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Comment Now: National Park Service Fee Hike

The National Park Service recently announced that it is considering increasing entrance fees to $70 at 17 of its most popular parks – Acadia, Arches, Bryce Canyon, Canyonlands, Denali, Glacier, Grand Canyon, Grand Teton, Joshua Tree, Mount Rainier, Rocky Mountain, Olympic, Sequoia and Kings Canyon, Shenandoah, Yellowstone, Yosemite, and Zion. This increase would double, and in some cases triple, current entrance fees. We are very concerned about how the proposed fee increase would impact the public’s ability to access and enjoy the National Parks and we oppose the fee increase in its current form. If you enjoy visiting National Parks we encourage you to comment on the proposed fee hike.

Almost all of the Parks included in the proposed fee hike are world-class destinations for skiers, many of which have a ski season that extends into the peak season when the proposed fee increase would be in place. However, our concern about this fee increase goes far beyond backcountry skiing. We strongly believe that entrance fees should never be set at levels where people are priced out of enjoying their public lands.

The Park Service is proposing this fee increase, which is projected to generate $68 million, in order to address an $11 billion maintenance backlog. We accept that fees increases are appropriate or necessary in some limited circumstances but we cannot and should not address a multi-billion-dollar maintenance backlog on the backs of Park visitors. This fee increase strikes us as unreasonably high, particularly when proposed in conjunction with overall Department of Interior budget cuts to the tune of $1.5 billion, including a $380 million cut to the Park Service budget. This backlog is the result of decades of systematic underfunding of the land management agencies, including the Park Service, by Congress. A much more appropriate course of action would be for the Administration to work with Congress to appropriate adequate funds for the Park Service each year and for Congress to pass the National Park Service Legacy Act, which would establish a dedicated park maintenance fund to invest a more substantial amount toward the Park Service repair backlog.

The Park Service is accepting comments on the proposed fee increase until November 23.

Click here to submit a comment

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Final Comments Due November 20 for Lassen National Forest Winter Travel Plan

On October 3, 2017, the Lassen National Forest released a Revised Draft Environmental Impact Statement (RDEIS) for its new winter travel plan. The final public comment period on the plan closes November 20. The Lassen, which straddles California’s northern Sierra and southern Cascades and surrounds Lassen Volcanic National Park, is the first forest in the country to write a comprehensive winter travel plan under the 2015 Over-Snow Vehicle (OSV) Rule, so what happens here is very likely to impact winter travel planning across the country.

Forest planners want to get it right on the Lassen, and have assured us that they are eager to incorporate substantive comments into the final plan, so we hope to get as many skiers and human-powered winter enthusiasts as possible to send in comments. Read on for some quick background and our notes and concerns on this latest revised draft, or click here to send the forest service your comments using our handy template.

Quick Background

As the guinea pig (or, perhaps, avalanche poodle), the Lassen NF has been working since 2015 — with some stops, starts, and re-dos — to set a course for how to go about writing a winter travel plan and complying with the OSV Rule. As we go through the process with them, we’re also learning – how to clearly articulate our winter travel planning vision to the Forest Service, how and when to reach out to other stakeholders, and how to better engage you – our members and supporters.

The forest published an initial draft Environmental Impact Statement (DEIS) in early 2016. The 2016 DEIS analyzed four Alternatives, or potential plans, including one based on the “Skiers Alternative” submitted by WWA and Snowlands Network. At that time, we told the Forest Service that we supported the skiers alternative, with modifications to account for impacts to wildlife, wilderness lands, and natural resources (exhibit A of us learning as we go – when we developed the skiers alternative we left too much to interpretation and the Forest Service’s interpretation wasn’t quite in line with our vision).

After considering all of the public’s comments on the DEIS the Forest Service wrote a “Selected Alternative”, or draft plan, which they put out for public review in August 2016.  This 2016 draft plan was a slight improvement over the status quo but did not meet the requirements of the OSV Rule on many fronts. For example, the plan did not propose management of snowmobiles under the new legally mandated framework of “closed unless designated open.” Instead, it proposed the opposite, identifying a few areas to close to over-snow vehicles and leaving the rest of the forest open to OSVs by default.

In September 2016 Winter Wildlands Alliance, Snowlands Network, and 6 other organizations filed objections to the Lassen’s draft winter travel plan. In response, the Forest Service went back to the drawing board to develop a new alternative and revise their draft Environmental Impact Statement.

