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.