The Record of Decision (ROD) and Final Environmental Impact Statement (FEIS) for the Stanislaus National Forest OSV Use Designation Project were published on March 22, 2019. Although we support elements of the draft plan – establishing a minimum snow depth restriction of 12″ for cross-country OSV travel, setting a season of use at Sonora Pass consistent with the Bridgeport Winter Recreation Area, and not designating some popular quiet recreation areas for OSV use – there are many aspects of the draft plan that fail to minimize conflict between OSV use and other uses, and to protect sensitive wildlife species.
OBJECT NOW: Anyone who submitted timely formal public comments on the DEIS may retain standing to participate in future objection resolution meetings by submitting an objection using the form and template below by May 13, 2019.
Airola Peak, Carson Iceberg Wilderness, Stanislaus National Forest. Photo by Alex Dodov.
Cross-country skiing on the Stanislaus in 1934
SCOPING: Based on a public scoping process that ended in August 2015, the Stanislaus National Forest has been working on developing and analyzing winter travel management alternatives. During the scoping period Winter Wildlands Alliance and Snowlands Network submitted a “Skiers Alternative” that would enforce existing protections of wild lands and unique natural features, set aside accessible areas for non-motorized winter recreation, and allow snowmobiling across a large network of trails and play areas. You can view a map of our scoping proposal HERE.
DEIS: The Draft Environmental Impact Statement (DEIS) for the Stanislaus National Forest‘s new winter travel plan was published on August 24, 2018. Alternative 5 was the forest’s “preferred alternative” — click here for a link to the high-res map (pdf) — and with some key exceptions (see below) we felt that it did a decent job of establishing a balanced baseline for winter management that accommodates appropriate existing snowmobile routes and play areas along Highways 4 and 108, and also provides some limited protections for important non-motorized recreation zones, wildlife, and natural resources.
HOWEVER: Several important nonmotorized areas were not protected in Alternative 5:
Pacific Valley and Eagle/Night Near Natural Areas
The Herring Creek area immediately adjacent to the Leland Snowplay Area on Highway 108
Osborne Hill and other Nordic touring terrain to the immediate east and west of Lake Alpine
Areas between Cabbage Patch and Black Springs and Mattley Ridge off Highway 4
Route 7N02 in the Big Meadow Area for non-motorized touring to the Stanislaus Canyon overlook
Full DEIS documents and map links below. Or visit the Forest Service project page HERE (click “Analysis” tab for DEIS and alternative maps).
Check out this beautiful film by one of our grassroots groups, Friends of Plumas Wilderness. "Visions of the Lost Sierra" is about the Wild & Scenic Middle Fork Feather River. The Middle Fork was one of the first eight rivers in the country protected by Congress through the National Wild & Scenic Rivers Act in 1968.
In late September, the Forest Service published a Proposed Action for Over-Snow Vehicle Planning that outlines a preliminary vision for all types of winter recreation in the Lake Tahoe Basin. This document represents one step in a much larger process, and the public can comment until November 19.
Public comments closed August 6 on the Eldorado National Forest’s Draft Environmental Impact Statement (DEIS) for Over-Snow Vehicle (OSV) management on June 22, 2018. Especially compared with what we saw in the Tahoe Draft OSV Plan, we were disappointed with the level of analysis performed by the forest and with the limited range of alternatives being considered. The forest failed to seriously consider and analyze any significant further restrictions on OSV use and is actually proposing to open many popular and historic cross-country and backcountry ski zones to motorized use.
NEPA Failure: We believe the Eldorado’s Draft Environmental Impact Statement (DEIS) for over-snow vehicle (OSV) designation fails in a number of ways to comply with NEPA and the 2015 OSV Rule. It does not consider a full range of alternatives (Alts 1, 2 and 4 are essentially the same); it fails to fully address the minimization criteria; it fails to treat the forest as closed to over-snow vehicles unless designated open (as required by law); and it designates open to OSVs areas that are larger than a ranger district. We hope that the Eldorado will go back to the drawing board, as the Lassen did, and significantly revise this draft before moving on.
