Archive | May, 2011

COHVCO and TPA respond to the National Forest Planning Regulations

May 16, 2011

  This document is the combined comments of the TPA and COHVCO to the new Forest Service Planning document.

May 16, 2011

Forest Service Planning DEIS
C/O Bear West Company
132 E. 500 S
Bountiful, UT   84010

Dear Planning Team:

Thank you for the opportunity to comment on the proposed rule making for 36 CFR Part 219, The proposed National Forest System Land Management Planning regulations and DEIS.  This is a combined response from the Colorado Off-Highway Vehicle Coalition (COHVCO) and the Trails Preservation Alliance (TPA).

The Colorado Off-highway Vehicle Coalition (COHVCO), represents nearly 200,000 Coloradoans, and thousands of visitors from outside Colorado, who enjoy recreating on our public lands with off highway vehicles.  COHVCO is a volunteer based non-profit conservation organization that has focused on preserving and enhancing the opportunities of all OHV users in Colorado since 1987.  We represent Motorcycle, 4WD, ATV & Snowmobile enthusiasts.  COHVCO, its participating clubs, and enthusiasts provide not only thousands of volunteer hours, but contribute over $3 million each year to public lands for maintenance, trail repair, signage and other needed public facilities associated with road and trail use through Colorado’s OHV Registration Program

The Trails Preservation Alliance, TPA is focused on preserving motorized, single-track trail riding.  All forms of OHV recreation, ATV’s, 4WD’s, snowmobiles, are supported by the TPA.   However, its primary goal is to preserve single-track trail riding.  The TPA is a 100 percent volunteer organization whose intention is to be a viable partner, working with the United States Forest Service (USFS) and the Bureau of Land Management (BLM) to preserve the sport of trail riding.  The TPA acts as an advocate for motorized recreation and will take the necessary action to insure that the USFS and BLM allocate to motorized recreation a fair and equitable percentage of access to public lands.

Summary Statement

Our shared goal is to help establish planning principles and content under of the Multiple Use-Sustained Yield Act of 1960 (MUSYA) and the 1976 National Forest Management Act (NFMA), in order to develop and revise plans of the National Forest System in a timely and efficient manner.  The National Forest Management Act of 1976 was originally met with a great deal of anticipation for producing predictable integrated, long-range Forest management plans that were sustainable and met the needs of the diversity of American communities and their visitors.
The Summary document (page 5) states that the Agency has a 30-year history with land management planning.  We think this comment is well understated based on a proud 106 year old Agency who has always been responsive to changing community and resource issues and needs. Communities and resources have been served with reasonably designed planning processes and appropriately applied and adapted science since 1905.  Dedicated natural resources managers, adaptive science, and planning processes were applied well before 1976.
We are delighted to see recreation being listed as a legitimate, sustainable multiple-use on National Forests System lands.  However, we are deeply concerned about the statement and positioning of the planning process to “bind” requirements for ecological sustainability, and consider other uses as just contributions to social and economic sustainability.  This sets up a possible situation where human use and dependency to meet social needs and benefits on NFS lands are subservient to ecological sustainability.  This might allow the decision maker no discretion to adopt innovative human use alternatives. We feel that decision makers need the latitude to make choices that might feature human and community social and economic needs, while still providing for sustainable ecological systems and services.  

Recreation and other uses in the proposed planning regulations as written appear to be the first to be traded-off or mitigated in light of any changed ecological condition.  In order to get to this point you have to reduce the importance of the sustainability of human needs and their associated sciences, and then differentiate them from ecological sustainability and its associated sciences. We feel strongly that any planning process and the decisions regarding sustainability of all systems (social, economic, ecological) be equally available to planning teams and decision makers to develop the best possible set of alternatives.

We are particularly concerned about the future of motorized use. There has been a track record of the continued loss of motorized recreation opportunity outside of the planning process. This continued loss of opportunity has resulted, in part, from uncoordinated planning processes and the lack of effective monitoring programs to document change across unit boundaries. 

The promise of the NFMA was to have an integrated, interdisciplinary process that was transparent to and included the public input.  Decisions for long-term resources production and services were commitments made to insure community needs.  Expectations were established.  However, it seemed every time a political condition changed, an administration changed, or a new congressional initiative evolved (i.e. endangered species, new wilderness, roadless initiatives, new parks and monuments were ordered), decisions and policy evolved outside of the NFMA process.  The results have been that many selected, promised and planned motorized transportation facilities, access points and systems were eliminated from the motorized road and trail system inventory of opportunities that were committed to in the NFMA promise.

