Thursday, July 31, 2014


On June 18, the Forest Service released its long-awaited draft federal rule for designating areas as open or closed to winter motorized vehicles. It’s a good first step, but the proposed rule misses the point on a couple of key details. Please take the time to comment. I just did.

 July 31, 2014
Joseph Adamson
Recreation, Heritage, and Volunteer Resources Staff
1400 Independence Avenue SW., Stop 1125
Washington, DC 20250- 1125

Dear Mr. Adamson,

Thank you for the opportunity to comment on the Forest Service’s proposed rule for over-snow vehicle use.  As and avid backcountry enthusiast I have been traveling and exploring the winter landscapes managed by the USDA Forest Service for over 25 years. As a guide and wildlife biologist I have done so by ski, snowshoe, and snowmobile. Mostly, however, my time in winter landscapes is purely recreational and my preferred means of travel is by ski.

Backcountry and Nordic skiing have a long history on the snowscapes managed by the US Forest Service. It is a traditional use that has been around since Gifford Pinchot became the first Chief of the Forest Service in 1905. And for good reason -- traveling silently through our majestic public lands skiing is one of the most elegant and least impactful forms of winter recreation.

In recent decades both ski and snowmobile technology has greatly improved. Coupled with an increase in the popularity of backcountry winter recreation, lands managed by the U.S. Forest Service are experiencing unprecedented use. Inevitably, this increase in use has lead to social conflict in the most popular and accessible snowscapes. For reasons that include public safety and the conservation of wintering wildlife, it is time for snowmobiles and other over-snow vehicles be held to the same standards as motorized vehicles in other seasons.

By designating specific trails and areas where over-snow vehicle (OSV) use may occur, winter travel planning is an opportunity to bring balance to the backcountry, address different recreational preferences and minimize resource damage on NFS lands. The Forest Service mostly misses that opportunity with this proposed rule, but still has a chance to get it right.

While I appreciate that the draft fixes a flaw in the 2005 Travel Management Rule that made management of snowmobiles optional, it does little to promote consistency across seasons or types of motor vehicle use.  I recognize that OSVs do have different impacts than ORVs - for example, cross-country travel is appropriate in some places – but they still impact the environment and other users.

In order to address this, I urge the Forest Service to incorporate the following recommendations:
  • The proposal to allow an “open unless designated closed” approach (the status quo) or a “closed unless designated open” approach (same as ORVs) is inconsistent, and confusing. The final rule should require a “closed unless designated open” approach to OSV management in order to promote seasonal and geographic consistency.
  • The draft seems to grandfather-in a range of past designations for over-snow vehicle use. Only plans that address a whole Forest or Ranger District, minimize user conflict and resource damage, and had meaningful public involvement should be carried forward. If the Forest Service can’t demonstrate how this was done, and that a plan is still sufficient to address current conditions, it should be redone. Allowing past decisions without showing how the “minimization criteria” are met is inconsistent with Executive Order 11644 and 11989, which the agency clearly must follow in issuing this rule.
  • The proposed definition of an “area” would allow designated OSV areas nearly as large as a Ranger District, with impacts of trails in that area exempt from analysis. If you combine this with an “open unless closed” approach, and allow past decisions covering only small areas, I am concerned the Forest Service would avoid taking a hard look at where motorized use is truly appropriate. Also, trail systems concentrate use and some impacts more than cross-country travel. In the summer, ORV play areas are small so I can understand why individual trails aren’t analyzed. For over-snow use, areas could be hundreds of thousands of acres, including hundreds of miles of trails. The rule should make areas smaller, with clear geographical boundaries, and require trails analysis.

Overall, the draft is a step in the right direction, but it does little to improve conditions for human -powered winter recreation.  Perhaps the simplest solution would be to remove the OSV exemption in Subpart B of the 2005 Travel Management Rule, and add language on the value of cross-country snowmobile travel so individual Forests could still designate open areas. This approach would bring winter travel management planning in line with travel management during other times of the year, and ensure consistency across all National Forests.

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

Forrest G McCarthy
Jackson, WY

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