March 24, 2015
United States Department of Agriculture Forest Service-Tahoe National Forest 631 Coyote Street Nevada City, California 95959-2250 Attn: Mr. Tom Quinn Forest Supervisor
The Sierra County Board of Supervisors on March 17, 2015 authorized and strongly endorsed this letter providing comments on the “proposed action” for designation of over-snow vehicle use (OSV) as part of Subpart C of the Forest Service Travel Management Rule as it affects Tahoe National Forest.
Transcending all of the County’s comments on the proposed action is recognition of the OSV winter snow grooming program funded by the State of California and implemented through a unique and successful partnership between the State Department of Parks C!Jld Recreation, US Forest Service, County of Sierra, volunteer user groups such as the Sierra Buttes Snowbusters, private contractors, landowners, and many recreation interest that enjoy the winter opportunities afforded in the Tahoe National Forest. This program is a major part of the economic engine that supports the existence of the communities within the County and its continued operation is critical to the County and to the region. Sierra County is the implementing and contracting party for these annual grant funds and the measured success of the program in providing opportunities for the recreating public, its respect for the resources in existence on public and private lands, and its importance to the economic viability of the region must have strong support in the selection of any proposed action.
Additionally, the County provides the following comments for your review and consideration in selecting any action or implementing any program related to OSV use and management:
1) Sierra County strongly supports a “status quo” alternative in that existing programs, existing management and oversight, and current use of the National Forest through OSV opportunities should continue without further additional regulatory influence. Multiple use should remain unchanged and the current opportunities afforded to the recreating public should not be altered. The support for ”status quo” is viable and strong and there is no basis for considering a reduced scope of program under the National Forest’s proposed travel management plan for OSV use.
2). The Pacific Crest Trail (PCT) exists throughout Sierra County, particularly in areas where OSV use is predominant during winter months. Typical winters provide a snow condition that is optimal for OSV use yet the alignment and location of the PCT is not discernable under several feet of snow. The County supports designating specific locations where structured/vehicular OSV grooming may occur upon trails/roads that require crossing of the PCT but there should be no attempt to regulate and direct open-country OSV users to cross the PCT at designated locations. The County opposes any effort to direct individual and open-country users to cross at designated locations. Any proposal to designate a “corridor” where OSV use is prohibited will be catastrophic to the County’s OSV program and essentially exclude miles and miles of prime recreational area from access by the public during winter months. The 1982 comprehensive plan for the PCT and the interpretations of the management direction should clearly allow open use of lands containing the PCT during winter months. The Lakes Basin is one of many examples where interpretations that restrict crossing or open-country OSV use will all but eliminate these lands from use by the winter recreating public. It makes no sense, is not supported in fact, and is virtually unenforceable. The County will strongly oppose any effort to implement further restrictions along the PCT impacting winter OSV use.
3) A more coordinated process and decision making mechanisms must be created to evaluate the method used to determine whether or not to commence grooming operations on a given day. The current restriction to 6 inches of snow depth at a trailhead and 12 inches in the open country to be in place before grooming is authorized fails to consider location of trailhead and its elevation, temperature, snow consistency, weather forecasts, conditions at higher elevations, season of the year and other factors that can contribute to this decision. This formula must contain discretion, flexibility, and be supported by reasonable standards that will continue to afford necessary protections to public and private lands yet not unduly restrict OSV grooming and use. Sierra County would desire to be part of this decision making formula but regardless of the County’s involvement, a better process for making this decision needs to be in place.
4) The proposed action and the EIS to follow needs to provide a much stronger analysis of the positive economic and social impacts and the value of the OSV program to the economic vitality of the region during:winter months. The interaction and positive impacts occurring at Bassetts Station, Yuba Pass, and Little Truckee Summit all point to increased economic and social interaction locally and regionally and any analysis of this should be a critical chapter in the proposed plan and EIS.
5) The existing parking area at Little Truckee Summit generates issues for traffic and management and a project to expand the parking area to manage the existing use should be strongly encouraged. This improvement would not be designed or proposed as a measure to induce further use but rather managing the current use. The safety issues along State Route 89 at the existing trailhead and the liabilities that accrue are sufficient to warrant the execution of such an expanded project at this site.
6) Further OSV prohibitions and putting forth an alternative that overly restricts OSV use is not supported by the County. Expanded efforts should be implemented by the Forest Service and the County to provided enhanced public outreach and education on the proper operation of OSV use and standards to avoid environmental impacts and measures to assure operator safety. Expanded efforts to reach the public OSV recreational user and a concurrent level of consistent enforcement will assure all parties, including private landowners in the checkerboard pattern of land ownership in the region, that measures have been taken to afford a maximum level of protection without the need for increased regulation, prohibition, and other undesirable methods of management.
Thank you for the opportunity to comment and the Board of Supervisors would ask that the receipt of this letter be acknowledged by the Forest Supervisor and that assurances are given to coordinate with and involve this Board in all future actions pertaining to OSV use on the Tahoe National Forest.
Sincerely, Sierra County Board of Supervisors, James Beard Chairman
CC: Members of the Board, Ranger Youngblood, Ranger Hayden, Ranger Roubique, Sierra Buttes Snowbusters C/0 Mr. Bob Latta, Representative Doug La Malfa