gather wood to heat their homes. It also helps reduce the fire hazard in the forest.

3. Making ML2-ML5 roads open to only highway legal vehicles is unacceptable. Green sticker vehicles need to travel on these roads to reach designated trails. Loading the green sticker vehicle into a truck to transport it between trails is not feasible.

4. Closing ML2-ML5 roads to green sticker vehicles is unacceptable specifically for hunters. Quads and side-by-sides need access to these roads for hunting, accessing hunting camps, and for retrieval of legally taken game.

5. Closing 34% of the roads on the Forest is not acceptable. With reductions in logging activity, it is essential that maximum access be preserved for recreation and tourism. This is vital to the rural communities who depend on forest land for their economy. Roads allow not only motorized recreation, but all forest users must have roads to access areas for hiking, fishing, bicycle riding, hunting, sightseeing, wildlife viewing, and other non-motorized activities.

Summary: We want to see the ML1 road closures dropped from this decision. We want ML2-ML3 roads to remain open to green sticker vehicles. It is imperative to keep as many miles of roads open as possible, for the economic health of the area.

Corky Lazzarino
Sierra Access Coalition
Quincy, CA
Dave

Have Scout, will wheel...Someday...Maybe





Quote:

Originally Posted by Oregon80

-By driving a Scout, you my friend have recycled, which is more than those pansy Prius owners can say.

-I love driving a piece of history that was nearly lost.

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Postby Grumpy » Tue Jan 13, 2015 7:47 pm

Sharp lady, and I think she just shot 'em right in the backside...
Dave

Have Scout, will wheel...Someday...Maybe





Quote:

Originally Posted by Oregon80

-By driving a Scout, you my friend have recycled, which is more than those pansy Prius owners can say.

-I love driving a piece of history that was nearly lost.

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Postby SPR » Fri Jan 16, 2015 8:08 am

Another Plea for Letters... This is from the Jan. PNW4WDA Region 4 Meeting

TRAVEL MANAGEMENT PLAN has been issued and the comment period closes January 20, 2015. Discussion followed and we need to get letters written ASAP. The plan seems to have lots of discrepancy in the maps, trails are missing, there are mislabeled trails, etc. We need to have some timely mitigation plans for any errors that are discovered after the plan is implemented. Additional information about the proposed action, including maps, is available online at: www.fs.usda.gov/goto/okawen/mtm. Please provide written comments on the proposed action to Comment Input Project #28730 Attn: Jennifer Zbyszewski, 24 West Chewuch Road, Winthrop, WA 98862. Comments can also be made on line. Please, please make your comments ASAP time is running out.
I don't Text (at least not very well), I eat Blackberrys, and I only Twitter after sex...

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Postby Grumpy » Fri Jan 16, 2015 9:21 am

Not much being added by way of comments! EPA and Sierra Club put in major statements, and they ain't pretty! Only two of us on there so far...
Dave

Have Scout, will wheel...Someday...Maybe





Quote:

Originally Posted by Oregon80

-By driving a Scout, you my friend have recycled, which is more than those pansy Prius owners can say.

-I love driving a piece of history that was nearly lost.

User avatar
Grumpy
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Postby Grumpy » Fri Jan 16, 2015 5:19 pm

Date submitted (UTC): 1/16/2015 7:01:38 PM
First name: Justin
Last name: Yeager
Organization: NMFS
Title:
Official Representative/Member Indicator:
Address1: 304 S. Water Street
Address2: Suite 201
City: Ellensburg
State:
Province/Region:
Zip/Postal Code: 98926
Country: United States
Email: justin.yeager@noaa.gov
Phone: 509-925-2618
Comments:
Thank you for the opportunity to comment on the Forest Service?s Motorized Travel Management Plan. This
plan is a good first step in addressing the management of the Okanogan-Wenatchee National Forest?s 8,200
miles of road. As you know, roads are one of the leading contributors to degraded watersheds and they have
numerous detrimental effects on fish and their habitat. The prohibition of cross-country motor vehicle use off
existing system roads and trails is a good first step. The closure of all maintenance level 1 roads and
unauthorized is also commended. However, I have concerns with portions of the proposed action. The proposal
to allow motorized access within 30 feet of all roads and 300 feet in certain corridors is very concerning. It is
also not yet clear where access to within 100 feet of water bodies will occur, as the ?Respect the River? sites
are not included on the available maps. I also have concerns about the significant expansion of the road
system that are not yet included as access routes to dispersed recreation sites, but would be included and
allowed on the new Motor Vehicle Use Maps. How will these roads be managed, maintained, and catalogued to
insure they do not expand over time and are not causing resource damage. It is also unclear what the definition
of resource damage is. Overall, this is a great step in helping manage and reduce the effects roads have on
aquatic systems. However, the proposed action does very little to correct the long list of roads that are currently
affecting aquatic systems and are in unsustainable locations.
Dave

