Blue Mountains Biodiversity Project Action Alert
Stein’s Pillar, in the middle of the Ochoco National Forest. Image source: Hiking blog
A corporate-supported lobby is pushing for extensive ORV (or OHV, Off-Highway Vehicle) trail systems on the public lands of Ochoco National Forest. The Blue Mountains Biodiversity Project (BMBP) is mobilizing a flood of public comments to the Forest Service on the OHV project, which are due in a week. All the info you’ll need to make an informed comment is available below, from the incredible research of BMBP.
Send email comments post-marked no later than April 15th on the “Ochoco Summit Trail System Project” Draft Environmental Impact Statement to the Ochoco Summit Planning Team, c/o Ranger Slater Turner, via: [email protected]
Image from the Ochoco Trail Riders
You can also fax or mail comments to the Ochoco Summit Planning Team:
Ochoco National Forest
c/o Ranger Slater Turner
3160 NE 3rd St.
(541)416-6695
Prineville, OR 97754
Learn more about the BMBP, which was founded by Earth First!ers over 20 years ago, in a recent article from the Beltane 2012 edition of the Earth First! Journal, written by BMBP director Karen Coulter. The group is a leading model of grassroots biodiversity activism and the successful strategy of “paper-wreching” the industry-driven permitting process. Read on to see a glimpse of how its done…
About the Ochoco Summit Trail System Project
The Ochoco National Forest is planning to construct a trail system for motorized “off-highway” vehicles to replace current uncontrolled off road vehicle use across the forest. While Blue Mountains Biodiversity Project is supportive of ending ecologically damaging cross country off road vehicle use, we are opposed to constructing new long segments of trails making incursions into interior forest habitat, and situating trails near streams, wet meadows, and other fragile areas, and within old growth management areas.
In general, we object to allowing a small but vocal minority of recreationists using noisy, polluting, soil eroding, wildlife-disturbing, and stream-destroying vehicles to outweigh the concerns of quiet recreationists, ecological integrity, fish and aquatic species viability, and native plant and wildlife diversity protection.
The action alternatives that the Forest Service is offering are the following, with No Action (not developing or designating trails for OHVs) being Alternative 1:
Alternative 2, proposed action, would create a 170 mile trail network for off highway vehicles, including areas intended for use by motorcycles, ATVS, jeeps, and 4 wheel drive trucks.
Alternative 3, the Forest Service’s preferred action, would create a 101 mile trail network, including areas intended for use by ATVs and motorcycles, but not for jeeps and 4 wheel drive trucks.
Alternative 4 would create a 212 mile trail network, providing areas for all the types of off highway vehicles.
Here are some of the concerns expressed by the public about this trail project to the Forest Service which we share:
*Potential impacts to wildlife, fish, streams, sensitive habitats, and the introduction or dispersal of more exotic invasive plants by off highway vehicles
*Disruption of non-motorized forest experience, potential noise level increase
*New trail system causing increased off highway vehicle use on the forest; shifting from low profile, local, and low density use to high profile, destination, or high density use
*User conflicts associated with motorized versus non-motorized recreation
*The economic sustainability of the road and trail system
*Monitoring, maintenance, and enforcement of appropriate use
As usual, the devil is in the details. Below are some of our more site-specific and planned action-specific concerns:
Regarding the Draft Environmental Impact Statement Summary of the project Proposed Action alt. 2:
Closed and decommissioned roads now proposed for conversion to OHV trails were generally closed or decommissioned for good reasons, such as reducing disturbance to wildlife, eliminating hydrological connections of roads to streams, stopping impacts to streams such as sedimentation, preventing invasive plant dispersal, etc.—and should remain closed or decommissioned. We are opposed to any new trail construction except for very short segments connecting open system roads.
Administrative closed roads were also often closed to increase wildlife security from hunting, stop illegal firewood cutting of snags, and other good reasons mentioned above. What would be the impacts to elk, lynx, Gray wolves, and other disturbance-sensitive wildlife of the proposed re-opening of closed and decommissioned roads and the building of new trails for motorized vehicles into the interior of the forest off the existing road system?
We are concerned that, based on the experience of other Forests creating such OHV trail networks, if you create and publicize such a trail network, many more OHV users will come—from all over, greatly increasing impacts to streams, soils, wildlife, and quiet recreation.
