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The Ashley National Forest, as you know, has undertaken a massive travel management planning process, releasing two scoping documents late in 2007 which will be used to guide the preparation of two Environmental Impact Statements which will determine where motorized travel will be allowed or restricted on the forest (see HUPC LYNX 12/07.) Comments were due early in January 2008. Thank you for your comments!

This scoping effort represents the early and formal process wherein a proposed alternative has been offered but not yet analyzed in the context of a formal National Environmental Policy Act (NEPA) review.

While these scoping documents advanced a proposed action outlining literally hundreds of travel designations, none of them have been reviewed or analyzed for their impacts upon the environment, including wildlife, other recreational uses, manageability, roadless values and enforceability, given shrinking Forest Service budgets, person power and law enforcement capabilities. None have been analyzed individually or cumulatively, with respect to their impacts upon water quality, riparian areas, soil stability, erosion, introduction of non-native invasive weed species, noise pollution (to both humans and wildlife), and aesthetic impacts. This analysis must exceed a point-in-time and recognize these impacts will occur for years while the motorized use is allowed in a particular area and then to some degree for many years after the use has been terminated.

Pine Marten by M. PettisThis is particularly true with respect to a plethora of wildlife-related issues, ranging from sensitive species, management indicator species, and threatened and endangered species. Impacts to dispersal and travel corridors, disturbance of resting areas, hiding cover, roosting and nesting areas are all crucial to a full evaluation and analysis of travel planning impacts. Impacts to effective habitat are vitally important--the simple matter of fact is not all terrain is effective habitat. Wild grazing/browsing critters are notoriously ineffective feeders and need considerable habitat that is not disturbed by noise, fragmentation of crisscrossing roads and motorized trails. Carnivorous forest creatures need considerable unfragmented open space and terrain--the linear nature of a motorized route is rarely an effective measure of loss of habitat as studies routinely reveal that anywhere from 1/4 to 1/2 mile from such a route is often rendered ineffective and avoided. Simply brushing this issue aside by suggesting there are other areas where motorized use is not prevalent, thus minimizing the issue(s) where it is prevalent, misses the biological concern of effective habitat, territoriality, home ranges and a host of other competing environmental constraints.

The concern of determining thresholds is of particular concern because it represents one of the most significant and usually overlooked issues with respect to travel management planning-- monitoring. Monitoring is directly related to manageability: how will these travel designations be systematically monitored, over what time frame, by whom on the Ashley’s staff, and with what budget? What will trigger the Ashley to reconsider a particular travel designation?

It is also notable that the proposed action must be analyzed in the context of appropriate alternatives. Ironically, the whole process has been initiated because ATV/ORV motorized recreation has created significant environmental issues, concerns and impacts which could last for long periods of time, yet the proposed action increases the number of miles of open roads, motorized trails and creates a whole new, as yet to be fully defined, road classification-- “potential dispersed camping routes,” which consists of 39 miles, forest-wide, of motorized “spurs” at least 150 feet long, up to 300 feet long and in some cases even longer. That could be something like 1,373 of these 150 foot spurs, 686 of the 300 foot spurs, or somewhere in between! Whatever the case, it is a phenomenal amount of new road classifications and we believe well outside of the regulations which require dispersed motorized camping spurs to be no more than 150 feet from open and designated roadways.

The Ashley’s proposed action simply offers more motorized access, not less, which would be expected, and creates a plethora of new roads and a new road classification.

Again, we asked the Ashley to include and select an alternative that assures all inventoried roadless/ undeveloped 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! It meets fundamental core issues in forest planning and, notably, actually 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.

Draft EISs are expected later this year.

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