Comment on snowmobile, snowbike use.

The Forest Service is taking comments on the proposal to manage over snow vehicles - read snowmobiles and snowbikes - as a result of the 2013 court decision that's been discussed here.

It's important that as many people as possible comment. Let em know what you think.




Release No. 0123.14

Contact:

Forest Service Press Office (202) 205-1134



U.S. Forest Service Seeks Comments on Over-Snow Vehicle Proposal



WASHINGTON, June 13, 2014 – The U.S. Forest Service next week will publish a Federal Register Notice seeking public comment on a proposal that would help standardize where and when over-snow vehicles, such as snowmobiles, are used on national forests and grasslands.

"Over-the-snow access and recreation is an appropriate use of public lands, and we strive to offer a variety of opportunities for that," said U.S. Forest Service Chief Tom Tidwell. "We believe it is essential that the public be engaged in decisions regarding travel management on the forests and grasslands, and we encourage the public to review the proposal and provide comments to help improve the final rule."

Motor vehicle use on national forests and grasslands is governed by the Travel Management Rule which provides for a system of roads, trails and areas that are designated for motor vehicles. Over-snow vehicles—vehicles designed for use over snow and that run on a track and/or a ski or skis—are currently treated differently from other motor vehicles by giving forest and grassland supervisors the discretion to develop a similar system for over-snow vehicles. In 2013, a federal court ruled that this violates Executive Order 11644, "Use of off-road vehicles on public lands." The court ordered that the Forest Service must regulate over-snow use, but does have the discretion to determine where and when over-snow vehicle use can occur on agency lands.

In accordance with the court's ruling, the Federal Register notice proposes amending the existing Travel Management Rule to establish consistent guidance for how forests and grasslands decide the appropriate use for over-snow vehicles. Over-snow vehicles are used for recreational purposes as well as work tasks that include gathering firewood or subsistence hunting.

The Federal Register Notice for the proposal is scheduled to be published Wednesday, June 18, 2014. The public will have 45 days from the date of publication in the Federal Register to comment on the proposed revisions. The Forest Service intends to publish the final rule change by Sept. 9, 2014.

Nationally, the Forest Service manages over 200,000 miles of roads and 47,000 miles of trails that are open to motor vehicle use. The roads and trails vary greatly, from single-track trails used by motorcycles to roads designed for high-clearance vehicles such as logging trucks.

The mission of the U.S. Forest Service, an agency of the Department of Agriculture, is to sustain the health, diversity and productivity of the nation's forests and grasslands to meet the needs of present and future generations. The agency manages 193 million acres of public land, provides assistance to state and private landowners and maintains the largest forestry research organization in the world. Public lands the U.S. Forest Service manages contribute more than $13 billion to the economy each year through visitor spending alone. Those same lands provide 20 percent of the nation's clean water supply, a value estimated at $7.2 billion per year. The agency also has either a direct or indirect role in stewardship of about 80 percent of the 850 million forested acres within the U.S., of which 100 million acres are urban forests where most Americans live.

For more information about today's release see www.fs.fed.us/publications/over-snow-vehicle-faqs.pdf

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USDA is an equal opportunity provider and employer. To file a complaint of discrimination, write: USDA, Office of the Assistant Secretary for Civil Rights, Office of Adjudication, 1400 Independence Ave., SW, Washington, DC 20250-9410 or call (866) 632-9992 (Toll-free Customer Service), (800) 877-8339 (Local or Federal relay), (866) 377-8642 (Relay voice users).


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Thank god for Canada.

Amen brother!
At least we get our sliver of Alpine in Whatcom Co. for two more years... blogs.seattletimes.com/today/2014/06/mou...-backcountry-trails/

Amen brother!
At least we get our sliver of Alpine in Whatcom Co. for two more years... blogs.seattletimes.com/today/2014/06/mou...-backcountry-trails/

Is that what you got from reading that article? I didn't see anything in that article that was about off trail sledding in the alpine. The grants are for trial maintenance and grooming of snow mobile trails. I doubt if snowmobile trail grooming will go away with this new action on the Travel Management Plan, off trail riding might be restricted though and sooner than two years.

