Comment on snowmobile, snowbike use.

Monday, August 4 (tomorrow) is the deadline for comments. I think you have until midnight to submit.

Here is the link to submit comments.

I've been super busy so I only just submitted my comments this evening. Here they are, for what it's worth:

[size=10pt]August 3, 2014
Joseph Adamson
Recreation, Heritage, and Volunteer Resources Staff
1400 Independence Avenue SW., Stop 1125
Washington, DC 20250-1125

Dear Mr. Adamson,

I would like to comment on the Forest Service’s proposed rule for over-snow vehicle (OSV) use. I am a long-time backcountry skier in the Washington Cascades. I am also a member of The Mountaineers in Seattle and a regional expert on backcountry skiing history. My website, alpenglow.org, was recognized for excellence by the International Skiing History Association in 2010.

I have been backcountry skiing in the Cascades since the late 1970s. Over that time, participation in backcountry skiing, both locally and nationally, has grown dramatically. I don’t have formal statistics, but my experience suggests that the number of backcountry skiers has doubled several times in the past 25 years. At the same time, the number of OSVs has also grown and the ability of these vehicles to penetrate rugged and remote backcountry terrain has undergone a revolutionary change. While snowmobiles were limited to gentle roads and trails in the 1970s, they are now capable of climbing slopes as steep as 45-degrees, terrain challenging even for expert skiers.

In my experience, motorized winter recreation is fundamentally incompatible with non-motorized winter recreation. The noise and exhaust created by OSVs, while unpleasant, is not really the issue. The key reason for incompatibility between these user groups is the ability of motorized users to travel much faster and farther than non-motorized users. The key resources sought by non-motorized winter recreationists are untracked snow and (for many) a sense of solitude. Motorized users, because of the huge disparity in the speed at which they travel, “consume” these resources much faster than non-motorized users do. The scale of the disparity is on the order of 10-to-1. In a few hours, a group of OSV users can track out an area that would take many days for non-motorized users to cover.

For this reason, non-motorized recreationists generally regard areas used by OSVs to be unsuitable for non-motorized use. This leads me to conclude that the proposed travel management rule for OSVs is flawed. The section “Background and Need for the Rule” states:

"A key difference between OSV use and other types of motor vehicle use is that, when properly operated and managed, OSVs do not make direct contact with soil, water, and vegetation, whereas most other types of motor vehicles operate directly on the ground. Unlike other types of motor vehicles traveling cross-country, OSVs traveling cross-country generally do not create a permanent trail or have a direct impact on soil and ground vegetation. In some areas of the country, OSV use is therefore not always confined to roads and trails."

From this premise, the proposed rule appears to conclude that the impact of OSVs is so much less than other motorized vehicles that forest managers should be able to designate OSVs as allowed except where specifically prohibited. In contrast, the normal rule for motorized vehicles specifies that such vehicles are prohibited except where their use has been explicitly allowed. Because OSVs can travel cross-country, I believe that their impact, from the standpoint of incompatibility with non-motorized users, is actually greater than dry-land motor vehicles. Therefore, I think that the assumption of minimal impact by OSVs is wrong and the provision for “allowed unless prohibited” should be discarded.

The key issue surrounding the use of OSVs is the problem of incompatible user groups. Damage by OSVs to trails and cross-country areas does occur (especially in early and late winter, when snow depth is low) but that is not the main reason why OSV rules need to be revised. The revised rules must address the problem of incompatible use. This will require study in each forest district of past, present, and projected future use by both non-motorized and motorized user groups with the goal of designating separate areas for these groups. I don’t think this has been done in my region, the Washington Cascades, so I don’t think past administrative decisions in this region provide an adequate basis for future management.

I believe that the OSV exemption in Subpart B of the 2005 Travel Management Rule should be removed. I think individual Forests should be allowed to designate areas for OSV use, but I think the “allowed unless prohibited” approach should be abandoned. I think the Forest Service needs to take a hard look at where motorized use is truly appropriate. The current rules have failed to keep up with the advances in OSV capabilities, and a revision is needed.

Thank you for the opportunity to comment on this important issue.

Sincerely,

Lowell Skoog
Seattle, Washington
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Note: I edited my comments here for clarity after submitting them to USFS.

For what it's worth (yeah, I know it's late) here are some guidelines that The Mountaineers distributed a while back regarding the proposed rules:

[size=10pt]Concerns and Recommendations

1.  Individual forests or ranger districts can choose to implement an “open unless designated closed” approach (the status quo) or a “closed unless designated open.”

Concern: This would allow ranger districts to take no action – leaving areas open to OSV use as they are currently. A number of areas could experience very negative impact to the human-powered experience if OSV use were allowed. We would like to see the Forest Service to better manage conflict areas.

Our recommendation: The Forest Service’s travel management rule for off road vehicles (the non-winter equivalent of OSVs) is the ‘closed unless designated open’ approach. We would like to see this same approach for winter use.

2.  The draft appears to grandfather-in a range of past designations for over-snow vehicle use.

Concern: This could allow past administrative decisions that were not comprehensive in scope, analysis, or public involvement to count as travel plans. While some Forests or Ranger Districts might have undertaken plans aimed toward minimizing user conflict and resource damage, and involved the public in a meaningful way, we do not feel this has been the norm in Washington State.

Our recommendation: We would like to see a process that identifies aspects of what a comprehensive process looks like and that calls for Forests to undertake a comprehensive planning.

3.  Mention of other types of winter travel in the draft

Concern: The draft nowhere mentions other types of winter recreation or travel (i.e., skiing, snow shoeing, etc.). Only OSV use and impact are mentioned. We are concerned this will translate into Forests not having to take conflicts between motorized travel and human-powered travel into account.

Our recommendation: The Forest Service needs to issue a final over-snow vehicle rule consistent with Executive Order 11644. Executive Order 11664 requires the regulation of off-road vehicles – including OSVs – to specific routes and areas. By issuing a final over-snow vehicle rule consistant with EO 11644, each ranger district must take into account motorized and human-powered recreation uses, OSV impact on wildlife and other forest resources.
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From an email sent by The Mountaineers on 8/15/2014:

[size=10pt]Last month, we encouraged folks to share their thoughts on the Forest Service’s draft rule for over snow travel management. Winter Wildlands Alliance (WWA) exceeded their goal of generating 1,000 comments to the Forest Service on this issue. Most of the comments are now posted on regulations.gov, and of the 1,560 comments posted, the vast majority - 72% (1,122) - reflected the WWA's talking points, or were in support of creating space for both quiet and motorized winter recreation.

Winter Wildlands staff went to D.C. to meet with the Forest Service decision makers and share comments. During those meetings, the Forest Service told the WWA they were placing a lot of weight on public comments, reflecting the power of our individual voices on conservation issues.

Congratulations to everyone who submitted comments to the Forest Service! We will continue to provide information and opportunities for you to weigh in on issues like these.
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