Which brings us back to this newly-released Revised Draft Environmental Impact Statement (RDEIS) and the current comment period.

We Support the New Alternative 5

The new draft plan contains a much more thorough environmental analysis than the 2016 version, and also includes an encouraging new alternative — Alternative 5 — developed in response to objections.

The 4 alternatives that had been in the 2016 DEIS are still included, with a few modifications to bring them (mostly) in compliance with existing laws and policy. All of the alternatives now identify specific areas where OSVs are allowed and prohibit OSV use outside of these areas. This corrected approach is a big improvement. However, the Forest Service’s “Modified Proposed Action” (Alternative 2) is otherwise almost exactly the same as what was proposed in 2015 — it does not protect important quiet recreation areas or wildlife habitat and would designate as open for OSV use low elevation areas that rarely receive snow. Likewise, Alternatives 3 and 4 are also essentially the same as in 2015.

Alternative 5: Areas and Trails to be Designated under Subpart C and Groomed for OSV Use (Click for larger version)

Alternative 5, however, addresses all of the concerns that we had with the previous draft plan, and lays out a winter travel plan that balances motorized winter recreation with quiet recreation and protection of wildlife and the environment. Alternative 5 designates OSV use areas in places where people actually go snowmobiling (preserving all of the opportunities the snowmobile community values) and doesn’t designate places that don’t make any sense (like low elevation areas that don’t get snow).

Alternative 5 also does a much better job of protecting wildlife habitat – not designating any critical deer winter range as open for OSVs – and doesn’t designate OSV use within any of the quiet recreation areas that we identified. In addition, Alternative 5 protects the quiet, non-motorized character of the Pacific Crest Trail by prohibiting OSV use within at least 500 feet on either side of the trail, except at a few designated crossing points. Finally, alternative 5 would designate a 12-inch minimum snow depth standard across the forest – meaning that OSV use would not be allowed on any trails or in any areas until those trails/areas have a minimum of 12 inches of snow. This snow depth standard protects underlying resources including soils, vegetation, and subnivian habitat, and also complies with State of California OSV grooming standards.

Your Comments Really Matter!

The Forest Service has assured us that they do not have a preferred alternative at this time. All options, including everything in Alternative 5, are on the table. For this reason, it’s incredibly important that people participate in this public comment period. Whether you’re a local who can speak to particular areas on the forest, or somebody who’s never set foot in northeastern California but cares deeply about winter travel management on National Forest lands, this comment period matters. Alternative 5 sets a really good course for the Forest Service as it embarks on winter travel planning, and provides a good example for other forests to follow. We appreciate the effort that the agency has put into developing this alternative and we’d love to see the final plan closely resemble it.

We urge you to comment in support of Alternative 5 before the comment period closes on November 20, and we’ve developed a nifty online commenting portal to help you do so.

Click here to comment now.

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An Open Letter to the Snowmobile Community

Re: Boise, Payette and Bridger-Teton National Forest litigation

Dear Fellow Winter Enthusiasts,

I understand many of you are upset with Winter Wildlands Alliance right now. I also understand the catalyst for your anger is a recent round of alerts from the Idaho State Snowmobile Association and American Council of Snowmobile Associations warning that Winter Wildlands is attacking snowmobiling on the Boise, Payette and Bridger-Teton National Forests through a frivolous lawsuit.

A few of you have reached out directly demanding explanation. Thank you. We’re glad for the opportunity for dialogue. I appreciate and respect your passion for snowmobiling and for winter outdoors. I share your passion for winter and public lands, and I think I understand your anger. I’d be mad as hell if I thought someone was trying to shut me out of my public lands or keep me from doing what I love in a responsible way. The privilege of adventuring into our wild snow-covered landscapes is one I hold dear and I’m here to tell you, despite what you’re hearing from certain leaders in the snowmobile industry, Winter Wildlands has no interest in denying that privilege to anyone.

Mark Menlove and his family using sleds to access a backcountry yurt on the Uinta-Wasatch-Cache National Forest. Photo by Troy Boman.

Many Winter Wildlands members enjoy riding snowmobiles, either as part of their ski day or as another way to have fun in the snow. I myself have hundreds of hours on a sled. My family had snowmobiles growing up (though those old blue SnoJets were a far cry from today’s machines) and just before coming on board with Winter Wildlands Alliance I spent three winters commuting daily by snowmobile to and from a remote cabin where my family and I lived.