Is that what you got from reading that article? I didn't see anything in that article that was about off trail sledding in the alpine. The grants are for trial maintenance and grooming of snow mobile trails. I doubt if snowmobile trail grooming will go away with this new action on the Travel Management Plan, off trail riding might be restricted though and sooner than two years.

Without off-trail riding, there won't be much money for grooming. A pretty high percentage of Washington Snowmobilers are not interested in road rides. Their registrations pay for grooming and plowing.

Without responsible recreational backcountry snow machine use, any chance of catching or discouraging wilderness violators is gone, too.

I'll let others speculate on the ramifications for SAR in places that have Snowmobile based rescuers, like Mt Baker.

There are a lot of folks interested in riding the groomed trails in my experience and observation. Riders on touring sleds in the Blewett and Colockum groomed trail system out number the folks on long track mountain sleds. Before the advent of lighter weight, more powerful long track sleds snowmobilers were stuck on groomed trails or ungroomed roads and areas with shallow gradients and people still rode sleds.

Actually it would be easier for other users and LE to catch illegal use of snowmachines if they were confined to designated roads and trails because if they strayed everyone would know. Currently you can ride across Wilderness boundaries with impunity because unless you are caught inside the boundary you're fine, if restricted to designated routes and caught even near Wilderness it would be illegal.

I really don't know why SAR would be affected, snowmobiles would still be allowed for those uses just like helicopters in Wilderness areas are now.

There are a lot of folks interested in riding the groomed trails in my experience and observation. Riders on touring sleds in the Blewett and Colockum groomed trail system out number the folks on long track mountain sleds. Before the advent of lighter weight, more powerful long track sleds snowmobilers were stuck on groomed trails or ungroomed roads and areas with shallow gradients and people still rode sleds.

Actually it would be easier for other users and LE to catch illegal use of snowmachines if they were confined to designated roads and trails because if they strayed everyone would know. Currently you can ride across Wilderness boundaries with impunity because unless you are caught inside the boundary you're fine, if restricted to designated routes and caught even near Wilderness it would be illegal.

I really don't know why SAR would be affected, snowmobiles would still be allowed for those uses just like helicopters in Wilderness areas are now.

There could be lots of trail riders: I just haven't seen them. Regarding enforcement, I have never seen a LEO in the backcountry outside Mount Rainier NP. I could have ridden in the wilderness every time I rode. Only responsible riders can discourage the small minority that ride wilderness now.

I can tell you that my SAR days will be over if I am spending 50-80 days a year in Canada. Like the trail riders you mention, I cannot speak for other volunteers. Snowmobiling and Snowbiking are not cheap and I doubt that many mountain riders would get after it if there was no legal place to ride.

On a personal note, the amount of driving North and back that I will do if shut out of the National Forrest is going to really suck.

Is that what you got from reading that article? I didn't see anything in that article that was about off trail sledding in the alpine. The grants are for trial maintenance and grooming of snow mobile trails. I doubt if snowmobile trail grooming will go away with this new action on the Travel Management Plan, off trail riding might be restricted though and sooner than two years.

To quote the article "The Mount Baker area is the third-most popular recreation area of the state, with its views of the surrounding mountains and valleys, according to the state agency. It also has the longest riding season with ample snow, but funding often runs out early".

Yep. That's what I got out of it and that's where I will be riding! "The longest riding season" doesn't happen on the roads buddy. Glad I won't be seeing you there!

Good luck with your quest, if snowmobiling is going to be restricted to roads, well, the world will have to end

By the way, to all you "road riders" out there, what will happen when this happens to your roads? This picture is taken about a mile from Baker Lake Rd, Dec. 2012, when a huge volunteer effort was put forth to open access back up to Schriebers. Hundreds of fallen trees were cut, excavators donated time...
I didn't see one whiney skier dude driving a Subaru show up to help. What gives??
You then had care-free access in the Spring, and continued to post on this web site about "abhorrent machines"!!
Be careful what you ask for TAYers. That wind event wasn't "budgeted for" if you catch my drift, and none of those dudes, myself included, are going to help you get your vehicle to the TH.