It has been extremely disappointing and extraordinarily costly since 1976 to have been involved in all of the appeals, suits, court cases, rule rewrites, suspended planning, issues and debates over an otherwise reasonably well developed NFMA planning process. We still have great anxiety about any of the proposed alternatives really solving the complex set of competing demands on public land, and the need by some to delay natural resources decision making.  The associated public land politics and pressures from widely divergent special interest groups may continue to override collaborative planning processes.  However, we standby to support the multiple-use role of National Forest System lands, and will help defend that role against any intent towards more restrictive access to the great legacy of NFS public lands. 

Concerns and Recommendations

Our comments, concerns, and recommendations are based on the following set of planning process objectives:

1.  That the selection of a planning alternative recognizes the need for a standardized unit-by-unit process for inventorying recreation facilities, settings, opportunities, activities and benefits across the full spectrum of needs and users.

2.  That the selection of  the planning process include and value the historic and unique uses of individual planning units and not just new trends in uses.
3.  That the definition of a “vibrant” community include the concept of a community of users who live and work outside of the unit plan area and who are dependent on  sustainable and long-term, predictable access to public lands nation-wide.

4.  That the planning process chosen is not so complex, expensive and time consuming that it practically eliminates participation by individual users and small local clubs because of costs to participate. 

5.  That the assessment and monitoring processes will allow the acceptance of data, based on approved sampling techniques, filed by forest users and volunteers.

6.  That the definitions of social sustainability and economic sustainability be added to the glossary of new planning terminology in order to avoid continued ambiguity over their application to the planning process.  Sustainability needs to include the elements of creative public-private partnership, volunteers and shared resources of communities and dependent users to help insure sustainable facilities and programs.

7.  That there be a monitoring and reporting process in place that tracks the loss of historic recreation use opportunities across regional landscapes, just as there is a need to track sensitive and endangered species and habitat losses.

8.  That the selected alternative for any new planning process eliminate the need for overlapping planning processes like, transportation system planning that re-allocates recreation opportunities for motorized and non-motorized recreation, stand alone wilderness and roadless studies, recreation niche decisions, project level decisions that change forest plan balance among the various recreation users, and special interest area studies.  

9.  That all applicable sciences and research be applied in equitable and balance manners to planning and analysis processes.  This includes the social and economic sciences.  Further, that the concept of “best available science” be more clearly defined to avoid legal challenges.
Concerns and Recommendations

1.  Social and economic sustainability and an appropriate planning process has still not been defined by the Forest Service.  Benefits-based management (BBM) recreation and its associated social sciences have not been included or referenced or cited to the same extent as the biological sciences. Nor, has a standard inventorying and assessment process like the Recreation Opportunity Spectrum (ROS) been established to get standardized information and monitoring results between planning units.   This leaves the appearance of placing a higher regard for the ecological sciences and their planning processes. This suggests a focus on preservation alternatives and a move away from conservation management alternatives in order to achieve ecological sustainability.

The planning issue of providing for “vibrant local economies” (Secretary Vilsack, page 2, DEIS)  and USFS Summary statement (page 3) “sustainable use…to support vibrant communities”  are introduced, new terminologies that lack  standardized planning approaches and definitions.  This sets up a continued concern for the stated position of just “contributing” to social and economic sustainability, rather than taking a responsibility for providing a predictable source of recreation of opportunities for effective community planning.  It further sets up a pre-decisional bias that does not allow the plan decision maker to examine a full range of alternatives that might need to include a binding set of  sustainable resource supply or social and economic services.
Recommendations:  Establish ROS and BBM as planning process requirements to order to achieve better public communications of opportunities and impacts between alternatives in a unit plan.  Further, reconsider the language of “binding” requirements for ecological sustainability, and “contribution” requirements for community social and economic sustainability.  Let the plans commit to all sustainability elements as national forests and grassland and the Department of Agriculture need to develop affirmative programs to provide for quality habitats, both human and ecological. 

2.  There appears to be conflicting set of planning objectives about collaborative processes and levels of decisions.  Section 219.4 sets up assurances that the Forest Service provide meaningful opportunities for the public to participate early in the planning process.  Provisions are made for consensus building, federal advisory committees to be inclusive of a diverse set of people and communities in the planning process.  Then, after some discussion about the importance of the sustainable social and economic needs of communities, the proposed rule at 219.4, page 28 says, “Requiring land management plans to be consistent with local government plans, would not allow the flexibility needed to address the diverse management needs on NFS lands and hamper the Agency’s ability to address regional and national interests…”.  

This portrays a double set of standards.  There is the impression that national forest and grasslands will work to provide economic stability for dependent local communities, and then pull back away to support national and regional needs not committing to or giving priority to local government plans. 