Important ski and snowshoe zones opened to snowmobiles: Meanwhile, the Eldorado’s Proposed Action (Alternative 2) actually reverses historic protections and opens many important and longstanding non-motorized areas to snowmobiles, including Anderson Ridge, numerous traditionally non-motorized areas accessed from the Carson Pass corridor and the historic Van Vleck closure. It also designates open to OSV use the important non-motorized area around the Ludlow Hut. Alternative 4 is even worse, proposing to allow OSVs in the Loon Lake winter recreation area along with all of the areas listed above. Alternative 4 also proposes to change the Forest Plan to allow OSVs in the Caples Creek recommended wilderness area, semi-primitive non-motorized high country areas, and in the Round Top Biological/Geological Special Interest Area! Click here to use our mapping tool to see how this plan might impact your favorite zones on the Eldorado NF.
Only Alternative 3 presents a clear-eyed vision for winter travel management that recognizes historically non-motorized areas, focuses OSV designations in areas where OSV use actually occurs, and acknowledges that not all parts of the forest receive sufficient snow for OSV recreation. SEE BELOW FOR WINTER WILDLANDS ALLIANCE COMMENT LETTER.
Alternative 1 (current management): The current management designates 75% of the forest open to snowmobiles and OSV travel. Of the remainder, 17% is designated wilderness. The rest of the winter non-motorized areas on the forest consist of recommended wilderness, primitive or semi-primitive areas, downhill and Nordic resorts, and various special non-motorized areas. This Alternative does not include many historically non-motorized areas because the closure orders protecting them have lapsed. There are 58 miles of groomed snowmobile trail forming the Silver Bear Trail System near Highway 88 west of Silver Lake.
Alternative 2 (proposed action): The forest’s proposed action is barely distinguishable from current management. This alternative closes an additional 23,000 acres (4%) to OSV use, but the area closed is generally below 4,500 ft in the western portion of the forest and wouldn’t provide any further non-motorized opportunity for skiers. Thus, the Proposed Action does nothing to minimize conflict between motorized and non-motorized winter recreation in the important areas near Carson Pass, Echo Summit, Anderson Ridge, Van Vleck Bunkhouse, and the Ludlow Hut, in violation of the 2015 Travel Rule.
Alternative 3 (“non-motorized” alternative): The alternative submitted by Snowlands and Winter Wildlands Alliance identified 21,500 acres (3.5% of the total forest area) of important non-motorized areas (those mentioned above) and specified that these areas not be designated open for OSV use. We also identified 123,000 acres (20% of the forest) where we knew that snowmobile use currently occurs and suggested these areas be designated open in our alternative. This comes to about 20% of the forest, which is supported by the Forest Service’s over-snow vehicle use analysis models, which show that most of the snowmobile use on ENF occurs on only 10% of the forest. The vast majority of snowmobile use on the ENF occurs on the Silver Bear Trail System located on Highway 88 near the Iron Mountain Sno-Park and Bear River Reservoir. Alternative 3 designates all 58 miles of groomed snowmobile trail for snowmobile use. Most of the land closed to snowmobiles in Alternative 3 is low elevation and gets very little use by either snowmobiles or skiers because it doesn’t get snow.
Alternative 4: Submitted by snowmobile groups, Alternative 4 designates more land (another 5,200 acres or another 1% of the forest above existing conditions) open to OSV use than current management. This alternative would designate open areas that are currently closed to snowmobiles, including the Loon Lake Winter Recreation Area, Caples Creek recommended wilderness area, semi-primitive non-motorized high country areas, and the Round Top Biological/Geological Special Interest Areas. Designating these areas open to motorized use would require an amendment to the Forest Plan.
