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From the Landuse Frontlines - NRC South Report - June 2019 - 4x4Voice


Recreation, environment, access, and land use news and information for California.
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From the Landuse Frontlines...

NRC South Report - June 2019

Sierra National Forest - The Sierra NF recently requested comments on travel management issues.  I have submitted comments on behalf of Cal4Wheel. The focus of my comments is that this effort is proceeding without the release of the Forest Plan Revision which may influence the outcome.

The Sierra NF is revising its Forest Land and Resource Management Plan under the provisions of the 2012 National Forest System Planning Rule.  That document contains the overarching guidance for forest management activities.

There are a couple of points where a “roads analysis process” has been completed and yet it is not provided as context to the request for proposed action.  Overall, I feel the Sierra NF proposed project is premature as there are several relevant documents that are not available for public review.

At this point in time, ALL forests in Region 5 have completed initial Travel management and Route Designation process as defined in the Travel Management Rule (TMR).  That effort was accomplished with approximately $10 million in OHMVR Grant Funding to the Forest Service to complete GIS surveys of the forests.

Since that time, a handful of Forests have followed on with the annual review required by TMR. 

The four southern forests (Los Padres, Angeles, San Bernardino and Cleveland) have the most current (and annually reviewed) travel management plans.  That effort was accomplished as part a settlement of a lawsuit filed by the Sate of California against the Forest Service.  BlueRibbon Coalition, AMA D 36 and Cal4Wheel filed as intervenors in support of Forest Service.  I was a party to the settlement hearings.

The Sierra, Sequoia and Inyo NF are undergoing Forest Plan Revisions.  The Inyo has worked through the objection phase.  My protest comments submitted on behalf of Cal4Wheel were accepted and discussed at the Objection Settlement Conference in Bishop in February, 2019.

Sierra and Sequoia FP Revisions - The Sierra and Sequoia NFs recently announced the release of the revised draft environmental impact statement and revised draft land management plans. Earlier versions of these draft documents were released in 2016. They have since revised the draft documents to address changed conditions across the landscape, including extensive tree mortality, and other concerns brought up through public participation.  I have submitted comments on behalf of cal4Wheel for those draft plans.

The revised draft documents are available for a 90-day public comment period, starting from the date of publication in the Federal Register (June 28, 2019). The public comment period will close on September 26, 2019.

The documents can be found on the project website at:

Additional information concerning public meetings can be found on the project website. The webinar is scheduled for July 10, 12:00-1:30 p.m. (Pacific) to provide an orientation to the revised draft environmental impact statement and revised draft land management plans. The Forest Service will host public meetings on both forests in August to discuss the draft plans, answer questions and accept comments.

Within the next year, the remaining forests in Region 5 will be undergoing their Forest Plan Revision which will include a review of travel management.  The final date (schedule) for beginning that process has not been finalized.

Forest Service - The U.S. Forest Service (USFS) released proposed changes to modernize how the agency complies with the National Environmental Policy Act (NEPA).

The proposed updates would not only give the Forest Service the tools and flexibility to manage the land and tackle critical challenges like wildfire, insects, and disease but also improve service to the American people. Revising the rules will improve forest conditions and make it simpler for people to use and enjoy their national forests and grasslands at lower cost to the taxpayer. The revised rules will also make it easier to maintain and repair the infrastructure people need to use and enjoy their public lands—the roads, trails, campgrounds, and other facilities.

While these proposed changes will save time and resources, they are ultimately intended to better protect people, communities and forests from catastrophic wildfire and ensure a high level of engagement with people and communities when doing related work and associated environmental analyses.

While many aspects are contained in the proposed updates, the portion concerning expanded use of a CatX (Categorical Exclusion) for forest management activities involving wildfire prevention and recovery is important as it provides a connection to trail maintenance activities. A viable network of routes to provide access to forest areas is a core component of forest management.  Revisions to the CatX will reduce the time and expense of conduction necessary trail maintenance activities.

Comments on the proposed NEPA revisions are due August 12, 2019.

Angeles NF - The Forest Service has completed the Land Management Plan Amendment, Environmental Assessment (EA), and Decision Notice for the San Gabriel Mountains National Monument. The Monument Plan provides guidance for the Angeles National Forest to manage the area’s unique ecological, social, and cultural resources for years to come.
The Monument, established in 2014, is part of the Angeles National Forest and encompasses more than 346,000 acres of high-use public land. More than 17 million people live within 90 minutes of the San Gabriel Mountains, which provide area residents roughly 30 percent of their water and 70 percent of their open space.
State Parks (Hungry Valley SVRA) - Based on input received so far throughout the General Plan Update process, California State Parks has developed Guiding Statements for the General Plan Update. These Guiding Statements will serve as key guidance for the General Plan Update.

I have responded to the on-line survey for the Guiding Principles.  In general, there are few areas where I disagree with the Guiding Principles.  When the draft General Plan is released I will be providing comments on behalf of Cal4Wheel.

Federal Legislation - Legislation meant to remove redundancy and increase efficiency for outdoor recreation on federal land has been submitted in the U.S. Senate.  The proposed legislation would simplify the recreation permits process.