I think that Pinch and others are making good points. I can understand how one might think that snowmobiles may interfere with your "wilderness experience" but the fact is that the snomo is a very large user group. The registration fees go to maintain access to areas that the "greenies" like to access i.e. Glacier Creek Rd, Schrieber Meadows, Salmon la Sac basically most areas that can deposit you into the alpine via road access. Without this user base and their funds, roads will wash out, trees will fall and come winter so will your tears.
The thing is that WE are ALL in this together. It's about the gov't limiting access, little by little. It costs the Forest Service ZERO dollars to let a road decommission itself ( Canyon Creek Rd.) With the budget cuts these days, the touring crowd is fooling themselves to think that by limiting sled access is somehow going to provide better access to skiing terrain. Without a large user base demanding access, the government will just divert those funds to dropping bombs in some other part of the world.
Besides, most of the areas that sledders ride would see very little touring traffic because they require snowmobiles to access the ~10+ miles of road to get in there.
I see a snowmobile being not too different as a car in terms of accessing wilderness areas for skiing. We drive cars on roads through mountains to get us closer to our objectives, how are snowmobiles that different? Why limit access to areas that are seldom visited by a touring folks just because you disagree with the politics. We truly are becoming a very divided country. When will we understand that it is the government that is screwing us all, not the other way around.

Safety is a concern with skiers and sledders alike. Who hasn't here hasn't had a group or another skier drop in on top of them or put themselves in harms way by poor route selection. We are talking about public access. The people need to play!!!

No I do not. Mostly, skiers and sledders play in different spots. The ability to get deep into the mountains on a sled is one of the primary reasons for this. Again, access is the issue. The more access we ALL have the less we will bump into one another.
Skiers and sledders both need to be aware of each other in the few spots they are in contact with each other. Both groups need to secure access points into the areas we already have because they certainly aren't planning on opening up more for us!

"Sustainable Roads" anybody? The FS only has a budget to maintain 25% of existing roads and is currently determining which ones to close.  Sledders are a huge asset in this area because they donate time and equipment to do repairs and maintenance for free. This could be dramatically increased if red tape were removed to streamline this process.

Good luck on snowmobile SAR.  "I don't want you to ride your sled for fun but I need you to get up in the middle of the night and come save me for free."  

Road riding is about as popular as a tayer posting up a skate ski report.  The old time sledders accessed some of the same terrain as riders do today but after the snow settled, not in the perfect ski conditions I experience today.  Yes I ride perfect pristine powder off my sled that makes heli clients envious.

The "access only" sledders are the worst hypocrites.  It takes no skill to sit down sled, park and ski.  Without a track to follow they wouldn't make it out of the parking lot.  But they are the most vocal to take away my freedom because I don't want to ride lame low hanging fruit off the road.  In my neck of the woods access only gets you nowhere close to good skiing. Washington pass is a rare exception where the road actually goes to amazing skiing and parking on the road is a viable option.  

The greatest failure of this legal push from WWA is the fight to take away from another group instead of working towards providing better opportunities for skiers. Look up north for examples.  Huts everywhere.  Illegal to maintain permanent structures in NF here. Even the fire lookouts are illegally located in wilderness and recently came under attack for removal...

Why the hardon for snow bikes? Snowmobiles and snow bikes aren't that different. Game changing? I'm not really following you.

Others see the solution as restricting machines to roads and trails so let's remind them that the snowmobile community helped evac that guided skier group after this years tragic accident in Oregon.

In reading that report, I believe the snowmobiles were unable to reach the site and the injured skiers were carried on litters to a waiting Baker Count SAR snowcat and Guard heli for evac. That doesn't diminish the snowmobile club's intention to help but it's not really accurate to say they rescued that group. If this is wrong, consider me admonished.

