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The Ashley National Forest (ANF) is now deep into the motorized travel planning process with a draft Environmental Impact Statement (DEIS) out for comment until the middle of July.

The DEIS went to great lengths to note all terrain vehicle (ATV) registrations and sales both in Utah and local Uinta Basin communities have increased dramatically. Yet in no way did the DEIS suggest how that increase translates to actual increased use on the Ashley National Forest and why the ANF feels compelled to respond in kind to that increase. Nor does the DEIS respond to the effects that this increased use will have on the need for a concomitant increase in monitoring and forest funding to patrol and enforce the travel plan. The DEIS argues in vain that education is the most effective enforcement tool. It has not worked in the past, given the plethora of unauthorized and undesignated (illegal) routes. And there is nothing in the DEIS that indicates or highlights any additional educational efforts that will be utilized to assure that education is, indeed, the most important enforcement tool.

The DEIS warns those who comment to focus only on site-specific routes, not the broader mileage indicators of each alternative. Yet, the indicators, without exception, focus on miles of routes, not specific routes or their distribution! The indicators are the basis for analyzing the impacts of each alternative. The DEIS clearly notes, “Measurement indicators were developed to gauge the effects of the alternatives on each resource. These indicators are used consistently throughout the document and provide the reader a basis for comparison of the alternatives.” How the DEIS/ the Ashley National Forest can urge reviewers to ignore the preponderance of indicators and focus elsewhere is beyond the pale!

The DEIS plainly notes the increase in designated routes proposed by the DEIS actually exists on the ground as undesignated and unauthorized routes (illegal routes largely pioneered by ATV users) and because of that had no actual impact on the environment since the impacts already occurred. Thus, this DEIS becomes a document constructed to ignore and dismiss direct environmental impacts! It is a convenient way to pass the proverbial buck forever backward by excusing itself from taking into account environmental impacts for those routes that the forest is now designating because they have, inappropriately, always been there.

The answer: assume these newly proposed designated routes are just that--newly designated. Analyze them in that context. It is time the Forest steps forward!

Butterfly by M. PettisTo be consistent with other Utah national forests, the Ashley chose to allow dispersed camping 150 feet off designated routes. The ANF then bypasses that rule by proposing to designate hundreds of miles of short spur roads longer than 150 feet--many of them previously undesignated, unauthorized (illegal) routes--in order to meet local dispersed camping concerns. Other than a qualitative statement that these routes were requested by motorized campers, there is no actual evaluation as to demand or need. A simple demand to camp here is not appropriate. This 150 foot exception has bent itself in knots trying to accommodate whiny ATV users who continue to complain that they’ve been camping illegally on their own, user-created, undesignated, unauthorized (illegal) routes for a long time and demand to continue that use.

By now, good reader, you won’t be surprised to know that the DEIS enforcement analysis concludes that the more routes that are closed, the more difficult it will be to enforce and monitor because ATV users will simply break the law! This becomes an excuse to open more routes. The DEIS cannot continue this mirage that fewer open routes increase enforcement difficulty because of threats of non-compliance by ATV users.

The DEIS proposes some 128 miles of motorized routes be designated in roadless areas-- the majority of them within the dispersed-camping-exception-route! Most of these routes fall within the previous undesigned/unauthorized routes now being designated.

While one can’t make the mileages align, it appears the ANF is proposing an increase in 44 miles of motorized trails (183 miles), an increase of 74 miles of motorized roads (1,431 miles) and an indeterminate number of dispersed camping routes! It is an amalgamation of travel routes rather than a travel plan. It is not based on a policy or an idea, but on who wants a motorized loop, a longer route, a favorite campsite.

Confusion upon confusion.

Dick Carter

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