Have Scout, will wheel...Someday...Maybe





Quote:

Originally Posted by Oregon80

-By driving a Scout, you my friend have recycled, which is more than those pansy Prius owners can say.

-I love driving a piece of history that was nearly lost.

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Postby SPR » Fri Jan 16, 2015 10:51 pm

Here I is...Your letter ID is 28730-623-95
I don't Text (at least not very well), I eat Blackberrys, and I only Twitter after sex...

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Postby Grumpy » Sat Jan 17, 2015 7:30 am

:D
Dave

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Quote:

Originally Posted by Oregon80

-By driving a Scout, you my friend have recycled, which is more than those pansy Prius owners can say.

-I love driving a piece of history that was nearly lost.

User avatar
Grumpy
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Postby Grumpy » Mon Jan 19, 2015 12:07 pm

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
Dave

Have Scout, will wheel...Someday...Maybe





Quote:

Originally Posted by Oregon80

-By driving a Scout, you my friend have recycled, which is more than those pansy Prius owners can say.

-I love driving a piece of history that was nearly lost.

User avatar
Grumpy
Peak Putters' Land-Use Coordinator
Peak Putters' Land-Use Coordinator
Posts: 6049
Joined: Wed Mar 14, 2007 8:38 am
Location: Kennewick, WA

Postby Grumpy » Wed Jan 21, 2015 9:34 am

Comment period has been extended to 1-30-2015. Seems attacking them with e-mails may have helped :wink:
Dave

Have Scout, will wheel...Someday...Maybe





Quote:

Originally Posted by Oregon80

-By driving a Scout, you my friend have recycled, which is more than those pansy Prius owners can say.

-I love driving a piece of history that was nearly lost.

User avatar
Grumpy
Peak Putters' Land-Use Coordinator
Peak Putters' Land-Use Coordinator
Posts: 6049
Joined: Wed Mar 14, 2007 8:38 am
Location: Kennewick, WA