I keep hearing the "loud voices" of the pro moto crowd talking about how big their user group is. This was proven to be inaccurate a few years ago when the WMC was pushing for further snowmobile regulation. All statistics point to non motorized groups(snowshoeing/xc skiing/bc skiing) having much larger participation than snowmobilers.

What I see is akin to fear tactics implemented by the snomo crowd because they might lose what is basically unrestricted access to the forest outside Wilderness area. Everyone is going to lose access to the forest if snowmobiles are restricted to roads and designated routes? We'll see, I personally don't see that happening. I don't see what's wrong with over the snow travel having a regulated travel plan just like all other motorized OHVs.

The argument that it costs nothing for the FS to decommission roads is wrong, they usually hire a contractor and bring in a cat with a ripper and tear up the road and build berms to restrict access. Most of the existing forest roads are in disrepair because no one uses them and they go nowhere. The majority of the roads were constructed for logging. Most, not all, of the roads with a destination or that connect popular areas get regular maintenance. More fear tactics.

BTW, I've used sleds to access areas for skiing that would otherwise involve long, time consuming approaches. I never left the road though. That's just like using a car to drive on the Forest, riding a sled in the alpine or other off trail areas isn't the same as driving a car.

I'm not anti snowmobile, but to continue with current travel management plans that don't address over the now vehicles is wrong. If continued use of snowmobiles in certain areas is upheld I won't whine about it. I'm more interested in the FS addressing the issue just like they do with snow free OHV travel instead of ignoring the current situation. I happily share the trails near my home with trail bikes.

IMO your oil leaking, smoke belching noisemaker should never be allowed to leave the road or designated OHV/Snomo park.

Agree, which is why I advocate that people scrap the old, slow stinky stuff and get on the new, lower emission, non leaky, much more off trail capable sleds that have been brought to market in the last 10 years.

Why the hardon for snow bikes? Snowmobiles and snow bikes aren't that different. Game changing? I'm not really following you.

Probably because there is a perception (which is accurate in my experience) that snowbikes are able to access terrain in a way that isn't easily done by most people on sleds (even the new gen sleds, but the gap is narrowing a bit).

I keep hearing the "loud voices" of the pro moto crowd talking about how big their user group is. This was proven to be inaccurate a few years ago when the WMC was pushing for further snowmobile regulation. All statistics point to non motorized groups(snowshoeing/xc skiing/bc skiing) having much larger participation than snowmobilers.

I see both sides of the argument. I ski and I own a mountain sled. On the skiing end of the spectrum I see a few access points crowded with skiers and snowshoers all stacked on top of one another. This causes all sorts of issues from secret stash issues and TR bitching, to skinning up the descent route to more serious accidents involving avalanches. Yes, this is a large group but the snowmo crowd is quite large and arguably in the B/C way more than Susie snowshoer and Rando Randy who gets out on the weekends. The snowmo crowd is accessing areas that only see a handful of people outside of the user group a year. So, why is a user group that has no practical way of accessing these areas (outside of huge road slogs) so up in arms? The snowmo crowd would love to cite their "hippy agenda" to limit access to everything green. Be careful TAY, you may just get what you ask for.

The argument that it costs nothing for the FS to decommission roads is wrong, they usually hire a contractor and bring in a cat with a ripper and tear up the road and build berms to restrict access. Most of the existing forest roads are in disrepair because no one uses them and they go nowhere. The majority of the roads were constructed for logging. Most, not all, of the roads with a destination or that connect popular areas get regular maintenance. More fear tactics.

Clearly we are splitting hairs now...

BTW, I've used sleds to access areas for skiing that would otherwise involve long, time consuming approaches. I never left the road though. That's just like using a car to drive on the Forest, riding a sled in the alpine or other off trail areas isn't the same as driving a car.