I still use a snowmobile on occasion to access backcountry huts and remote trailheads, and I know from experience I can always find common ground with a fellow winter enthusiast. I also know if I make the effort I can find mutual understanding of other perspectives and mutual respect for those who share my passion for winter. Invariably I find far more that unites us in our shared love of winter than anything that might divide us. In an effort toward understanding and respect, I hope you will hear me out in response to the recent alerts.

First, in regard to the litigation we recently filed, here’s the backstory and intent:  In 2015 the Forest Service issued a regulation known as the Over-Snow Vehicle Rule directing each national forest unit that receives regular snowfall to gather public input, analyze current conditions and uses, and then based on that information determine which areas on the forest should be designated as open to snowmachines. The rule includes a passage known as the grandfathering clause that allows forests to carry prior designations into a new winter travel plan if those decisions originally included public input and also meet the rule’s criteria requiring that open areas be located in a way that minimizes impacts to natural resources, wildlife and other recreational uses.

The point of the lawsuit is to ensure that ALL stakeholders have an opportunity to provide input into how each forest manages winter use.

Three forests – the Boise, Payette and a portion of the Bridger-Teton – are interpreting the grandfathering clause to mean they can simply add a sticker to their current winter travel maps, in each case a hodgepodge of piecemeal decisions going back as far as the 1970s, and call it their new winter travel plan. No chance for public comment, no analysis of current conditions, just a rubber stamp that says they’re done. Incidentally, these three are the only forests in the nation attempting this approach. We don’t agree with their interpretation, we’ve taken our concerns directly to each forest to no avail, and now we’re asking the court to clarify the intent of the grandfathering clause.

The point of the lawsuit is to ensure that ALL stakeholders – snowmobilers, skiers and those of us who are both – have an opportunity to provide input into how each forest manages winter use. If forests just cement the status quo then we all lose the opportunity for intentional, balanced planning that will affect future recreation on public lands for years to come. We all know the backcountry is becoming more crowded each winter, with more of us using new technologies, both motorized and non-motorized, to venture out into our favorite places. Thoughtful planning with input from all of us will ensure we can all continue to enjoy our shared public lands in the future.

Winter Wildlands staff get ready for the approach to the Hellroaring Hut in Montana’s Centennial Mountains – 7 miles of snowmobiling followed by 3 miles of skiing.

We don’t take litigation lightly. We do understand it’s sometimes necessary as a last resort—when the feds aren’t listening. In the 17 years since Winter Wildlands Alliance was formed this is the fourth lawsuit we’ve filed against the Forest Service. Official snowmobile organizations have a similar track record as evidenced by the Idaho State Snowmobile Association’s recent lawsuit against the Clearwater National Forest and its lawsuit against the Kootenai/Idaho-Panhandle National Forest.

I don’t fault snowmobile organizations for turning to litigation when they disagree with actions taken by federal agencies. Petitioning the courts for clarification over government action is a right as fundamental to a working democracy as the right to free speech or the right to vote. I for one am deeply grateful we all have the opportunity to exercise that right. And for better or worse, in our great democracy, this is sometimes the only way to be sure things are done properly.

As to the broader claims that Winter Wildlands Alliance is out to eliminate snowmobiling or that we think we should have our kind of recreation but you shouldn’t have yours, let me be crystal clear: that is not true. Yes, we do advocate for balanced planning and management of our public lands to provide for some protected and accessible areas for quiet winter recreation – as just one component of public lands use in a range of other opportunities. That’s our mission. But that doesn’t mean we advocate against snowmobiles. We don’t.

It might be helpful to put those accusations in context: The alert from the Idaho State Snowmobile Association that ignited this round of anger toward Winter Wildlands is a fundraising appeal. I understand the need for fundraising in any organization but it’s disappointing to see some leaders in the snowmobile industry stoop to fear-based and intentionally misleading statements intended to pit snowmobilers against skiers, and to incite anger and distrust as a way of raising money. That approach sells everybody short, disrespects both the motorized and human-powered communities and divides us where we should be unified in our support and defense of public lands and our ability to use them responsibly.

I know there’s a better way to move this conversation forward, and I remain committed to open and respectful dialogue with all those who want to enjoy our public lands in winter. Winter travel planning, the very public process we’re trying to open up for all of us who use and care about the Boise, Payette, Bridger-Teton and other forests across the country, is one of the best ways I know to facilitate that open respectful dialogue. I hope you’ll meet us at the table to advocate for your preferences as snowmobilers and fellow public land owners.