Postby Grumpy » Wed Jan 21, 2015 6:22 pm

January 20, 2015
Michael Pena
US Forest Service- Pacific Northwest Region
PO Box 3623
333 SW First Ave
Portland, OR 97208- 3623
Dear Director Pena,
We have reviewed the information provided to us by your personnel in response to our FOIA
request of June 30, 2014 regarding the 2005 Travel Management Plan for the OkanoganWenatchee
National Forest ( OWNF). The purpose of this letter is to share with you our
position on the legal status of the OWNF travel plan as it relates to the operation of licensed
ATV' s on forest service roads. This letter also provides our comments for the proposed
travel management plan issued for public comment on December 22, 2014. We have
submitted a copy of this letter to appropriate personnel as indicated in your request for
comments.
It is apparent from our review of the materials received that Region 6 has not adopted a
travel management plan for the OWNF that is compliant with the 2005 Travel Management
Rule ( TMR). The 2005 Travel Management Plan ( TMP) was adopted pursuant to the policy
language of the 1989 forest management plan. As such any amendments, including
amendments phrased as " interpretations" after the adoption of the 2005 TMR must comply
with the procedural requirements contained therein. The TMP published in the Federal
Register in 2009 has never been adopted, and, in any event, is not compliant with the 2005
TMR since the USFS failed to coordinate the development of the plan with Okanogan
County as required in section 212. 53 of the TMR.
The 2005 TMP clearly allows the operation of all licensed vehicles on USFS roads. It makes
no distinction in terms of the type of license or the type of vehicle the license is affixed to.
Your recent amendment, or interpretation, as you refer to it, which states the 2005 TMP
plan does not allow the operation of licensed ATV' s on USFS roads, is clearly outside of the
original intent of the 2005 TMP. We find support for our last statement since your personnel
have chosen to whiteout that pertinent language in the published 2005 TMP pamphlets. We
are also very disturbed with USFS personnel using 36 CFR 261 as a means to circumvent
the process required by the 2005 TMR as we will explain below.
Telephone 123 Fifth Avenue N. * Room 150* Okanogan* Washington * 98840 Fax
509.422. 7100 TTYNoice use 800.833.6388 509. 422. 7106It is clear from the reading of 36 CFR 261 and the discussion regarding its application found
in the 2005 TMR that the authority in 36 CFR 261 is to close individual roads on a
temporary, emergency basis due to very specific circumstances without the process
requirements found in the 2005 TMR. This is clearly directed at circumstances such as
wash- outs, road damage, or the occasion that road access to a limited area must be
curtailed for specific and immediate environmental protection concerns. To suggest that 36
CFR 261 was adopted as an alternative process to the 2005 TMR would render the TMR
and its requirements without value. We find it difficult to imagine the USFS adopted the
2005 TMR only so they could disregard it. The 2005 TMR directs the process requirements
for the creation of travel management plans in a forest or other identified management
region. We find no authority to disregard the TMR on a wholesale basis.
In past discussions with USFS personnel from the Methow District, the restrictions in the
2005 TMR were often cited. We direct your attention to the discussion found in the 2005
TMR as it relates to the application of 36 CFR 212. 51. The TMR is clear that until " those
designations are complete for the entire administrative unit or ranger district existing
authorities and orders remain in effect." The USFS is specifically prohibited from enforcing
the restrictions of the TMR until a compliant TMP has been adopted. The 2005 TMP for the
OWNF was adopted prior to the adoption of the TMR and is the TMP still in place. The rules
it contained in the adopted April 2005 draft allow the operation of licensed vehicles on USFS
roads. The response to comments in the TMR clearly defers to state traffic laws when a
compliant TMP does not contain specific and different regulation. The 2005 TMP, based on
the 1989 management plan, allows licensed vehicles to operate on USFS roads. The State
of Washington now allows certain ATV's to be licensed. Any changes in the 2005 TMP must
comply with the 2005 TMR. An attempt to enforce any changes in the 2005 TMP based on
the restrictions in the 2005 TMR is outside the law until a compliant plan has been adopted.
In terms of the Travel Management proposal issued for comment on December 22, 2015 we
must point out several deficiencies. First and most important the USFS personnel have
failed to coordinate the drafting of this initial proposal as required in the National Forest
Management Act, National Environmental Policy Act and very specifically by section 212.53
of the 2005 Travel Management rule. This is a fatal flaw and must be remedied prior to the
USFS moving forward with its proposal. The December 22, 2014 proposal does not explain
the relationship it has with the proposal that was issued for scoping in 2009. This lack of
clarity makes it difficult for local government and the public in general to effectively
participate. The December 22, 2014 proposal fails to open roads that provide valuable
linkage to other travel corridors throughout the region and offers no justification for the
decision. Linking these existing transportation corridors fulfill local recreation and economic
goals and would be consistent with objectives stated in the 2005 TMR.
The proposal overstates the impact of the use of existing roadways by motorized vehicles.
The footprint of the road system in terms of the overall acreage in the OWNF is miniscule
and poses no significant impact to forest health. Motorized vehicle recreation, while very
Telephone 123 Fifth Avenue N. * Room 150* Okanogan* Washington* 98840 Fax
509.422. 7100 TTYNoice use 800. 833.6388 509.422. 7106
Page 2 of 3important to the local economy is a small percentage of the overall recreation and
commercial activities in the OWNF. The proposal seems to be based on the notion that
motorized travel on existing roads causes great harm to the OWNF but we find little credible
science to support that assertion.
The proposal as offered for public review is fatally flawed.
In an effort to avoid litigation we urge the USFS to adhere to the following courses of action:
1) Immediately allow all licensed ATV's to operate on USFS roads in the OWNF;
2) Withdraw the proposed TMP published in the federal register in 2009;
3) Withdraw the TMP proposal issued for comment on December 22, 2014.
4) Coordinate the creation and subsequent review of a new OWNF TMP with
Okanogan County;
5) Review the new OWNF TMP for its economic impacts to the businesses and
communities of Okanogan County;
6) Publish the new draft OWNF TMP in the federal register and complete the review as
necessary for adoption;
We believe the above represents the legal and most responsible course of action. This is
an important issue to Okanogan County and you as the trustee of a huge expanse of public
land in the county play a critical role in the discussion. We are hopeful you will accept our
proposal as the only legitimate path to move forward.
We look forward to your response and to working with USFS personnel on this important
process.
Sincerely
Board of Okanogan County Commissioners
Jim De ro, Cha rman
Ray pbell, Me Wer
d'
heilah Kennedy, Mem
Dave