Yes, its even less impact because at the end of that "road" we leave no trace of ever being there come the next snowstorm. Your right, its not the same as driving a car.

not anti snowmobile, but to continue with current travel management plans that don't address over the now vehicles is wrong. If continued use of snowmobiles in certain areas is upheld I won't whine about it. I'm more interested in the FS addressing the issue just like they do with snow free OHV travel instead of ignoring the current situation. I happily share the trails near my home with trail bikes.

Hmm...just like to argue then.

Hmm...just like to argue then.

Well, maybe. Do you think that Winter Travel Management Plans should address over the snow vehicles? I do and a Federal Court has deemed that it's something the FS should do instead of ignoring the current status quo.

I'm in the same camp as freeski pretty much. I think the user groups are incompatible for the most part and need separate areas.

I have no problem finding untracked snow wherever I choose to go, whether I go skiing, or sledding.

We have discussed some points and Aaron is right, the FS has been pressured into creating a new plan.
Where is the link to comment? Or is it the phone # at the top?
The link now seems wrong and the phone # accesses a bulk voice mail.

This should work as a link for comments:

www.regulations.gov/#!submitComment;D=FS_FRDOC_0001-1883

And here is more more info regarding Forest Service approach to this issue. Not unexpected, it appears the FS is doing their best to minimize any real change. But, I could be wrong and we'll see how it plays out. Years of lawsuits ahead?

winterwildlands.org/long-awaited-winter-rule/ 

Well, that first link doesn't quite work. If you copy and paste the whole thing into your browser it will.   

Here are a few bullet points proving yet again that requiring the Forest to manage a particular activity does not require them to manage it well. Not to be overly cynical but I think it's going to be many years, if ever, before we see any meaningful change in how the Forest Service manages motorized winter recreation.

From the Snowest site:

IMPORTANT NOTICE!
FROM COLORADO SNOWMOBILE ASSN
ACTION ALERT!!!

1. The proposed rule recognizes that off trail snowmobile riding is a valid usage of NFS lands that should be continued, and is highly valued especially in the Western United States;
2. The proposed rule continues existing management decisions regarding over the snow vehicles, which means the riding area boundaries will not change as a result of the new rule and riding opportunities you will have this year are the same areas as you had last year; and
3. The proposed rule recognizes that open riding area boundaries are significantly larger for winter travel than summer travel and open riding areas for winter .

The wood river valley, Ketchum, Id. went through this process years ago and settled on dedicated areas to separate the user groups. Other approaches didn't work so it was decided to define these areas. Our mountains are quite different and we're talking thousands of square miles of terrain. I don't get back there much anymore so can't comment as to the longer term vibe but it was essential that the conflict end. Things like that can feel lose-lose to some and I get that. Riders and sliders can co-exist if some simple common sense and courtesies are extended both ways. I felt bad about one of S.V. Trekking's yurts going up in smoke a couple years ago but blaming sledders as a whole for the act of such a small segment of that community is asinine. If you know the Sawtooth, White Cloud, Smokey area, there's a good amount of the season you don't play, at least on the fun stuff. We're more fortunate, generally speaking and a reasonable, sustainable approach be it some division of terrain may be where this is headed due to the Fed's involvement?? I'd wager that the economics of ski traffic and SnoMo's will be looked at and become a factor. So does the subie with a load of skiers on a day climb spend like folks in trucks, expensive machines, using fuel, paying licensing and sno-park permits do? I hope this isn't just played on the state revenue basis but we'll see.

The opinion from the 10th Mtn Hut Ass'n (just rec'd this email today):

New "Over-Snow Vehicles"
(a.k.a. Snowmobiles) Rule

YOUR COMMENTS ARE NEEDED NOW!

DO YOU PREFER a human-powered, non-motorized winter experience in the backcountry? Most hut visitors do and this is why 10th Mountain and others have worked diligently to help preserve and improve this type of experience.

Consequently, conditions have improved at many of the huts, particularly those located on the White River National Forest because it was one of the first to implement a winter travel management plan that effectively addressed "over-snow vehicles" (a.k.a. "snowmobiles").

The US Forest Service is now gathering public input on a proposed rule requiring forests across the country (those that have snow) to develop and implement winter travel management plans.

