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It’s been a busy month at Winter Wildlands Alliance. David Page, our advocacy director, has been road-tripping across California, going from Stanislaus travel planning meetings to Sierra-Sequoia forest planning meetings to California outdoor recreation lobbying days in Sacramento and then more travel planning meetings. Meanwhile, I jetted across the country to Washington D.C. to tout our vision for the Custer Gallatin forest plan and talk policy with the Forest Service Washington Office. Actually, I climbed a number of hills this month: after Capitol Hill, I went to the Wind River Range for some backcountry climbing. And throughout it all, we have been planning the 8th Biennial Grassroots Advocacy Conference.

Grassroots Advocacy Conference
October 24-27
Join policy makers, athletes, grassroots activists, scientists, educators, and other recreation and conservation stakeholders and activists from across the country for two full days of engaging workshops and discussions on issues important to public lands, winter and sustainable recreation. Get the latest developments in policy and planning issues, share grassroots successes and strategies, meet with public land managers, gain new advocacy tools and spend quality time with colleagues, partners, new friends and allies. Visit the conference website find out more and to register!

NEPA
This is where you and the rest of our members and community have been instrumental. Together, we rallied 600 letters to send to the U.S. Forest Service about their proposed revisions to their NEPA regulations. The agency received more than 42,000 letters total. Forest Service officials have assured us the proposed revisions are a starting place and they will be taking public comments seriously as they develop the final rule. If you’d like to read the letter we sent the U.S. Forest Service, you can read it here. They have certainly heard an earful about the importance of scoping and concern about many of the proposed new Categorical Exclusions, so hopefully they make some serious changes!

Travel Planning
Earlier this month, the Stanislaus National Forest hosted an objection resolution meeting concerning their winter travel plan. This was the last public step in the winter travel planning process and a chance for anybody who filed an objection to the draft plan to discuss their objections and proposed resolutions. We objected to the Stanislaus amending its forest plan to permit motorized use in highly sensitive Near Natural Areas (critical habitat for the endangered Sierra Nevada Red Fox). We also objected to the Stanislaus designating a few important backcountry ski zones for snowmobile use and not properly managing motorized use adjacent to the Pacific Crest Trail. The objection meeting had many participants with different opinions, and now it’s up to the Forest Service to take everything they heard and decide what, if any, changes they’ll make before finalizing the winter travel plan.

The Plumas National Forest published a draft winter travel plan and final EIS last week. We’re still reviewing it, but our partners at Friends of Plumas Wilderness are tentatively optimistic about the plan. Objections to the Plumas draft plan are due in early October.

Forest Planning
I went to Washington DC earlier this month with two colleagues from our Outdoor Alliance Montana coalition (representing Southwest Montana Mountain Bike Association and the paddling community). We met with the USDA Undersecretary for Natural Resources and Environment and the Forest Service staff who oversee forest planning and the dispersed recreation, Wilderness, and travel management programs. We discussed the vital importance of forest planning, specific issues facing the Custer Gallatin, and the Outdoor Alliance Montana vision for the revised forest plan.

Meanwhile, David has been working with Outdoor Alliance California to review and comment on the Sierra and Sequoia forest plans. The draft plans were published in June and the comment period wraps up on September 26. The Sierra and Sequoia face the challenge of integrating and managing for outdoor recreation, traditional timber interests, and wildland conservation. We’re working with recreation and conservation partners to create and advocate for vision for the Sierra and Sequoia that meets these challenges.

Public Comment Deadline is March 1, 2019: Comment Now!

With our local partners at Friends of Plumas Wilderness, we support the forest’s preferred Alternative 2 with specific modifications from Alternative 5.

