| December 6, 1999
USDA Forest Service - CAET Re: Comments on Proposal for National Forest System Roadless Areas Dear Sirs, Our family of four has enjoyed riding our motorcycles on primitive trails and roads within our public lands for the past 30 years. This form of recreation requires physical and mental skills, is great fun, and is family-oriented. We support and practice the "tread lightly" policy. We believe in sharing trails and respect the use of our public lands by other recreationists. We support motorized recreational use of our public lands and the opportunity that it provides for many other groups of recreationists. We recognize that there is activist opposition to the motorized recreational use of our public lands and offer the following comments to help support motorized recreational opportunities for the common citizen. Please consider the following comments when developing the scope of the Draft Environmental Impact Statement (DEIS) for National Forest System Roadless Areas, as announced in the Notice of Intent (NOI) issued 10/19/99. Comment 1. Motorized recreation is an important form of recreation. Attached are our observations from 1999 which demonstrates the types of recreationists visiting national forests in our area. We ask that the process include a fair evaluation of the need for motorized recreation and the existing level of use and that the decision-making be based on meeting those needs. Comment 2. We are concerned about the cumulative loss of motorized recreational opportunities at a time when we need to maintain a diversity of recreational opportunities. We ask that the document include a fair evaluation of the cumulative loss of motorized recreational opportunities and that the decision-making consider correcting this overall loss of motorized recreational opportunities. Comment 3. We ask that the DEIS include full evaluation of resource areas which support the creation or preservation of motorized recreational opportunities including the need for motorized recreational opportunities (number of people who benefit and enjoy), social and economic benefits (importance of a healthy human environment), environmental justice (equitable balance of opportunities), and cultural (responsibility to protect local values and character, motorized recreationist's values and cultural diversity). Comment 4. The protection of our natural resources including soil, water, vegetation, and wildlife are a concern that all of us share. However, in many cases where motorized closures have been enacted, the impacts from motorized recreationists on these resources have been minimal (acceptable) when objectively compared to other activities and the nature's own level of activity. Additionally, many impacts associated with motorized recreation can be mitigated by measures such as structural trail improvements and re-routing, education, and seasonal closures. We ask that the decision-makers develop and use an overall sense of magnitude when evaluating potential positive benefits to the natural environment versus negative impacts to the human environment. For example, the closure of a trail to reduce soil erosion in some cases may not produce a measurable difference in the sediment load of a stream or noxious weed problem while causing a significant loss of recreational opportunity. We ask that these sorts of situations be considered a reasonable use of our natural resources for the benefit of the public. Comment 5. We would like to see the Purpose and Need section address society's growing need for a diversity of recreation, what recreation means to all of us, the need to maintain existing motorized recreational opportunities and the need to create new opportunities for motorized recreationists. The 1996 Recreation Roundtable Survey found that; People who recreate on a regular basis, or for whom outdoor recreation was important while growing up, are more likely than all others to be completely satisfied with their lives... Reasons for participating in outdoor recreation reflect a commitment to family life and personal fitness. The number one reason for participating is "to have fun" (76%) and other key recreational motivators include "relaxation" (71%), "health and exercise" (70%), "family togetherness" (68%) and "stress reduction" (66%). Over the last year, the top recreational activity has been pleasure driving, done by 40% of the public. As these reasons indicate, we must provide recreational opportunities for everyone. Additionally, we are fortunate to have plenty of public land with which to provide those opportunities. Comment 6. Disturbance or protection of wildlife is another reason that is often used to enact motorized closures. All of us who have visited Yellowstone National Park have noted that the wildlife are not the least concerned with vehicular traffic. There are many other factors which influence wildlife behavior. Motorized recreation is not the most significant factor affecting wildlife populations. If hunting is the cause of wildlife impacts, then it should be addressed directly by implementing motorized closures during hunting seasons and/or enacting permit hunting. Addressing hunting management issues by enacting closures on motorized recreationists creates unnecessary significant negative impacts on motorized recreationists. Comment 7. Conflicts with other recreationists are often associated with noise. Noise associated with motorized recreation has been a sensitive point for many years. This concern can be mitigated, to some extent, by requiring Forest Service approved mufflers/spark arresters. Motorized recreationists can be called upon to enforce this requirement. In addition the Forest Service could initiate a theme campaign (less sound equals more ground) to promote use of quiet mufflers. It is unfair to use this reason to enact motorized closures (impose impacts on motorized recreationists) while not pursuing these sorts of viable alternatives. Additionally, some motorized noise, such as airplanes, exists even in the most remote areas and it is not reasonable to expect absolute quiet in areas intended for multiple-use by the public. Comment 8. The often use reason "conflicts with other users" needs to be addressed from the perspective of "fair-mindedness of expectations". To provide non-motorized experiences we have designated and set-aside wilderness/non-motorized use areas. Just as motorized recreationists do not expect to be able to use motorized vehicles in wilderness/non-motorized use areas, non-motorized enthusiasts should not expect to go to multiple-use areas and experience wilderness conditions. It is not equitable to manage multiple-use areas as segregated-use areas based on the reason that some users say they cannot accept other users. In order to be equitable, multiple-use areas should be managed to provide a diversity of use and all recreationists should be expected to respect and accept each other. If some non-motorized recreationists are really bothered by motorized recreationists, then they simply need to locate the many wilderness/non-motorized areas that are available to them. Comment 9. We have revisited trails and areas which received use by hundreds of motorized recreationists before they were closed and have observed that these same areas now receive much less