Comments on the Draft Environmental Impact Statement for Travel Management…

The TPA in conjunction with it New Mexico supporters, and COHVCO have decided to respond to the Santa Fe NF DEIS/TMP document.  This decision was made to help the New Mexico motorcycle riders in their quest to preserve single track motorcycle trail riding.  This action follows the mission statement of the TPA, and was the right thing to do to help preserve public access to public lands.

September 29,2010
Delivered via Federal Express and email tosftravelmgt@fsfed.us

SFNF Travel Comments
11 Forest Lane
Santa Fe, NM 87508

Dear SFNF ID Team:
We submit the following comments regarding the Draft Environmental Impact Statement (“DEIS”) for Travel Management on the Santa Fe National Forest (“SFNF”), July 2010, on behalf of the Trails Preservation Alliance (“TPA”), Colorado Off-Highway Vehicle Coalition (“COHVCO”), Jim Burton, Greg Fleming, Ed Hoffman, and John O’Malia (collectively “the Recreation Groups”). We appreciate the opportunity to provide comments and to work with the Forest Service to ensure that the public is afforded ample motorized recreation and access opportunities on the SFNF.

Background
The DEIS addresses the purpose of complying with national policy articulated in the 2005 Travel Management Rule (“TMR”) (70 Fed. Reg. 68264 et seq., Nov. 9, 2005; 36 CFR Parts 212, 251, 261 and 295). It is important to note at the outset that the TMR is not a “closure” directive as portrayed by some preservationist special interests. Then-Chief Dale Bosworth stated upon release of the TMR that “[l]and Managers will use the new rule to continue to work with motorized sports enthusiasts, conservations, state and local officials and others to provide responsible motorized recreational experiences in national forests and grasslands for the long run.” USDA Forest Service, News Releases, “USDA Releases Final Rule for Motorized Recreation in National Forests & Grasslands,” dated November 2, 2005. “A managed system of roads, trails and area designated for motor vehicle use will better protect natural and cultural resources, address use conflicts, and secure sustainable opportunities for public enjoyment of national forests and grasslands.” Travel Management Rule Final Communication Plan, November 2, 2005, p.5. In fact, “it is Forest Service Policy to provide to diversity of road and trail opportunities for experiencing a variety of environments and modes of travel consistent with the National Forest recreation role and land capability.” Forest Service Manual 2353.03(2); see also, 70 Fed. Reg. 68264 (“motor vehicles are a legitimate and appropriate way for people to enjoy their National Forests in the right places and with the proper management.”).

The Forest Service should be planning for a managed system, and working with all groups, including OHV enthusiasts, in order to comply with not only the agency’s own directives and the Travel Management Rule, but the policies behind the Rule.

The Recreation Groups have many members who live near and/or recreate in the SFNF. These activities include or are economically-connected to motorized and non-motorized recreation, including access by passenger auto, full-size four-wheel drive, ATV, UTV, motorcycle, mountain bike, horses, hiking and other modes of access. This recreational access is intrinsically rewarding for Recreation Groups’ members, but also facilitates other activities including sightseeing, camping, picnicking and day trips, hunting, fishing, photography, observing wildlife, wood and nut gathering, and similar activities. The restrictions proposed in the DEIS, even under Alternative 4 which we support among the range of present alternatives, will adversely impact the activities and recreational/aesthetic interests of Recreation Groups’ members.

These comments are supplemental to, and independent of, any submitted by individual or organizational members of the Recreation Groups. The agency shall independently evaluate and respond to all such comments. In particular, we will not attempt to address route-specific issues in these comments, but anticipate that many members and enthusiasts will do so. An effective response to such comments will be essential to the initial and long-term success of the Travel Management Plan on the SFNF. Please direct any correspondence regarding these comments to Paul Turcke via the above-listed contact information or pat@msbtlaw.com.

cont…

To read the rest of this 23 page document, download the PDF.