OUR TAKE: We like that Alternative 2 protects terrain east of Bucks Lake Wilderness, the Bucks Creek Loop Trail, the Historic Lost Sierra Ski Traverse Route, and the backcountry ski zone on Thompson Peak by Susanville. We urge that the Forest Service also include specific amendments from Alternative 5 to protect proposed Middle Feather, Bucks Creek, Chips, Grizzly, & Adams Peak Wilderness Areas, Lakes Basin Snowshoe and Ski Trails, Little Jamison Basin and to stop grooming on 24N33 to help prevent OSV trespass into the Bucks Lake Wilderness.

Last year, after exhausting all other avenues, we filed a lawsuit challenging over-snow vehicle use maps on 3 National Forests – the Boise, Payette, and Bridger-Teton. Today, we’re pleased to report that we’ve dismissed the challenge because the Forest Service recognized that these maps don’t comply with the OSV Rule and withdrew them.

Winter travel planning is a big deal for Winter Wildlands Alliance. The Over-Snow Vehicle Rule is a hard-won regulation that came about after a decade of advocacy work and we’re committed to seeing it properly implemented. This means that the majority of National Forests that get snow will need to go through winter travel planning. Any forest that wants to roll existing designations into an official winter travel plan — through a so-called “grandfathering provision” — can only do so if they can show that those designations comply with the OSV Rule.

The grandfathering of existing designations is a bit tricky, and could possibly be interpreted as a loophole big enough to drive a snowcat through. The provision isn’t meant to allow forests to codify the status quo and call it good. It’s intended to help make winter travel planning efficient by allowing decisions that already comply with the OSV Rule to be rolled into new plans.

However, faced with a shortage of resources and a desire not to stir up conflict, some forests have been tempted to circumvent winter travel planning by publishing over-snow vehicle use maps (OSVUMs) based on current management, regardless of whether or not that management complies with the OSV Rule. Publishing an OSVUM is the final step in winter travel planning, so once a forest publishes one of these maps they’re essentially closing the door on the opportunity to revisit OSV use designations or do any further planning.

Codifying the status quo without actually doing anything makes all of our past efforts to establish a protocol, process and requirements for winter travel planning moot. Which is why, when the Payette, Boise, and Bridger-Teton published OSVUMs based on outdated decisions that don’t comply with the OSV Rule, we realized we’d have to sue if we wanted to keep OSV Rule implementation on track. We don’t take litigation lightly, and prior to filing a lawsuit we approached each forest and made a case for why they should withdraw their maps and commit to doing winter travel planning instead. But they weren’t having it. So, in September 2017, we sued.

A few months ago we received notice from each forest that they’ve withdrawn their OSVUMs and will conduct winter travel planning when resources allow. Because the case is now moot, we’ve withdrawn the lawsuit. Onward and upward.

Now it’s time to talk about what comes next. The Bridger-Teton is about to embark on a forest plan revision, which is a perfect opportunity to set the stage for winter travel planning. Once the forest plan revision is completed (a process that usually takes around 5 years), we’d like to see the Bridger-Teton roll right into winter travel planning. From forest planning through travel planning, we’ll be advocating for backcountry skiers and wildland and wildlife conservation and we’re excited to help the Bridger-Teton revamp it’s management to reflect current conditions, opportunities, and challenges on the forest.

Meanwhile, over in Idaho, the time is ripe right now for the Boise and Payette to start working on winter travel plans. We understand that winter travel planning isn’t easy, but there are ways to ease the process. Right now would be a great time for these forests to convene collaboratives, or work with existing ones, to start thinking about winter travel planning and coming up with ideas and agreements that could inform the planning process and make it less resource-intensive.

Winter travel planning doesn’t have to start with the NEPA process, and now that we’re all in agreement that these forests need to do winter travel planning, we should be able to move forward with figuring out winter travel management plans that balance motorized and non-motorized snowsports and protect wildlife habitat and winter wildlands.

Related Media:

2018 07 12 Legal Challenge Holds the Line on Winter Motorized Travel

The Shoshone National Forest has published a revised Proposed Action outlining its vision for winter travel management on the forest. When finalized, this plan will have major repercussions for skiing and snowboarding on the Shoshone, especially on Togwotee Pass and Beartooth Pass.