recreational use by non-motorized users. This is also supported by the attached graphs. Opportunities for motorized recreationists are disappearing while non-motorized users are enjoying a growth of opportunities. New wilderness/non-motorized opportunities created through enactment of motorized closures must include the creation of new motorized recreational opportunities in order to offset the loss of motorized recreational opportunities, meet the needs of motorized recreationists, provide equal opportunities for motorized recreationists and to avoid imposing significant impacts on motorized recreationists. Comment 10. We must manage our resources to meet the needs of all citizens on an equitable basis. To maintain a healthy society the NEPA process must first determine the full scope of our needs. Then the process should develop and use a relative sense of magnitude to evaluate impacts and benefits. For example, keeping a motorized recreational trail open may result in the movement of 2 cubic yards of soil versus a natural movement of 1 cubic yard and provide 5 miles and 500 person-hours of recreational opportunity. NEPA decision-making must be based on a sensible comparison of environmental benefit to human benefit and environmental impact to human impact. Decision-making such as the DEIS for National Forest System Roadless Areas should allow for reasonable use of our resources with the purpose of meeting basic human needs which include motorized recreational opportunities. Comment 11. Decision-making documents prepared under the National Environmental Protection Act (NEPA) are intended to address the environmental concerns of the proposed action. NEPA was formulated to develop and address issues raised through public comment. The document preparation and decision-making enacted by NEPA are being shaped largely by public comment. This "watch dog" arrangement was originally incorporated into the process to assure that environmental issues would not be overlooked. NEPA was formulated to provide correction to abuses resulting from an era when projects were enacted with one-sided input and inadequate consideration for the natural environment. Now NEPA is being manipulated and has created its own version of one-sided input and inadequate consideration for the human environment. The flaw in the current NEPA process is that it allows activists to strongly manipulate the process to their advantage. NEPA has successfully brought environmental issues into the decision-making process and corrected past environmental inequities, however, it has also created human inequities. The current NEPA process does not provide the proper evaluation and recognition of the needs and rights of "Non-NEPA Activist Citizens" in the decision-making. For a variety of reasons, including lack of time and money, every citizen cannot possibly participate and comment on all of the NEPA actions that affect them. Additionally, the NEPA process encourages citizens who are opposed to a particular proposal to respond. Most often citizens who support a proposed action or existing conditions assume that their needs and rights will be considered and, therefore, do not participate in the NEPA process. It is not practical for all of the population to fully participate in NEPA. Therefore, decision-making is being shaped by "NEPA Activists" who have the time and money to manipulate NEPA issues in their favor and who also have a keen understanding of the NEPA process. The NEPA process is implementing actions that favor NEPA Activists and are creating significant negative impacts on Non-NEPA Activist Citizens. One of the most drastically affected groups is motorized recreationists, which represent a substantial group of recreationists who enjoy our public lands. Most NEPA documents prepared for travel management decision-making do not contain complete documentation of existing motorized recreational use, needs, and associated economic, cultural, legal, and social needs. Current NEPA decision-making is not fully considering issues associated with the human environment and, therefore, is not well-balanced. The NEPA decision-making process must be corrected so that it recognizes and protects the needs and rights of those who, for many different reasons, do not fully exploit the comment and public participation process. While we can encourage Non-NEPA Activist Citizens to fully participate in the NEPA process, this is an unrealistic expectation for many different reasons. The destructive flaw in the current NEPA process is that it allows one sector to strongly manipulate the process to their advantage. Non-NEPA Activist Citizens are disadvantaged because; (1) they do not have the same level of understanding of the NEPA process as do NEPA Activists, (2) for a variety of reasons they participate less than NEPA Activists, (3) they have less financial resources than NEPA Activists, and (4) they are less organized than NEPA Activists. Past environmental abuses have largely disappeared. Environmental issues and concerns are well-known and recognized by all involved. The correction sought by the creators of NEPA to enact environmental safe guards has now swung to an extreme. The NEPA process should not be so heavily influenced by NEPA Activists. The NEPA process should be adjusted to allow agencies and their professional staff the freedom and responsibility to address the entire spectrum of public needs and rights. In its present application, the NEPA process is predisposed against Non-NEPA Activist Citizens and is unacceptable. Correction must be brought to the process in the form of procedural changes requiring full consideration of all human needs and rights and a sensible comparison of benefits and impacts. Action must be taken to adjust the process so that NEPA decisions are based on a fair balance between public comments by NEPA Activists versus the needs and rights of Non-NEPA Activist Citizens. We ask that you listen less to NEPA Activist groups who are successfully manipulating the NEPA system simply due to a process that is overly biased to the participation of NEPA Activists. This un-balanced participation is further magnified by financial backing that provides NEPA Activists with paid advertisements, professional lobbyists, professional managers and a strong network of organizations. Because of these sorts of reasons, Non-NEPA Activist Citizens are disadvantaged and are not fairly accounted for in the NEPA process. We ask that you seek out, listen to, document, and base your decision-making on the needs of all citizens including motorized recreationists and other multiple-use recreationists who do not fully participate in the NEPA process and tend to be Non-NEPA Activist Citizens. The attached table shows our 1999 observations in the field and clearly demonstrates the types and number of recreationists who are out enjoying our national forests. We ask that you recognize and properly address the needs of motorized recreationists as you prepare the document and enact decision-making. In closing, we oppose the creation of new roadless areas. We support all existing motorized recreational opportunities on our public lands and encourage you to develop additional motorized recreational opportunities. Thank you for your consideration of this input. Sincerely,
Ken Salo |