Jennie
O’Connor
Mt.
Hood National Forest Travel Plan Team Leader
6780
Highway 35
Parkdale,
OR 97041
MHNF
Travel Plan Team:
Please
accept these comments from the Restore Mt. Hood Coalition (Coalition) in response
to the proposed Mt. Hood National Forest Off-Highway Vehicle (OHV) Travel
Management Plan (OHV Plan). The Coalition commends the Forest Service for
recognizing the importance of controlling OHV abuse in Mt. Hood National Forest
(MHNF) – all Americans have the right to enjoy our public forests, but no one has
the right to destroy them or to ruin the experience of other forest visitors.
The
Restore Mt. Hood Coalition represents recreation and conservation organizations
committed to promoting and preserving Mt. Hood National Forest’s world-class
recreation opportunities and healthy ecosystems. We believe that a Mt. Hood
Travel Plan should provide a framework for all users and not just OHV riders. Therefore,
we respectfully request that the Forest Service expand the scope of the OHV Plan
to simultaneously address the impacts of OHV use AND the crumbling road system on
ecosystem health and quiet recreational opportunities. The result will be a
stronger Mt. Hood recreational community, a more robust recreation
infrastructure, improved relations with
adjacent landowners and communities, and
healthier ecosystems.
Travel plan regulations intent
broad, Mt. Hood plan narrow
The
nationally-mandated travel planning process is designed to create a framework
for current and future travel infrastructure decisions. The regulations (36 CFR
212,251,261, and 295) clearly state that the Forest Service should address “all motorized travel” and identify the
“minimum road system” necessary. Emphasis
added. However, the purpose and need of the proposed OHV Plan addresses only
two small parts of larger travel planning needs on Mt. Hood. The approach described
in the Notice of Intent states that the “National Environmental Policy Act
(NEPA) process will only address OHV use and motorized access to dispersed
camping.” In order for the true intent of travel planning to be realized, the
Forest Service must address off-road user needs simultaneously with the needs
of quiet recreationists, other forest visitors, and the ecosystem impacts of the
various modes and conditions of travel throughout the forest.
Multiple
Forest Service documents raise concerns associated with the extensive road
network within MHNF (~3,464 miles), including the need for greater road
closures, decommissions, and maintenance. The 1999 Mt. Hood Access and Travel
Management Plan (ATM) found that 49% of the classified road system is “…closed
now or could be closed or decommissioned in the future” to mitigate the threat
to fish and wildlife habitat and drinking watersheds. The Mt. Hood National
Forest 2003 Roads Analysis states that “preliminary estimates indicate that the
Forest Service is underfunded by more than 50% to maintain the current road
network to full objective maintenance-level standards.” Despite the 1999 and
2003 analyses, there is limited information on the effectiveness of current
road closures and decommissioning efforts. Bark, a Coalition member, conducted
a forest-wide road inventory and found that out of 335 road segments surveyed,
twenty-six percent, or eighty-seven road segments, had clear signs of OHV use despite
being labeled “closed” by the Forest Service. Without the elimination of
unneeded roads, the Forest Service has a limited ability to prevent roads
listed as closed from being abused or further damaged.
Mt. Hood National Forest deserves
a vision
The
Coalition has adopted a vision for Mt. Hood National Forest that will
successfully meet the intent of USFS travel management regulations as well as
the needs of all stakeholders. Given the absence of a vision offered by the
Forest Service to guide the OHV Plan and related travel management decisions,
we encourage the Forest Service to adopt language similar to the following
citizen-generated vision.
The Restore Mt. Hood Coalition
envisions a future for Mt. Hood National Forest that balances long-term
ecosystem health with diverse recreation opportunities by protecting the health
and safety of different users and minimizing conflicts with adjacent landowners
and communities.
In
order to implement this vision, we propose the OHV and travel management plan
include the following outcomes:
·
The
Coalition supports a travel planning process that designates OHV areas only
where it is demonstrated that there will be adequate enforcement and minimal
user conflicts.
·
The
Coalition supports a travel planning process that includes the evaluation of
the year-round impacts of motorized travel on existing roads, trails, and areas
with the goal of using this information for future recreation planning and
management decisions.
·
The
Coalition supports a travel planning process that uses quantifiable standards
to determine roads that should remain open or be improved, roads that should be
closed through passive decommissioning, and roads that should be removed
through active decommissioning.
·
The
Coalition supports a travel planning process that attains the minimum road
system necessary to balance Forest Service administrative needs with recreational
needs and long-term ecosystem health.
Overcoming obstacles
The
Coalition believes that by working together with the Forest Service and other
stakeholders that the current scope of travel planning can be expanded to
implement a comprehensive, yet timely, Mt. Hood Travel Plan. Based on two
meetings with Mt. Hood National Forest Supervisor, Gary Larsen, we understand
that our vision echoes similar sentiments within the agency: nationally, as
described in the 2001 Roads Rule and 2005 Travel Management Rule, and locally,
as described in the 1999 ATM and 2003 Roads Analysis. However, Mr. Larsen has
expressed to us his concern in accomplishing a more comprehensive Travel Plan
due to the following four constraints:
1.
Staff resources: The Forest Service does not
have the resources to do the NEPA analysis (i.e. write an environmental impact
statement on removing, maintaining, or upgrading roads).
2.
Politics: The Forest Service feels that
the OHV proposal is already contentious enough and is concerned about the added
controversy of road removal.
3.
Timing: The Travel Plan must be
completed by November 2009.
4.
Regional agency direction: Internal direction is to
focus on OHV planning and not open up travel planning to non-OHV needs.
Common sense solutions to real
problems
The
Coalition is committed to working with the Forest Service to circumvent these
constraints and broaden the scope of the travel planning process to comply with
both regulatory mandates and previous Forest Service recommendations for Mt.