This is a great step in the right direction and the US Forest Service is to be commended. Regrettably, the draft rule (issued June 18, 2014) misses the mark on several issues and your direct involvement is needed to improve it.

ISSUE #1

1 | The draft rule allows the US Forest Service to maintain an
"Open unless Designated Closed" approach for snowmobiles which is the status quo on many forests. Instead, the rule should require a "Closed unless Designated Open" approach. This would be more effective because it would be consistent with summer rules (for off-road vehicle use) and easier for users to follow and the agency to enforce. This approach has worked well on the White River National Forest and is worth replicating.

ISSUES #2 and #3

The draft rule also gives the agency 2 huge loopholes:
2 | The US Forest Service can simply grandfather in old outdated winter decisions and avoid updated planning, and...

3 | They can leave huge swaths unregulated under the term "open areas" that can be larger than an entire Ranger District (upwards of a million acres in size).

These 2 loopholes can undermine the entire intent of the new rule.

10th Mountain is working closely with the Colorado Mountain Club's Backcountry Snowsports Initiative (BSI) and Winter Wildlands Alliance, the nation's leading voice for human-powered winter recreation, but we need YOU to personally weigh in.

Together these groups have provided everything you need to comment and ensure human-powered users in Colorado and around the country are represented.

You can find all the information you need online at: www.cmc.org/bsi

This is a rare opportunity to help shape Forest Service policy. But we don't have a lot of time-comments need to be submitted before August 4, 2014-it's critical that the Forest Service hear from the ski, snowboard, snowshoe and mountaineering communities.

A strong rule today means balanced management of winter recreation tomorrow. Please take 10 minutes to weigh-in on this once-in-a-generation opportunity to impact how the backcountry is managed.

The proposed rule is weak and allows the Forest to basically declare that the District is an area, and that area is open to OSV use.   Regardless of how the rule comes out, I hope our local forest managers are deliberate about the use designations.  This would ease conflict between user groups.  Here are the comments I left on the regulations.gov site:


July 22, 2014

Joseph Adamson
Recreation, Heritage, and Volunteer Resources Staff
1400 Independence Avenue SW., Stop 1125
Washington, DC 20250- 1125

SUBJECT: Comments on Proposed Over-Snow Vehicle Use rule


COMMENTS: Oppose Open unless designated Closed (Section 212.81 (a))
        Oppose modifying the definition of “Area” (Section 212.1)
        Oppose grandfathering previous decisions (Section 212.81 (b))

Dear Mr. Adamson,

I recreate in the Wenatchee National Forest in central Washington State.  My passion is backcountry skiing and I am a year-round skier active in the “Turns-All-Year” community.   I live near the Wenatchee Mountains where there is just one easy access point for non-motorized winter recreationalists to approach the two basins which I visit frequently for backcountry skiing.   The basins are locally known as the Lake Clara Area, and the Stemilt Basin.  Unfortunately both of these areas are also accessed by high powered snowmobiles and snow bikes which destroy the quality of my wintertime forest experience.   When this happens, I have no easy alternate area in which to recreate.  The user conflict between back-country skiers and OSV users in my area is frequent.  For this reason, I am very excited that the Forest Service intends to manage the wintertime forest.   I have read the proposed rule and offer the following comments:

1.  Oppose Open unless designated Closed (Section 212.81 (a))
I am disappointed that the rule does not seem consistent with the summer travel management rule which requires that off road vehicle use is confined to areas that are designated open to their use.  The proposed winter rule allows areas to be open to OSV use unless designated closed.  I am opposed to the idea that a Forest can rule that everything is open to over-snow vehicle travel unless designated closed.  I expect areas open to OSV use to be studied and deliberately marked as acceptable locations for this use.  To declare an area open unless designated closed allows a use without proper study or discussion, and does little to reduce user conflict.   Please rewrite Section 212.81 (a) to read “…shall be prohibited unless designated as allowed…”

2. Oppose modifying the definition of “Area” (Section 212.1)
The proposed rule modifies the definition of “Area”, to include the phrase, “except for over-snow vehicle use”.  I see no excuse to modify a definition in a conditional manner.  Either change the definition of “Area” globally, or do not change it at all.  To have a definition dependent on context creates confusion.  This definition modification is unnecessary.  It gives the appearance that the creation of the rule was influenced not by a desire to manage the wintertime forest, but to please the Snowmobile lobbyist.  Please do not change the definition of “Area”.

