vb
August 31st, 2004, 09:25 PM
~~~~~~~~~~~~~~~~~~~~
THE UGLY
The anti-access crowd is pushing hard to morph this rule into a
top-down, impossible-to-implement, one-size-fits-all management
nightmare. They do not seem sincere in their statements about wanting
only to limit OHV's to properly designated roads and trails.
The upshot of their proposal is to close all OHV routes immediately.
They demand every "olo-gist" in the world sign off on every liner
millimeter before allowing any vehicle use. They are pushing hard for
the impossible to achieve "no impairment" standard for OHV trails.
Naturally, they'll demand the Forest Service complete all of that
within a two year timeframe. Miss it by one minute, and you can bet
the farm those foundation funded lawyers will be in the federal
courts petitioning for immediate and final elimination of OHV use.
Let's disappoint them, shall we?
~~~~~~~~~~~~~~~~~~~~
COMMENT SUGGESTIONS
* I strongly support the Proposed Rule?s recognition of
vehicle-oriented recreation as a legitimate use of our National
Forests.
* I also strongly support the Proposed Rule's approach of providing
broad national policy guidance while leaving the details of any
decision making process to the discretion of local land managers.
* The agency must reject pressure from anti-access forces to create a
deadline for the designation process or to create specific "one size
fits all" management prescriptions through this rulemaking. It is
inappropriate and unworkable to dictate on-the-ground management
changes through a nationwide OHV rule.
* I appreciate the need for flexibility in the inventory and planning
process. The rule should be modified, however, to require the agency
to acknowledge and fully act upon its responsibility to complete an
inventory of all existing roads and trails. I agree that the public
should be allowed to provide early input into this process,
specifically including identification of legitimate but uninventoried
routes.
* I strongly oppose any national or local deadline or timetable for
inventories. The final rule should continue to acknowledge and
further clarify the importance of user contributions to a flexible
and broad-ranging inventory and scoping process before any formal
route designation.
* The agency's "emergency" closure authority must be better defined
and limited. Some land managers improperly avoid the public travel
planning process by instituting a patchwork of "temporary, emergency"
closures that continue indefinitely. The final rule should clarify
that closures without public notice and input under 36 C.F.R. section
212.52(b) must be documented
by publicly-available monitoring and analysis that identifies the
specific impact(s) and vehicles or uses causing those impact(s) to be
addressed by the closure and cannot remain in effect for more than
one year without formal analysis.
* Please make sure the final rule clarifies that segments of any road
may be designated for use by non-street legal vehicles where
appropriate to avoid blanket prohibitions of non-street legal OHV use
on roads such as Level 3 roads.
* Please make sure the final rule clarifies that any trail may be
designated for use by street legal vehicles where appropriate to
avoid blanket prohibitions of street legal OHVs, particularly 4x4s
and SUVs, on all trails.
* I am concerned about the agency's commitment to effective
implementation of any OHV rule. The rule is supposedly motivated by
a need to address "unmanaged recreation" but good management will not
flow from a whisk of a pen in Washington, D.C. Any final OHV rule
must be accompanied by adequate budget, staffing, and priority to
achieve critical on-the-ground goals.
***** END ALERT ***** END ALERT ***** END ALERT ***** END ALERT *****
THE UGLY
The anti-access crowd is pushing hard to morph this rule into a
top-down, impossible-to-implement, one-size-fits-all management
nightmare. They do not seem sincere in their statements about wanting
only to limit OHV's to properly designated roads and trails.
The upshot of their proposal is to close all OHV routes immediately.
They demand every "olo-gist" in the world sign off on every liner
millimeter before allowing any vehicle use. They are pushing hard for
the impossible to achieve "no impairment" standard for OHV trails.
Naturally, they'll demand the Forest Service complete all of that
within a two year timeframe. Miss it by one minute, and you can bet
the farm those foundation funded lawyers will be in the federal
courts petitioning for immediate and final elimination of OHV use.
Let's disappoint them, shall we?
~~~~~~~~~~~~~~~~~~~~
COMMENT SUGGESTIONS
* I strongly support the Proposed Rule?s recognition of
vehicle-oriented recreation as a legitimate use of our National
Forests.
* I also strongly support the Proposed Rule's approach of providing
broad national policy guidance while leaving the details of any
decision making process to the discretion of local land managers.
* The agency must reject pressure from anti-access forces to create a
deadline for the designation process or to create specific "one size
fits all" management prescriptions through this rulemaking. It is
inappropriate and unworkable to dictate on-the-ground management
changes through a nationwide OHV rule.
* I appreciate the need for flexibility in the inventory and planning
process. The rule should be modified, however, to require the agency
to acknowledge and fully act upon its responsibility to complete an
inventory of all existing roads and trails. I agree that the public
should be allowed to provide early input into this process,
specifically including identification of legitimate but uninventoried
routes.
* I strongly oppose any national or local deadline or timetable for
inventories. The final rule should continue to acknowledge and
further clarify the importance of user contributions to a flexible
and broad-ranging inventory and scoping process before any formal
route designation.
* The agency's "emergency" closure authority must be better defined
and limited. Some land managers improperly avoid the public travel
planning process by instituting a patchwork of "temporary, emergency"
closures that continue indefinitely. The final rule should clarify
that closures without public notice and input under 36 C.F.R. section
212.52(b) must be documented
by publicly-available monitoring and analysis that identifies the
specific impact(s) and vehicles or uses causing those impact(s) to be
addressed by the closure and cannot remain in effect for more than
one year without formal analysis.
* Please make sure the final rule clarifies that segments of any road
may be designated for use by non-street legal vehicles where
appropriate to avoid blanket prohibitions of non-street legal OHV use
on roads such as Level 3 roads.
* Please make sure the final rule clarifies that any trail may be
designated for use by street legal vehicles where appropriate to
avoid blanket prohibitions of street legal OHVs, particularly 4x4s
and SUVs, on all trails.
* I am concerned about the agency's commitment to effective
implementation of any OHV rule. The rule is supposedly motivated by
a need to address "unmanaged recreation" but good management will not
flow from a whisk of a pen in Washington, D.C. Any final OHV rule
must be accompanied by adequate budget, staffing, and priority to
achieve critical on-the-ground goals.
***** END ALERT ***** END ALERT ***** END ALERT ***** END ALERT *****