There are significant problems with the Eldorado’s Draft Plan that violate both the National Environmental Policy Act (NEPA) and the 2015 Travel Rule:
1) The majority of Alternatives, including the Proposed Action, make no attempt to minimize conflict with other uses or protect backcountry skiing opportunities
NEPA regulations require that the Forest Service, in designating areas and routes open to OSV use must “minimize conflicts among the various uses of National Forest System lands.” The Proposed Action designates as open to OSV use areas that are important to non-motorized users such as Van Vleck Meadow, terrain south of Highway 50 at Echo Summit, areas north and south of Highway 88 at Carson Pass, Martin Meadow at Carson Spur, and Anderson Ridge just north of Highway 88. These are all popular and longstanding locations for cross-country skiers and snowshoers. Alternative 4 is even worse – it would allow OSV use in the Loon Lake winter recreation area as well as all of the areas listed above, and many existing non-motorized areas on the forest. By designating these areas for OSV use, Eldorado has completely ignored their responsibility to minimize conflicts between snowmobilers and non-motorized users. Alternative 3 is the onlyAlternative that protects backcountry skiing opportunities on the Eldorado National Forest.
2) The DEIS does not consider a full range of alternatives
The four alternatives described in the DEIS designate 75%, 71%, 20%, and 76% of the forest open to snowmobiles. NEPA requires that the Forest Service “consider all reasonable alternatives.” There are obviously reasonable alternatives for designating areas and routes open for OSV use that would fall into a range between 20% and 76%. The fact that the forest has not analyzed any such alternative is a serious violation of the NEPA requirement.
3) The Proposed Action designates open areas that are larger than a ranger district
The DEIS divides the forest into four partitions using ranger district boundaries and designates a single OSV area within each partition that is “smaller than a ranger district.” However, since the “open areas” are adjacent to each other and snowmobiles can freely travel across these arbitray boundary lines without even knowing they are doing so, in reality there is a single, large open area that constitutes 75% of the forest. This is violation of the Travel Rule, which states that open areas must be “discrete, specifically delineated spaces that are smaller … than a ranger district.”
4) Three of four alternatives propose to manage the forest as open to OSV use except for a few designated closed areas
These proposed alternatives do not meet the basic legal requirement established by the 2015 OSV Rule to manage the forest as “closed [to over-snow vehicles] unless designated open.” This same flawed approach by the Lassen National Forest in 2016 led to multiple official objections which forced the Lassen to go back to the drawing board to develop a new Alternative and re-work its Environmental Impact Statement. We are disappointed to see the Eldorado repeating the Lassen’s early mistake.
Winter Wildlands Alliance Comment Letter to the Eldorado NF
Based on a public scoping process that ended in April 2015, the Eldorado National Forest has been working on developing and analyzing a series of draft winter travel management alternatives. During the scoping period, Winter Wildlands Alliance and Snowlands Network submitted a “Skiers Alternative” for the Eldorado National Forest. You can view a map of our proposal here.
From the DEIS: “The Forest Service received and considered responses from 103 interested groups, individuals, and agencies in the form of letters, emails, and website submissions. Comments received expressed support, opposition, or concerns with the proposed action, or requests for revision and new alternatives. Letters dated April 20, 2015 , were received from the Plaintiffs describing their preferred alternatives. The Intervenors sent a letter describing their alternative on April 16, 2015. Follow – up letters were sent to both the Plaintiff and Intervenor groups on October 22, 2015 , requesting clarification of the alternative components that had been submitted and informing them of the components of their requests that were believed to be outside of the scope of this project. The Forest Service received clarifying letters of response from the Plaintiffs and Intervenors dated November 5 and 16, 2015, respectively.”
For more on the Eldorado’s scoping, proposed action and analysis, visit the Forest Service Project Page (click on “Analysis” tab).
Backcountry Skiing on the Eldorado National forest
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.
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.
Winter Wildlands Alliance
https://winterwildlands.org/wwa/wp-content/uploads/2017/10/IMG_1260-1.jpg4781500Mark Menlovehttps://winterwildlands.org/wwa/wp-content/uploads/2017/08/Winter_Wildlands_Alliance_Logo.pngMark Menlove2017-10-10 17:41:212018-07-12 15:08:07An Open Letter to the Snowmobile Community