Have Scout, will wheel...Someday...Maybe





Quote:

Originally Posted by Oregon80

-By driving a Scout, you my friend have recycled, which is more than those pansy Prius owners can say.

-I love driving a piece of history that was nearly lost.

User avatar
Grumpy
Peak Putters' Land-Use Coordinator
Peak Putters' Land-Use Coordinator
Posts: 6049
Joined: Wed Mar 14, 2007 8:38 am
Location: Kennewick, WA

Postby Grumpy » Tue Jan 27, 2015 11:46 am

Date submitted (UTC): 1/27/2015 6:03:55 PM
First name: Mark Weick
Last name: Weick
Organization: Washington Trails Association
Title: Member
Official Representative/Member Indicator:
Address1: 5724 Campbell Rd
Address2:
City: Peshastin
State:
Province/Region: WA
Zip/Postal Code: 98847
Country: United States
Email: mweick@charter.net
Phone: (509) 548-4388
Comments:
As a hiker/ backpacker, cross country/downhill skier, climber, camper, and other forest user since the 1950s,
It's clear to me that motorized use of the Wenatchee/Okanogan National Forest and other Public Lands has
already surpassed the capacity of ecosystems to retain and sustain their integrity. Not just backpackers and
hikers, but also responsible campers, horsemen, hunters and other forest users are aware of the continuing
degradation by off road vehicles, motorcycles, snowmobiles, as well as the frequent attitude of entitlement
exemplified by machine operators. Although there are possibly a few instances where new vehicle use might
be allowed. it's clear to me that restriction of current levels of use and further regulation is urgently called for. I
feel somewhat dismayed but a recent draft proposal and cannot intelligently or responsibly offer support of
current proposals and assessments by the Forest.
Mark Weick
Dave

Have Scout, will wheel...Someday...Maybe





Quote:

Originally Posted by Oregon80

-By driving a Scout, you my friend have recycled, which is more than those pansy Prius owners can say.

-I love driving a piece of history that was nearly lost.

User avatar
Grumpy
Peak Putters' Land-Use Coordinator
Peak Putters' Land-Use Coordinator
Posts: 6049
Joined: Wed Mar 14, 2007 8:38 am
Location: Kennewick, WA

Postby Grumpy » Tue Jan 27, 2015 2:22 pm

Date submitted (UTC): 1/27/2015 6:39:18 PM
First name: Patricia
Last name: Rodgers
Organization: Sierra Club
Title: Mrs
Official Representative/Member Indicator:
Address1: 8121 NE 141st Street
Address2:
City: Kirkland
State: WA
Province/Region:
Zip/Postal Code: 98034
Country: United States
Email: patriciam@clearwire.net
Phone: 425 823 0386
Comments:
Ban on all cross-country motorized use- cars, trucks, ATVs, and dirt bikes.
No new motorized trails
Designate these roadless areas as non-motorized:
Mad River
Lake Chelan-Sawtooth
Entiat/Chelan
Teanaway
West Manastash
Golden Horn
Tiffany
We need quiet recreation areas for hikers, horse riders and mountain bikers. Dirtbikes and other off-road
vehicles by their nature are noisy, cause erosion, impact wildlife and conflict with other users.
Dave

Have Scout, will wheel...Someday...Maybe





Quote:

Originally Posted by Oregon80

-By driving a Scout, you my friend have recycled, which is more than those pansy Prius owners can say.

-I love driving a piece of history that was nearly lost.


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