Re: Sierra Nevada Framework Review Team Draft Focus Area
Summaries
Dear Mr. Ash:
I appreciated Mr. Blackwell's letter of April 4, 2002 and the
Sierra Nevada Framework Review Team Draft Focus Area Summaries. The
team should be commended for their work on this project. Per your
request, I have reviewed the draft and am submitting my comments
which are limited basically to Focus Area V: Impacts on Recreation.
FOCUS AREA V:IMPACTS ON RECREATION BACKGROUND -- The team correctly
identifies the fact that many recreational uses (e.g. trails,
roads, campgrounds, ski areas, etc.) could be impacted within both
mapped and unmapped land allocations. CATEGORY V-A: GENERAL
CONCERNS Issue V-A-1 -- The team correctly identifies the fact that
the (Record of Decision) ROD did not disclose the impact to current
and future recreation activities ... that will occur due to the
restrictions, limitations and closures imminent under the selected
alternative. And, that the recreation community had a concern about
the validity and reliability of data on recreational use in the
Sierra Nevada. Recent revelations about flawed Forest Service
recreation use data prove we have a valid concern. CATEGORY V-B:
FOREST-WIDE STANDARDS AND GUIDELINES Issue V-B-1 -- The team
correctly identifies the fact that a literal interpretation of the
selected alternative could prevent maintenance and management of
developed recreation sites, trails, campgrounds, etc. Issue V-B-2
-- The team correctly identifies the fact that the extremely
limited scope of "incidental removal of vegetation and down woody
material" could affect a number of "non-qualifying" activities.
Issue V-B-3 -- The team correctly identifies the fact that surveys
for owl or goshawk habitat are expensive and could take up to 2
years (I believe that getting a study done in 2 years is rather
optimistic). The team should review if current studies are being
completed in "2 years" or if they take longer. I believe that the
team would find that in some cases a study may take up to 3-5 years
-- hence delaying even simple recreation development projects for
an unreasonable time period. Issue V-B-4 -- The team correctly
notes "the presence of wolverine or red fox can trigger a six-month
limiting operating period (LOP) for activities within 5 miles of
the detection." This vague standard could, in fact, shut down many
motorized and non-motorized activities in the Sierra. CATEGORY V-C:
FUEL TREATMENTS STANDARDS IN RELATION TO RECREATION RELATED
PROJECTS Issue V-C-1 -- The team correctly identifies the fact that
"broadly interpreted" the standards and guidelines could prevent
maintenance and development of trails, campgrounds, and other
facilities. CATEGORY V-D: MANAGEMENT DIRECTION FOR PACS AND DEN
SITE BUFFERS Issue V-D-1 -- The team correctly identifies that the
LOPs associated with nest and den sites could result in the shut
down of various recreational activities including maintenance and
construction for trails, roads, and ski areas. As state before, I
believe the team should reevaluate the time it takes the agency to
complete a "study." Depending on agency funding and priorities, the
needed study to reopen said activities impacted by LOP restrictions
could range from 3-5 years or longer instead of the rather
optimistic "2 year" time period. Issue V-D-2 -- The team correctly
notes, "there is no clear basis for a blanket prohibition on
recreation activity in PACs and den buffer sites." No closure
should be enacted until viable research is completed. Issue V-D- 3
-- The team correctly identifies that fact that PAC and den site
buffers -- and the associated restrictions on recreational
activities -- are to remain regardless of occupancy status and that
new PACs will be established after successful surveys. Over time,
this could result in the unnecessary restriction of motorized and
non-motorized recreational activities on vast sections of the
forest -- a sort of de facto "creeping closure" prescription.
CATEGORY V-E CRITICAL AQUATIC REFUGES (CAR) AND RIPARIAN
CONSERVATION AREAS (RCA) Issue V-E-1 -- The team correctly
identifies the fact that many existing or approved recreation
facilities already exceed the maximum disturbance limits regarding
soil compaction on more than 10 percent of the area of a CAR or 5
percent of an RCA. The ROD does not state how this will be handled.
Issue V-E-2 -- The team correctly notes that there could be
problems or impacts as existing and proposed uses and activities in
CARs and RCAs are evaluated for their "consistency" with Riparian
Conservation Objectives (RCO). Many trail users including
motorized, mechanized, and equestrians may find that their activity
is "inconsistent" with RCOs. MISSING ISSUE: DESIGNATING "OPEN"
FORESTS TO "RESTRICTED” FORESTS One of the major actions
outlined in the ROD was changing the last remaining "open" Forests
to "restricted" for motorized recreation. Examples of such Forests
were the Tahoe, Plumas, and Lassen. The ROD did not assess any of
the effects for this change. In addition, the ROD did not provide
any rationale (need or a problem statement) for changing from open
to restricted. The BRC believes that the agency should make such
decisions at the Forest level based on increased or changing user
needs or substantiated resource concerns. SUMMARY I want to thank
the agency and team for analyzing the ROD and noting its potential
negative impacts to motorized and non-motorized use, cabin access,
and other developed recreational opportunities. Sincerely,
/s/ DON AMADOR
Don Amador
Western Representative
BlueRibbon Coalition, Inc.
cc: BRC
REN
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