We now have until December 10, 2017, to provide comments to influence the plan as it takes shape. Your comments matter (even if you commented last year, it’s important to weigh in again).

— CLICK HERE TO USE OUR HANDY LETTER TEMPLATE TO SUBMIT A COMMENT —

Context

The Shoshone National Forest bills itself as a wild backcountry forest, and indeed there are some amazing adventures to be had deep in the Wind River, Absaroka, and Beartooth mountains. What’s at stake in this travel plan, however, and where most skiers go, is the Shoshone’s relatively accessible world-class front-country terrain. Specifically Togwotee Pass and the Beartooth Pass.

The current Proposed Action —revised from the Proposed Action of May 2016—was developed based on suggestions the Forest Service received from the public as well as from groups like Winter Wildlands Alliance, Togwotee Backcountry Alliance, and the Wyoming Wilderness Association. This revised Proposed Action doesn’t change much from how snowmobiles and other over-snow vehicles (OSVs) are currently managed on the forest, and for the most part we’re pretty supportive of what the Forest Service is proposing. You can review the latest plan, and look at maps of what the Forest Service is proposing here.

Discrete Motorized Season

For the first time ever, the Shoshone is considering a set season for winter motorized use. We like that they’re proposing specific dates before and after which snowmobile use would not be allowed, but the current proposal is confusing — there are different season dates for each ranger district and even different dates within ranger districts. We suggest they simplify things with a single season: December 1 through April 30, with a slight extension to allow snowmobile use on the Beartooth Pass until May 15.

Implementing these season dates would reduce conflicts between over-snow vehicles and wildlife and is a balanced way for skiers and snowmobilers to share the Beartooth Pass while recognizing that the two user groups have traditionally used this area during different and distinct seasons. These season dates also bring the Shoshone in line with how it’s neighbor, the Bridger-Teton, manages winter use on Togwotee Pass.

Protection for Cross-Country Skiing on Togwotee Pass

We are pleased to see that the Shoshone is proposing to formally close the cross-country ski trails on Togwotee Pass to motorized use (excepting for grooming purposes). The local trails group in Dubois — DART — spends a lot of resources grooming these trails for skiing and their efforts can be completely undermined by just one or two irresponsible OSV users. By closing, and signing, these areas cross-country skiers on Togwotee Pass will finally have non-motorized trails to enjoy.

Compliance With OSV Rule and Wilderness Act

In general, we think the Shoshone needs to do more to comply with the OSV Rule. The OSV Rule requires that the Forest Service designate discrete areas for OSV use, located to minimize impacts on wildlife and the environment and in areas that won’t cause conflict with other uses. Right now we’re not so sure the areas they’re proposing to designate really will minimize impacts and we expect them to explain how they’ve complied with this requirement when they write an Environmental Impact Statement.

We are especially concerned that the Shoshone has proposed to designate the entire High Lakes Wilderness Study Area (WSA) open for OSV use. This violates the Wyoming Wilderness Act, which states that snowmobile use in the WSA is only permissible if it’s at the same “manner and extent” as occurred in 1984. Unfortunately nobody thought to collect any baseline data showing how many people were snowmobiling in the WSA in the early ’80’s or where they were going, so we have to give it our best guess. While it’s pretty hard to guess how many snowmobiles were up there in the 80’s, we are confident that the machines people were riding then weren’t as powerful as what they’re riding today and therefore people weren’t traveling very far into the WSA. Therefore, we think the Forest Service should limit where snowmobiles can go within the WSA, restricting them to areas near the designated trail network (where it seems most likely people were riding in the past). After all, until Congress changes the status of the WSA the Forest Service is legally bound to comply with the existing law.

Press

Wyofile.org. 12/8/2017: Skis and Snowmobiles: National forest examines winter travel. 

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.