3. Oppose grandfathering previous decisions (Section 212.81 (b))
The proposed rule allows previous administrative decisions regarding OSV use to stand without public input.  This portion of the rule prevents the new rule from solving the user group conflict I experience in my favorite local areas.  The previous decision in my local forest has been to look the other way and allow OSV use nearly everywhere outside of Wilderness Areas.  To be effective, management of the winter forest must be deliberate, and grandfathering previous decisions robs the process from proper consideration and planning.  Please delete Section 212.81 (b) which grandfathers previous decisions.

Thank you for the opportunity to comment on the proposed rule.  I look forward to active management of our winter Forest.

Sincerely,

Mike Rolfs
Wenatchee, WA

Monday, August 4 (tomorrow) is the deadline for comments. I think you have until midnight to submit.

Here is the link to submit comments.

I've been super busy so I only just submitted my comments this evening. Here they are, for what it's worth:

August 3, 2014
Joseph Adamson
Recreation, Heritage, and Volunteer Resources Staff
1400 Independence Avenue SW., Stop 1125
Washington, DC 20250-1125

Dear Mr. Adamson,

I would like to comment on the Forest Service’s proposed rule for over-snow vehicle (OSV) use. I am a long-time backcountry skier in the Washington Cascades. I am also a member of The Mountaineers in Seattle and a regional expert on backcountry skiing history. My website, alpenglow.org, was recognized for excellence by the International Skiing History Association in 2010.

I have been backcountry skiing in the Cascades since the late 1970s. Over that time, participation in backcountry skiing, both locally and nationally, has grown dramatically. I don’t have formal statistics, but my experience suggests that the number of backcountry skiers has doubled several times in the past 25 years. At the same time, the number of OSVs has also grown and the ability of these vehicles to penetrate rugged and remote backcountry terrain has undergone a revolutionary change. While snowmobiles were limited to gentle roads and trails in the 1970s, they are now capable of climbing slopes as steep as 45-degrees, terrain challenging even for expert skiers.

In my experience, motorized winter recreation is fundamentally incompatible with non-motorized winter recreation. The noise and exhaust created by OSVs, while unpleasant, is not really the issue. The key reason for incompatibility between these user groups is the ability of motorized users to travel much faster and farther than non-motorized users. The key resources sought by non-motorized winter recreationists are untracked snow and (for many) a sense of solitude. Motorized users, because of the huge disparity in the speed at which they travel, “consume” these resources much faster than non-motorized users do. The scale of the disparity is on the order of 10-to-1. In a few hours, a group of OSV users can track out an area that would take many days for non-motorized users to cover.

For this reason, non-motorized recreationists generally regard areas used by OSVs to be unsuitable for non-motorized use. This leads me to conclude that the proposed travel management rule for OSVs is flawed. The section “Background and Need for the Rule” states:

"A key difference between OSV use and other types of motor vehicle use is that, when properly operated and managed, OSVs do not make direct contact with soil, water, and vegetation, whereas most other types of motor vehicles operate directly on the ground. Unlike other types of motor vehicles traveling cross-country, OSVs traveling cross-country generally do not create a permanent trail or have a direct impact on soil and ground vegetation. In some areas of the country, OSV use is therefore not always confined to roads and trails."

From this premise, the proposed rule appears to conclude that the impact of OSVs is so much less than other motorized vehicles that forest managers should be able to designate OSVs as allowed except where specifically prohibited. In contrast, the normal rule for motorized vehicles specifies that such vehicles are prohibited except where their use has been explicitly allowed. Because OSVs can travel cross-country, I believe that their impact, from the standpoint of incompatibility with non-motorized users, is actually greater than dry-land motor vehicles. Therefore, I think that the assumption of minimal impact by OSVs is wrong and the provision for “allowed unless prohibited” should be discarded.