Sincerely,

Mark Menlove
Executive Director
Winter Wildlands Alliance

The latest from the WWA Policy Desk

By mid-September many a skier’s thoughts turn to snowy days ahead, but this year we’re not the only ones praying for snow. With fires raging across much of the West and snow the only hope for truly extinguishing them, Ullr is getting a lot of requests these days.

Between fires and hurricanes it seems the environment is front page news every day. There’s a lot going on that doesn’t make headlines though – Secretarial Orders and legislation that may adversely impact our environment and the way we experience it for generations to come. Right before Labor Day weekend Interior Secretary Ryan Zinke issued Secretarial Order 3355, which mandates that Environmental Impact Statements (EIS) must be completed within 15 months and not exceed 150 pages. The intent of this order is to streamline National Environmental Policy Act (NEPA) reviews and more quickly approve infrastructure projects, which sounds okay at first—we’re all for streamlining bureaucracy as appropriate and had already seen the encouraging beginnings of a shift within the agency toward streamlining special use permitting—but if you look closer is pretty worrisome.

Agencies write an EIS when they need to examine how a proposed project will affect the environment or people. The EIS doesn’t determine the outcome of a decision-making process but it generates the information needed for an agency to make an informed decision, and gives the public a very important window to comment on and engage in the planning process. By setting an arbitrary timeframe and page limit, SO 3355 limits opportunities for public comment during the EIS process, curtails information-gathering (including scientific data collection – it often takes more than a year to gather necessary baseline information), and undermines environmental protections for our public lands. This is just the latest example of the Trump Administration’s continuing assault on public lands.

Meanwhile, things aren’t looking any brighter over in Congress. Last week the House Natural Resources Committee held a hearing on a trio of scary bills – The Federal Land Freedom Act (H.R. 3565), Planning for American Energy Act of 2017 (H.R. 2907), and State Mineral Revenue Protection Act (H.R. 2661). These bills all have two things in common – they all would undermine public ownership of public lands and advance privatization of oil and gas reserves on public lands.

This week, the same committee held a hearing on the SHARE Act (H.R. 3668) which, among other things, would allow road construction and motor vehicles (including snowmobiles) within designated Wilderness areas. The committee voted to advance this bill to the full House, moving it one step closer to becoming law. And, of course, all of the other bills we’ve discussed over the past 9 months are still kicking too. The good news is that none of these has become law, yet. Help us make sure they never do by taking action today.Let your elected representatives know that these bills are bad news.

At the end of this month we’re heading to D.C. with our Outdoor Alliance colleagues to meet with agency leaders and elected officials. We’ll be advocating for public lands, the public process, and better and more sustainable funding for land management agencies so that they have the resources they need to steward the places we love.

Protecting public lands is multifaceted and complex. In addition to ensuring that these lands continue to be owned and managed by the public, and that we continue to have regulations in place to protect the environment and balance multiple uses, we also have to make sure the land management agencies are following these regulations. To that end, last week, Winter Wildlands Alliance made the difficult decision to file a lawsuit against the Payette, Boise, and Bridger-Teton National Forests. We’re suing over a somewhat wonky issue, but it’s really important for winter travel planning and for the balanced zoning of winter recreation as population and use pressure continue to increase.

Basically, these 3 forests published over-snow vehicle use maps (OSVUMs) based on outdated decisions that don’t comply with the OSV Rule (the winter travel planning regulations we fought hard for). If these maps go unchallenged, they set a dangerous precedent for winter travel planning – allowing forests to essentially cement the status quo and complete the final step in winter travel planning (publishing an OSVUM) without actually doing anything. This is a tempting option for resource-strapped forests but makes all of our past effort to establish a protocol, process and requirements for winter travel planning moot. Winter travel planning is a major campaign for WWA, and central to this campaign is the proper implementation of the OSV Rule. For better or worse, a legal challenge is necessary at this point to keep OSV Rule implementation on track.

By the way, Our upcoming Grassroots Advocacy Conference is an excellent opportunity to catch up on issues important to winter recreation and public lands. From the latest in policy and planning issues to learning new advocacy tools and spending quality lodge time with likeminded folk, it’s going to be a good time. Don’t miss it! Register by September 22 for Early Bird pricing!