FROM: COLORADO SNOWMOBILE ASSOCIATION
The new forest plan for the San Juan National Forest significantly impacts your motorized usage & CSA's concerns are:
1. Several important riding areas, such as Molas Pass and the Sharkstooth areas, with long histories of snowmobile usage are identified as currently closed despite on-going usage. This is illegal. If the areas are to be closed these impacts must be analyzed and not just have the area identified as already closed in the plan.
2. The Plan designates an additional 83% of the Forest as unsuitable for summer motorized usage and states that routes in these newly unsuitable areas would not be considered for incorporation into the travel system and would be prioritized for decommissioning. This change incorporates unsuitability standards for all wildlife habitat, despite numerous previous decisions that motorized usage of these areas was permissible, such as the Wolverine, Lynx and Grouse. This sets a dangerous precedent for future winter planning.
3. Suitability area boundaries are designed to reduce user conflicts but at no point does the plan discuss the nature of the conflicts or how closing an additional 83% of the Forest will mitigate these concerns. NVUM analysis clearly identifies current management boundaries are highly effective at providing a quality recreational experience to all users.
4. Economic analysis of recreational spending is facially incorrect and incorrectly asserts conclusions are based on NVUM data, which is simply not accurate at all. NVUM analysis asserts all recreational users spend on average $59 per day, while the SJ/TR plan asserts this is $30 per day. The FEIS spending profiles for particular user groups are even more erroneous, as follows.
Activity SJ/TR conclusions NVUM high spending avg % Diff between NVUM & SJ/TR
Downhill skiing $208.18 $408.00 51%
X-Country skiing $208.18 $361.50 57%
Snowmobile $127.23 $446.75 28%
It is CSA's position that erroneous spending profiles of non-motorized users and multiple users has directly impacted the allocation of these uses on the San Juan to the direct detriment of the motorized community. Spending profiles for users must be corrected and land management decisions must be reallocated based on correct spending analysis.
4. Many blanket statements are incorrectly made about statutory prohibitions to motorized usage, such as WSA. These statements directly conflict with federal laws including §603 of FLPMA and §3(d) of the Wilderness Act and BLM policy for the management of these areas.
5. All roadless areas are determined to be upper tier eligible despite the fact that the Colorado Roadless Rule recently found all these areas ineligible for such a designation. Motorized usage is a characteristic for heightened protection under the Colorado Roadless Rule and has been unilaterally excluded from these areas in the RMP.
6. Separating the Tres Rios BLM plan from the San Juan National Forest Plan at this point will cause significant confusion of users and results in numerous comments being submitted to the wrong agency. No provisions are provided to address this issue.
Link to Website with plan and related documents:
If you originally submitted comment on the draft EIS of the San Juan Forest Plan you are eligible to file an appeal. We encourage you to use any of our talking points above or incorporate what is relevant based on your original comments. The point is if you feel as though the final has not adequately addressed your comments please consider appealing.
On or before December 19, 2013
Who to contact:
A written notice of appeal must be filed in duplicate with the Chief of the Forest Service at:
USDA Forest Service
Attn: Judicial and Administrative Reviews
1601 N. Kent St.
Arlington, VA 22209