The key issue surrounding the use of OSVs is the problem of incompatible user groups. Damage by OSVs to trails and cross-country areas does occur (especially in early and late winter, when snow depth is low) but that is not the main reason why OSV rules need to be revised. The revised rules must address the problem of incompatible use. This will require study in each forest district of past, present, and projected future use by both non-motorized and motorized user groups with the goal of designating separate areas for these groups. I don’t think this has been done in my region, the Washington Cascades, so I don’t think past administrative decisions in this region provide an adequate basis for future management.

I believe that the OSV exemption in Subpart B of the 2005 Travel Management Rule should be removed. I think individual Forests should be allowed to designate areas for OSV use, but I think the “allowed unless prohibited” approach should be abandoned. I think the Forest Service needs to take a hard look at where motorized use is truly appropriate. The current rules have failed to keep up with the advances in OSV capabilities, and a revision is needed.

Thank you for the opportunity to comment on this important issue.

Sincerely,

Lowell Skoog
Seattle, Washington

Note: I edited my comments here for clarity after submitting them to USFS.

For what it's worth (yeah, I know it's late) here are some guidelines that The Mountaineers distributed a while back regarding the proposed rules:

Concerns and Recommendations

1.  Individual forests or ranger districts can choose to implement an “open unless designated closed” approach (the status quo) or a “closed unless designated open.”

Concern: This would allow ranger districts to take no action – leaving areas open to OSV use as they are currently. A number of areas could experience very negative impact to the human-powered experience if OSV use were allowed. We would like to see the Forest Service to better manage conflict areas.

Our recommendation: The Forest Service’s travel management rule for off road vehicles (the non-winter equivalent of OSVs) is the ‘closed unless designated open’ approach. We would like to see this same approach for winter use.

2.  The draft appears to grandfather-in a range of past designations for over-snow vehicle use.

Concern: This could allow past administrative decisions that were not comprehensive in scope, analysis, or public involvement to count as travel plans. While some Forests or Ranger Districts might have undertaken plans aimed toward minimizing user conflict and resource damage, and involved the public in a meaningful way, we do not feel this has been the norm in Washington State.

Our recommendation: We would like to see a process that identifies aspects of what a comprehensive process looks like and that calls for Forests to undertake a comprehensive planning.

3.  Mention of other types of winter travel in the draft

Concern: The draft nowhere mentions other types of winter recreation or travel (i.e., skiing, snow shoeing, etc.). Only OSV use and impact are mentioned. We are concerned this will translate into Forests not having to take conflicts between motorized travel and human-powered travel into account.

Our recommendation: The Forest Service needs to issue a final over-snow vehicle rule consistent with Executive Order 11644. Executive Order 11664 requires the regulation of off-road vehicles – including OSVs – to specific routes and areas. By issuing a final over-snow vehicle rule consistant with EO 11644, each ranger district must take into account motorized and human-powered recreation uses, OSV impact on wildlife and other forest resources.

From an email sent by The Mountaineers on 8/15/2014:

Last month, we encouraged folks to share their thoughts on the Forest Service’s draft rule for over snow travel management. Winter Wildlands Alliance (WWA) exceeded their goal of generating 1,000 comments to the Forest Service on this issue. Most of the comments are now posted on regulations.gov, and of the 1,560 comments posted, the vast majority - 72% (1,122) - reflected the WWA's talking points, or were in support of creating space for both quiet and motorized winter recreation.

Winter Wildlands staff went to D.C. to meet with the Forest Service decision makers and share comments. During those meetings, the Forest Service told the WWA they were placing a lot of weight on public comments, reflecting the power of our individual voices on conservation issues.

Congratulations to everyone who submitted comments to the Forest Service! We will continue to provide information and opportunities for you to weigh in on issues like these.