The "Simplifying Outdoor Access for Recreation Act," introduced by Sen. Martin Heinrich (D-N.M.) and co-sponsored by Sen. Shelley Moore Capito (R-W.Va.), would direct agencies to allow for online permit applications, allow one permit even if multiple agencies have jurisdiction and allow a single permit to cover activities that are "substantially similar."

The bill would also update fees in the Federal Lands Recreation Enhancement Act to help lower costs for those applying.

BLM - West Mojave Route Network Plan - BLM has completed its West Mojave Route Network Plan.  As a long time participant in the planning effort to bring this forward, I am generally pleased that it is a good plan for recreation interests in the West Mojave region.  I do harbor some concerns and have submitted a protest on behalf of Cal4Wheel.

I have long been a proponent for the BLM (and other public agencies developing land planning documents) to incorporate a valid socio-economic analysis within their planning documents.
With respect to the WMRNP, the milage of routes quantified fails to address the economic impact of those routes. 

As noted within the National Environmental Policy Act (NEPA), “…when environmental impacts are considered, these impacts are not limited to the physical environment, but also include impacts to the human environment. The human environment includes the social and economic considerations within the county.”

The outdoor recreation industry jointly commissioned the firm of Southwick Associates to conduct a survey of Americans on their spending on outdoor recreation equipment and activities. The partners wanted to determine the economic impact of outdoor recreation. The findings of the survey are summarized in the report: A Snapshot of The Economic Impact of Outdoor Recreation, June 2012.

As noted in that study, “Spending on outdoor recreation is a vital part of the national and western economies. It means jobs and incomes and can be the lifeblood of many rural communities in the West. This snapshot helps highlight the value of this often overlooked sector – one that is not otherwise measured as a traditional pillar of the U.S. economy.”

The economic impacts of OHV recreation should be compared to the economic value or consumer surplus derived from OHV use for making policy decisions. Consumer surplus is the value of a recreation activity beyond what must be paid to enjoy it. It is an economic measure of an individual's satisfaction after all costs of participation have been paid.

The consumer surplus, also called net willingness-to-pay, is the theoretically preferred measure of net benefits or net economic value (Bergstrom et al., 1990b). Summing individuals' net willingness-to-pay provides a measure of aggregate net benefits to society. Cost-benefit information can help policy makers and managers in making difficult decisions.

Similar types of economic impacts are frequently noted when other activities on public lands are analyzed for their economic verses environmental impact.  Recreation is one of those activities that NEPA requires an economic impact to be considered within the decision making process.

As noted in Cal4Wheel’s June 12, 2018 comments to the West Mojave Route Network Project,

“…Cal4Wheel believes that the loss of access to the West Mojave (WEMO) region for recreation opportunity is a direct loss. There are also indirect impacts that would result should this WMRNP be approved and implemented causing displacement of recreational activities. Those cost include, but not limited to: (1) the increased enforcement required at other sites when displaced recreational users seek out other areas that may be poorly identified as wildlife preserves or other resource-rich areas; (2) the loss of biological resources or habitat at other sites that displaced recreational users may utilize ; (3) the loss of nature education, (4) the loss of outdoor recreation opportunities, (5) the loss of outdoor access and experiences for children in the community; (6) the loss of familial traditions, custom, and culture of recreational and nature-oriented activities in the region; and (7) the loss of the region's history and traditions, specifically with respect to mining and recreational activities.”

The analysis (comment response) does not adequately address the benefits of motorized recreation and to responses to the comment fail to address the NEPA requirement to include impacts to the human environment. The human environment includes the social and economic considerations within the county.
The analysis does not adequately address the benefits of motorized recreation, the economic impacts (impacts to the human environment) are not quantified within the analysis of routes.  While reference to 43 CFR 8342.1 is noted and it is stated that route analysis was conducted in accordance with 43 CFR 8342.1, the lack of a quantified economic impact is not quantified as part of the analysis.  As noted in NEPA, “…impacts to the human environment. The human environment includes the social and economic considerations…” are required in the decision making process.

The analysis of economic impacts is part of the “other factors” in keeping with the “impacts to the human environment” theme of 43 CFR 8342.1(c).

In short, agency analysis considers cost to maintain and costs for enforcement is “economic” factors.  While those are valid costs the agency will incur, they are not valid nor representative of the social and economic consideration borne by the public impacted by the administrative decision.

BLM (Dingell Act) - The Dingell Act provided a number of benefits to OHV recreation in the Mojave Desert region from congressional designation changes of “open areas” to “OHV Areas”.  This minor change provides for a designation that removes the high value recreation areas fro consideration of other uses in the desert.  In addition, the Cady Mountains Wilderness Study Area was released from consideration as potential future wilderness.  One benefit to OHV, a long closed route just north of Rasor Road OHV Area that was not reflected as “open” in the WMRNP is now an open and designated by Congress OHV trail. 

As with any legislation, there will be minor issues as words on paper are translated to boundaries and action on the ground.  The area covered by the Dingell Act does encompass much of the area covered by the West Mojave Route Network Plan.  The legislation does contain verbiage that provides for minor boundary adjustments where an arbitrary line described in words may impact an actual route on the ground.

An errata sheet will be released late summer to address inconsistencies between the Dingell Act and the WMRNP.  The verbiage of the Dingell Act will prevail and the errata sheet will not be open for public comment.

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