We are opposed to the entire Class II vehicle (jeep, small truck, and “dune buggy”) proposed trail network as too destructive and unnecessary overkill. Such trails would be larger, potential damage greater, and require additional trailheads and staging areas compared to a Class 1 (ATV) and Class 2 (motorcycle) trail system. A Class II trail network would also necessitate a lot more construction, maintenance, monitoring, and enforcement costs. Class II vehicles already have more than enough roads to explore. We should not invite even more extreme damage such as rock crawlers leaving the trails to go over streambeds and up fragile drainages.
Any OHV staging areas should be confined to existing large areas of disturbance such as gravel pits. We are concerned by all the new developments proposed for places like “Peterson Lava”, “Road 600 Staging Area”, and “Ross/Person ridge”, such as toilets, defined camp sites, picnic tables, sign boards, Haz-mat supply, etc. Who is going to pay for all the new amenities purchase, installment, maintenance, repair, and replacement? Why do motorized recreationists get all this special attention when hiker trails are not maintained and natural values such as forest and stream integrity and wildlife and plant diversity are already not protected adequately? We are wary that this project is being driven in part by offered funding to the Forest Service by the huge off road vehicle recreation lobby groups and associated industry corporations poised to profit from such OHV trail system expansions.
Alteration of trailhead and dispersed camp sites should be limited, not continually expanded to accommodate increasing OHV traffic. We are greatly concerned by the industrialization and increasing privatization of our public lands. We are opposed to any use of private concessions to provide services to OHV users or to regulate and maintain their staging areas, camp sites, trail systems, and trail heads.
Keep all OHVs out of the Old Growth Management Areas! There are very few places on the forest that are even theoretically devoted to wildlife protection. Increased motorized use of these areas—especially by louder vehicles—could drive wild life out of the OGMAs into less suitable habitat, threatening the viability of disturbance-sensitive species, which include Pileated woodpeckers, lynx, Northern goshawks, wolverines, elk, Pacific fisher, and potentially many other species, such as Pronghorns, marten, and Neotropical migratory songbirds—a variety of federally and state listed species and Management Indicator species. We are opposed to any new OHV crossings through Old Growth Management Areas, including but not limited to creek crossings (Looney Creek), crossing near a spring (Chamberlin Spring), and crossing on closed roads.
We are opposed to management through Forest Plan amendments. We consider project- and site- specific amendments to the Forest Plan to be a misuse of the Forest Plan amendment process and a violation of the National Forest Management Act and the Forest Plan. The repeated and cumulative use of project-specific Forest Plan amendments in project after project across eastern Oregon National Forests effectively moots the standards and guidelines and the intent of the existing Forest Plans.
As for the Forest Plan objective to provide for OHV use and for associated trail construction and reconstruction being allowed where they are not in conflict with other resource objectives, the existing Forest Plan is very out date, created well before the boom in ATV use, which has, in fact, come into conflict with many other uses of the forests (“resource objectives”), including primitive recreation (the vast majority of recreational use), water quality, aquatic objectives, Riparian Habitat Conservation Area Riparian Management Objectives, soil integrity, wildlife security, etc. and causes noise pollution, air pollution, and increased CO2 emissions that exacerbate climate change.
We are in favor of rehabilitating and closing off existing OHV user-created trails; why is this needed restoration not included in any of the action alternatives to stop ongoing sedimentation of streams, rehabilitate eroded slopes, block access routes for invasive plant dispersal and stop illegal OHV cross country travel? Who is going to enforce vehicle and route restrictions, how, and with what funding?
Any designated trail system needs to be kept small to limit ecological damage and allow for adequate maintenance, rehabilitation, and enforcement. There is already an excessive mileage of open roads, far more than the Forest Service can maintain or than is desirable on the landscape. Off road vehicle use does not justify reversing sound decisions to close and decommission unnecessary and ecologically damaging roads.
Regarding preferred Alternative 3: While we consider alternative 3 a worst case scenario (alt.s 2 & 4 are completely unacceptable), alternative 3 includes changes from alt. 2 & 4 that are worth preserving: It’s more ecologically protective to only have motorized routes open June 1st through September 30th, avoiding at least the most vulnerable part of the Spring reproductive season, although ideally access would not be allowed until late June or July, since significant rutting could still happen on higher elevation and moister areas in early to mid- June. Early Spring and fall elevated moisture levels would lead to more soil and riparian area damage. Most recreationists don’t come out earlier any way; many areas are not accessible earlier, and after September, rifle season shooting user conflicts and hunting security conflicts for elk and deer arise.
