WWA Seeking 1,000 Comments in 45 Days

Last April Winter Wildlands Alliance won a historic victory when a Federal Court agreed with our claim that the Forest Service has an obligation to manage snowmobiles under the same guidelines used for all other off-road vehicles in other seasons. The court ruled that the exemption of over-snow vehicles (OSVs) in the 2005 Travel Management Rule was unlawful and it directed the Agency to develop a new rule outlining the process under which each national forest will create a winter travel plan to complement their existing summer travel management plans. This new Over-Snow Vehicle Travel Rule (OSV Rule) is a huge opportunity to protect winter ecosystems and bring balance to the backcountry.

But, the proposed rule released today falls short of its potential, and your engagement will be crucial if the Forest Service is going to get it right. Stakeholders have just 45 days – until August 4 — to comment on the draft. WWA has an ambitious goal to rally at least 1,000 backcountry and Nordic skiers, snowboarders, snowshoers and winter mountaineers to weigh in with unique comments to ensure the Forest Service finalizes a rule that meets its obligation to minimize the impacts of winter motorized use, and finally brings balance to the backcountry.

The draft says each national forest must now take a proactive approach to designating appropriate trails and areas for winter motorized use as either open or closed, or with certain restrictions (like dates or a minimum snow depth). Forests that have previously completed comprehensive winter travel plans also would not have to redo them. Both of these aspects of the rule are great, but when we dig a little deeper the draft is problematic.

  •  The draft would allow individual national forest units to choose either an ‘open unless designated closed’ approach or the opposite ‘closed unless designated open’ approach, as is the case with all other off-road vehicles in all other seasons. This element of the draft is inconsistent, and would be confusing on the ground.
  • The draft also appears to grandfather in past decisions about over-snow vehicle use, regardless of whether they were comprehensive, minimized conflict and resource damage, or involved the public. Administrative decisions that did not allow stakeholder involvement, or that apply to only part of a forest, should not be allowed to pass for proper planning.
  • Also, the rule proposes to change the definition of an “area” to include landscapes even broader than a Ranger District, with groomed trails in that area not subject to analysis. Groomed trails concentrate use, and cross-country snowmobile travel, while certainly appropriate in some places, also has impacts. Both of these deserve a harder look than is possible when designating areas that could be hundreds of thousands of acres as the draft proposes.

The Forest Service needs to hear from skiers and snowshoers about how management of the backcountry has the potential to improve your experience on national forest lands — or how a lack of management has degraded your experience. This is a chance for WWA members to share your story.

The Take Action page at https://winterwildlands.org/take-action/provides everything you need to comment. Personal comments are proven to make the biggest difference to decision-makers — so please take 10 minutes to weigh in on this once-in-a-generation opportunity to impact how the backcountry is managed.
Once the public comment period closes the Forest Service will analyze all comments and will issue a final rule no later than September 9, 2014 as directed by the court. After the final rule is released the Forest Service will issue guidance and a schedule for developing individual winter travel plans on national forests.
The draft rule can be viewed online here: http://www.regulations.gov/#!documentDetail;D=FS-2014-0004-0001
For questions on the draft rule, or help writing comments please contact:

Hilary Eisen
Recreation Planning Coordinator

So maybe it was Yogi Berra the baseball player, not Yogi Bear the Jellystone cutup, who famously quipped, “It ain’t over ’til it’s over,” but either way those words never rang truer than with the infamously long-running process to finalize a winter use plan for Yellowstone National Park.

The effort to permanently protect Yellowstone’s magical winter ecosystem ain’t over yet, but it’s SO close. It is critically important the Park Service hear from you now.

Please join me in urging the National Park Service to continue Yellowstone’s transition to cleaner, quieter and healthier conditions. Thanks in large part to the groundswell of support from concerned citizens like you, Yellowstone has made a remarkable recovery from a decade ago when our nation’s first national park looked, sounded and smelled more like a wild west race track than the winter sanctuary it was meant to be. Fewer vehicles, commercial guiding requirements, and tighter restrictions on noise and emissions have led to a Yellowstone today that is cleaner, quieter, and far better for skiers and snowshoers and for the Park’s iconic winter wildlife. However, those gains are only temporary until they are built into a long-term winter use plan. Last month Park officials put forth a draft long-term plan for public comment. The proposed plan is on the right track, but it backslides in a couple of important areas.

