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12 June 2007
Kris Rutledge
Environmental Coordinator/Travel Management Team Leader
Ashley National Forest
355 N. Vernal Ave. (sent by email 6/12/07, PM)
Vernal, UT 84078

Dear Kris:

Now that the travel management planning process has started--thank you for a good discussion and presentation in Duchesne on 6 June--we want to provide a couple of comments and concerns from the outset and make sure they are part of the official record and your deliberations. As the process moves forward, described a few nights back, we will provide additional comments.

We are mystified as to why the High Uintas Preservation Council is never invited to be a partner and thus be a participant in the early formal discussions of such far reaching and important projects such as travel planning and forest planning. Starting in 1976-1979 I worked with the Wilderness Society on Ashley National Forest/Uintas issues, from 1979-1996 with the Utah Wilderness Association, and from 1996 until this day with the High Uintas Preservation Council--a continuous 31 years I have worked on High Uintas issues!

That noted, we want to offer two observations and suggestions.

First we checked our records and and can find nothing that substantiates the travel planning decision to allow ATV/OHV travel on “...established, undesignated routes...” on the Vernal Ranger District. The 6 October 2003 News Release notes, in fact, that motorized use is being restricted (finally) on the Vernal Ranger District to “...reduce the number of user-created trails and roads...” and to require motorized use occur on “designated roads and trials...” This was done to be consistent with the other districts on the forest and other national forests.

Thus we think it is imperative, though difficult, to promptly and clearly note the intent of the closure order was to restrict travel to designated routes, not established, undesignated, user-created routes. In fact, this appears to be counter to Forest Service policy.

Starting the travel management planning process by allowing user created roads to be unofficially designated seems, as well, counter to policy and certainly disingenuous in a travel management process as it ascribes a priority and approved
status to something illegally created and certifies a higher status to a single user group. ATV/OHV users simply argue these roads are now in use and to close them would restrict opportunities thus giving those groups and illegally created routes a status that assures these routes will be analyzed as legal routes from the inception of the planning process when, in fact, they don’t legally exist on the Ashley National Forest.

We have no problems with these routes being recommended for travel during the NEPA/planning process. And that is where they belong--recommendations during the formal travel management planning process. Starting the process with these illegal user created routes officially recognized, having never been analyzed, is inappropriate and literally negates the whole concept of travel management planning.

Second, as a suggestion to analyze as part of this travel planning process we offer an alternative which would assure that all inventoried roadless areas harbor no routes or trails open to motorized traffic. This assures a true diversity in travel management planning, assures sensitive landscapes will not be open to possible environmental degradation, assures ecological diversity, wildlife protection and truly creates and assures opportunities are diverse and engaged! This also meets the spirit of much of the discussion of the Ashley National Forest’s recreational niche in that recreational opportunities are broad, diverse and consistent with environmental conditions.

This should not be perceived as a blanket support for ORV/ATV use on the majority of the Ashley National Forest (roadless areas, of course, constitute less than half of the acreage on the Ashley) because on the roaded portions of the forest there are also crucial values not consistent with ATV/OHV use as well. But it assures ATV/OHV use will be focused on the areas where it already occurs and where landscape/environmental values are more consistent with the kind of use and impacts ATVs/OHVs create. We fully support allowing ATVs/OHVs to use the established, inventoried and designated forest road system where safety and environmental issues have been properly evaluated

Of course, as the process moves forward we will provide more detailed comments. Please confirm that our suggestion/alternative has been received, accepted and placed into that pot of suggestions to be mapped and analyzed as was discussed in Duchesne a few days back.

Hope to hear from you soon. Thanks much.


Dick Carter

cc: Kevin Elliott, Forest Supervisor
Nicholas Schmelter, Vernal District Ranger

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