Alternative 3 would still provide more than enough OHV trails and could be trimmed down further to eliminate new interior forest trail construction (especially all long segments), stream and Old Growth Forest Management area crossings, and trail proximity to elk calving, goshawk habitat, wet meadows, springs, and ponds. Alternative 3 can be seen as a starting point to designating an already open road system for OHV usage that would be greatly scaled down from the other alternatives, reducing wildlife disturbance, recreational conflicts, riparian impacts, and installation,
maintenance, restoration, and enforcement costs. Such a scaled-down, open system road-focused plan would also discourage OHV use from being attracted from distant communities and increasing exponentially to the detriment of the great natural values and opportunities for solitude and quiet that the Ochoco offers. Eliminating Class II trails also reduces the risk of a large escalation of OHV use on the Forest.
We support the eastern route only being made available to Class III vehicles (although we still want it pared down), as motorcycles at least use smaller trails. We support alt. 3 separating the ATV and motorcycle use areas with an area without designated OHV trails. We support the alt. 3 elimination of alt. 2 proposed trailheads and non-gravel pit or snow park staging areas. Any staging areas for OHVs should already be disturbed areas, as much as possible already set up for recreational use.
Alternative 4 would result in unacceptable heavy dominance of the entire area by motorized vehicle use and very high costs in wildlife security, primitive or quiet recreation opportunities, riparian impacts, and installation, maintenance, restoration, and enforcement.
Riparian Habitat Conservation Areas and stream systems can’t take much more damage on the Ochoco National Forest. They are already heavily impacted by historic, recent, and ongoing livestock grazing and logging. If there are to be any stream crossings for OHV routes (which should be avoided), they need to be over bridges and culverts with fencing or other barriers to prevent cross country entry into streams and riparian zones. There should be no OHV entry into wet meadows or near ponds, seeps, and springs.
The Forest Service should retain and exercise authority to prevent OHV trail use when the wet season for sensitive areas that could be accessed extends after the opening of the OHV use season (ideally later than June) or before the end of the OHV use season (before September 30th at the latest) or to prevent impacts under other adverse conditions (eg. soon after wild fire.)
Regarding monitoring, it’s better to prevent impacts rather than monitor the demise of ecological integrity and biological diversity. It’s also more cost effective to initially prevent impacts rather than to do restoration later. This is why we favor only a small trail network on existing open roads that is the least expensive, involves the least riparian areas, avoids Old Growth Management Areas, and stays closest to existing traffic and disturbance areas, involving very little and only short new trail construction if any, and no use of decommissioned roads or closed roads not maintained for administrative use. Then the proposed monitoring and mitigation measures (which we support) are more likely to result in acceptable conditions, reasonable levels of expense, more likely enforcement effectiveness, and an end to OHV
cross country use and user-created trails. Minimum annual reporting should include: type of ecological impacts and violations found, location and extent of violations and impacts, and what measures will be taken to correct these violations, prevent future such impacts, and rehabilitate or restore damaged areas.
It’s important to recognize that many OHV trails and “play areas” already exist in central Oregon, including about 700 miles of designated OHV trails, including “play areas” located less than 50 miles from Prineville—i.e. all viable alternatives for OHV recreationists to any new trail system on the Ochoco.
There’s an inadequate range of action alternatives for this project as all of them apparently would violate the Forest Plan, the Travel Management Plan, and the Deep Creek Restoration Plan, and all would fail to reduce already excessive road density , adequately avoid impacts in RHCAs, avoid stream crossings and sediment delivery to streams, and impacts to wet meadows, seeps, springs, and hydrologic flows. There is notably no “restoration only” alternative that would cause no increased damage or fully rehabilitate areas suffering from cross country OHV damage.
We are deeply concerned by the dire devastated condition of most of the streams and creeks documented in the DEIS discussion on pages 187-194 and by the high potential for further riparian area decline and impacts to Redband trout and Columbia spotted frogs in particular from action alternative trail crossings of riparian areas and streams combined with livestock grazing, existing roads, mining, herbicide use, logging, and unrehabilitated OHV cross country travel damage.
We ask for the following areas to be completely avoided by any OHV trail system: roadless areas, potential Wilderness areas, Riparian Habitat Conservation Areas, Wild and Scenic River corridors, Old Growth Management Areas, existing restoration project areas, elk calving areas, Northern goshawk nesting and post-fledging areas, populations of rare or federally or state listed native plants, existing invasive plant infestations, Native cultural sites, Lookout Mountain and other popular hiking or quiet recreation areas, and critical or core nesting, foraging, and dispersal habitat for all Threatened, Endangered, and Sensitive-listed species and Management Indicator species.
BMPP is also proposing comments on the “McKay Fuels and Vegetation Management Project” Timber Sale in the Ochoco National Forest which are Due by April 29th.