Deadline for Public Comment is June 17. Please take a few minutes right now to write a personal letter using the sample letter and talking points below. Be sure to include information about your personal experience as a skier, snowshoer or quiet winter visitor to Yellowstone in winter.

Sample Letter:

Dear Superintendent Wenk :


As a skier [or snowshoer, winter hiker, etc.] who values the natural sights and sounds of Yellowstone in winter, I appreciate improvements to the Park ‘s winter environment resulting from reduced motorized traffic, requirements for cleaner, quieter machines and commercial guiding of snowmobiles. I applaud your commitment to a plan that leads to a cleaner, quieter Yellowstone and I appreciate your renewed emphasis on better services for sk iers, snowshoers and other low-impact winter visitors by designating certain side roads as ski and snowshoe routes.

Your proposed rule has much to commend including more stringent noise and emission standards for all vehicles and reducing the park ‘s winter speed limit to 35 mph on all transportation routes. However, I am deeply concerned that the proposed rule ask s whether the very provisions you’ve stated are the foundation of your plan for a “cleaner and quieter Yellowstone” should be dropped, delayed or not required of all vehicles. Please do NOT back slide on these requirements!

More specifically: Do not allow some snowmobiles to be noisier and dirtier than others.

Instead, require ALL snowmobiles to meet the same high standards for noise and emissions. The proposed rule makes clear that “racing snowmobiles, or operating a snowmobile in excess of 35 mph” will be prohibited. This standard must be maintained on all oversnow vehicle road segments for the safety of skiers, snowshoers and others and for the benefit of wildlife. Implement “Best Available Technology” standards no later than the 2015-2016 season. Your own studies have determined these standards are essential to limiting air and noise pollution, especially given the increased numbers of vehicles allowed through your proposed “transportation events.” Please support better services for sk iers and snowshoers by investigating the feasibility of a system of huts or yurts to accommodate non-motorized access to the Park ‘s interior.



[Your name]


Additional Talking Points:

  • Support increasing demand by visitors desiring snowcoach access to carry skis or snowshoes into the park . Under the current Temporary Use Plan, the maximum daily number of snowmobiles at the West Entrance has been 160 per day. Despite the fact this cap has never been reached, the proposed rule would increase this limit to 230 snowmobiles per day at the West Entrance by decreasing the number of snowcoaches per day from 34 to 23. This directly contradicts recent trends and appears to favor snowmobile access over skier-friendly snowcoach access.
  • Snow Bikes. Snow bikes, also known as fat bikes, which are bicycles designed specifically for over-snow travel, are an increasingly popular form of human-powered winter recreation. While the use of snow bikes was not analyzed in the environmental impact statement, the proposed rule nevertheless expressly prohibits them on oversnow routes in Yellowstone. Rather than outright prohibition, the rule could instead leave room for future analysis of snow bikes under a separate adaptive management process.


Please ensure a better future for Yellowstone by submitting comments today. The deadline for comment is June 17.


Click on the following link, which will take you to the NPS comment webpage: http://www.regulations.gov/#!submitComment;D=NPS-2013-0001-0001


You may also comment by mail to:

Yellowstone National Park

Winter Use Proposed Rule

P.O. Box 168 Yellowstone NP, WY 82190

Click here to learn more about the Proposed Rule.


Even though this news is delivered on April 1st, this is no joke. It’s a historic win for Winter Wildlands Alliance and for all those who value piece and quiet in the winter backcountry. All of us at WWA offer a huge thanks to Advocates for the West and attorney Laurie Rule who presented a compelling case on our behalf.

Following is a news release we issued this morning: Federal Court Overturns Forest Service Exemption of Snowmobiles. Read more.