Recommendations:  If maintaining historic rural communities are to remain a priority focus for the Department of Agriculture, the Forest Service planning process needs to be give a stronger commitment to local government plans and be willing to mitigate some national and regional needs as appropriate. If forest supervisors are expected to help integrate community needs, restrictive language on local planning commitment needs to be lifted and changed.

3.  We support the two-tiered monitoring plan concept of the proposed planning regulations.  However, we are unsure about how unit-level planning “would be informed by the assessment phase”, and how the associated broad-scale monitoring can take place with the loss of regional guidelines and with no stated regional goals or objectives.  This is exactly how regional and national motorized opportunities have been lost because there was no monitoring program in place at any level to watch for the cumulative effects of uncoordinated and incremental local non-motorized decision making at the forest project level.

Select a two-tiered monitoring program, but associate the assessment process more clearly.

Include the opportunity for the public and user groups to assist gathering and submitting data.

Re-institute regional guides and standards for trail system balance goals between motorized and non-motorized uses in order to have established objective amounts to be able to conduct broad-scale monitoring against.  Recreation use demands have “landscape scale” and regional scale impacts that will go unidentified at just the project or unit level.

The proposed regulations at 219.2 page 20 suggests a role for Regional Office oversight to provide consistency of planning interpretation and implementation on units within the region.  We believe this role should include the establishment of regional targets or objectives to help guide alternative development at the unit planning level.

Sec. 219.6 Assessments guidance needs to highlight the need for the Forest Service to also review and evaluate all other and separate planning decisions, i.e. roadless area policy, transportation planning decisions, in order to determine consistency with the forest plan and monitoring results. The Assessments process should also be linked to the Forest Service system of integrated management reviews to assess performance in implementation of plan priorities.      

4.  The proposed planning alternative has an incredible amount of new process associated with species viability, species of conservation concern, and candidate species especially with the inclusion of “native invertebrates”.  The level of assessments required in the wildlife area and the amount of science cited overwhelms the amount of analysis and science cited for social and economic sustainability assessments.

Recommendations:  Take a “second look” at the availability of science and its balanced application for all of the elements involved in determining ecological, social and economic sustainability.  The recent response and finding by the team of science reviewers on this draft should be extremely valuable to guide reconsideration to balance science applications between resources.

5.   The Multiple Use planning direction of proposed 219.10 is generally complete and suggests not only the original uses, but an updated set of values and policy direction for the multiple uses. 


We want to assure that under 219.10 (a)(1) that the responsible official also consider not just recreation values and settings, but historic recreation use patterns and points of access and not just new trends.

Under 219.10(b)(i) Sustainable recreation needs to be defined  as including the predictability of opportunities, programs and facilities over time in order to satisfy the social sustainability requirements and needs of vibrant communities. Field units have thought that sustainability only applies to their ability to fund maintenance from appropriated funds, and does not apply to providing a continued supply of opportunities to meet personal/social need objectives.  The continued drift to non-motorized recreation and conflict is a classic example of this misunderstanding and misapplication of socially sustainability for all users.

6.  The discussion on page 60 under the discussion about 219.10 Multiple Uses requires the planners to take into account reasonably foreseeable risks.  Among those risks listed is the category “human-induced stressors” on the units resources.  Outdoor recreation is a human-based resource within a human environment under the Multiple Use Sustained Yield Act.  The discussions and planning requirements throughout the proposed document tend to make recreation use secondary to and trumped by all other resources.  There is a case that can be made that other resource decisions including wildlife can be stressors on the human environment.


Change the style of multiple-use management and risk assessments to avoid a hierarchical ordering of resources, and remain with the concept that all resources interact with each other in a system of stressful ways, both positively and negatively.  The entire document needs to be edited to avoid statements that bias human use and recreation as stressors, as this is not fair to a balanced, sustainable social-economic-ecological planning process.

We are supportive of Alternative A , subject to our recommendations, as it clarifies and requires collaborative planning, pre-decisional opportunities for input, a broad-landscape approach to monitoring and a higher level of social/economic analysis for sustainability of committees dependent on public land resources.

We are appreciative of the effort the Forest Service has taken to try and correct and update the current planning process.  While it is more complex and will be more costly, we hope it will move the process along so unit plans can be brought up to date and amended in more timely and responsive ways.


/s/ Jerry Abboud, Executive Director       
Colorado Off-Highway Vehicle Coalition   
13670 Cherry Way               
Thornton, CO  80602   

/s/Don Riggle, Director of Operations
Trails Preservation Alliance
725 Palomar Lane
Colorado Springs, CO  80906-1086


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