Hood roads. The Coalition suggests the following resources and solutions for
working together on this process:
1.
Staff
resources and funding: In the last year, the Coalition
has contributed over 2,000 hours of volunteer time inventorying the Mt. Hood
road network. Data has been collected on road closures breached by OHVs, failing
culverts, and recreation demands. Recognizing that information collected by
non-professionals may not provide sufficient data for a comprehensive Travel
Plan and Environmental Impact Statement (EIS), the Coalition has secured
funding for consultation services to assist the agency’s data collection and
analysis. The Forest Service has an extensive history of working with multiple
Portland-based consulting firms in the collection and analysis of data for a
variety of NEPA processes. The Coalition encourages entering into a cost-share agreement
with the Forest Service were it to expand the scope of the travel plan to
address forest-wide travel needs while seeking opportunities for active and
passive road decommissioning.
2.
Timing: We believe that the following
Forest Service documents serve as a model for expanding the scope of the
planning process by providing baseline information and identifying existing data
gaps: the 1990 Mt. Hood Land and Resource Management Plan, 1999 ATM, 2003 Roads
Analysis, 2004 National Visitor Use Monitoring Project, 2007 Oregon State
Comprehensive Outdoor Recreation Plan, various 5th field watershed
analyses, and guiding regulations found at 36 CFR 212,251,261, and 295.
Federal
contracting requirements allow for an abbreviated procedure when working with previously certified contractors. The Coalition
would be supportive of utilizing such a process to identify a consultant in a
timely manner and begin implementation as soon as possible. We believe that the
combination of existing documentation and guidance, flexibility in federal contracting
process, and willingness of the Coalition to work with the Forest Service facilitates
the development of a comprehensive Travel Plan to be completed well
within the September 2009 goal.
3.
Politics: Removing unnecessary roads is
only one small (although well documented) component of a truly comprehensive
travel plan. The Coalition represents 50,000 Oregonians who recreate in Mt.
Hood National Forest, depend on it for drinking water, and believe that a truly
comprehensive Travel Plan is less controversial than one which only caters to
one user group.
A timeline for a comprehensive
Travel Plan
The
Restore Mt. Hood Coalition realizes that time is limited, but we also want the
Forest Service to move forward in a way that is inclusive and thorough. The
Coalition is sensitive to the September 2009 timeline for this process. By
moving forward with an expanded scope the Coalition feels the process will be
more effective and diminish the likelihood of an administrative appeal. In
order to realistically accomplish the goals outlined above, we propose the
timeline below that we believe will allow for the completion of the necessary
Motor Vehicle Use Map by the September 2009 deadline.
·
Re-issuance
of Notice of Intent following required travel analysis February 2008
·
Publication
of Draft EIS August 2008
·
Final
EIS and accompanying Record of Decision completed November 2008
We
understand the current constraints under which the Forest Service is working
and offer resources and potential solutions to help alleviate some of the
burden. We hope the Forest Service will move forward with an inclusive and
transparent process that meets regulatory mandates, addresses ongoing resource
impacts, and is responsive to diverse stakeholder concerns. By broadening the scope
of the OHV Plan to be more consistent with the intent of the November 2005
Travel Management Rule, the Forest Service, the Coalition, and other
stakeholders can work together to create a long-term and sustainable vision for
MHNF that results in a stronger Mt.
We
would appreciate as soon as possible confirmation of your receipt of this
letter and a written response to our proposals outlined herein by November 30th.
It is our desire to meet with the plan ID team and forest supervisor to discuss
these proposals in greater detail.
Sincerely,
The
Restore Mt. Hood Coalition
Randy
Rasmussen
American Hiking Society
946
NW Circle Blvd. #145
Corvallis,
OR 97330
David
Moryc
American Rivers
320
SW Stark Street
Suite 412
Portland, OR 97204
Thomas O'Keefe, PhD
American
Whitewater
3537 NE 87th St.
Seattle, WA 98115
Bob
Sallinger
Audubon Society of Portland
5151
NW Cornell Road
Portland,
OR 97210
Alex
P. Brown
Bark
PO
Box 12065
Portland,
OR 97212
Noah Greenwald, M.S.
Center
for Biological Diversity
PO Box 11374
Portland, OR 97211
Jurgen
Hess
Columbia Gorge Institute
412
– 24th St
Hood River, OR 97031
541-386-2668
Barbara Wilson
Friends
of Mt. Hood
12820 SW 20th Court
Beaverton, OR 97008
Lisa
Moscinski
Gifford Pinchot Task Force
917
SW Oak St.
Portland,
OR 97205
Ivan Maluski
Oregon Chapter Sierra Club
2950 SE Stark Suite 110
Portland, OR 97214
Jonathan Graca
Hood River Valley
Residents Committee
PO
Box 1544
Hood River, Oregon 97031
Russ Pascoe
Lower Columbia
Canoe Club
400 E 22nd Ave
Vancouver, WA 98663
Heather Campbell
Mazamas
527 SE 43rd Ave.
Portland, OR 97215
Neil Clark
Northwest
Environmental Defense Center (NEDC)
10015
S.W. Terwilliger Boulevard
Portland, Oregon 97219-7799
Tom Wolf
Oregon Council
Trout Unlimited
22875 NW Chestnut St.
Hillsboro, OR 97124
Keith de Wit
Oregon
Kayak and Canoe Club
8125 SW 71st Ave
Portland, OR 97223
Brett Brownscombe
Oregon
Trout
65 SW Yamhill St.
Portland, OR 97204
Bill
Erickson
Oregon Wild
5825
N. Greeley Ave.
Portland,
OR 97217
Mary Scurlock
Pacific Rivers Council
917 SW Oak Street, #403
Portland, OR 97205