Monday, December 3, 2012


Subject: RE: Oregon Dunes NRA Management Area 10c Designated Routes Project

Dear Mr. Ingersoll,

The five alternatives presented by the Forest Service in their DEIS dated 10/2012 are unacceptable. The Forest Service needs to start from scratch to develop new alternatives that will provide maintenance of the OHV trail-riding experience. The value of the trail riding experience is not found by wide connecting roads (i.e. whoop roads). The preferred alternative (4) closes 62% of trails (84 miles closed out of 135 miles) --- unacceptable.
I am a member of Washington ATV Association and find the closures proposed in this document to directly negatively affect our membership and usage of the dunes. In the 1972 Act that created the Oregon Dunes National Recreation Area (ODNRA) we had 28,900 acres of mostly wide open sand to ride on.
In 1979 that area was reduced to roughly 14,000 acres for mixed use. We had no problem with that. It was big enough for all.
In 1994 this was split up, 4,455 acres was basically closed and what is in contention today, 18 years later. This acreage is called 10C which is “trails only” that is by their definition closed. We are authorized to ride on 5,930 acres or 21% of the original 28,900 acres.
In the 1972 Act; one of the main points was to establish an Advisory Council in order to receive public input for management of the ODNRA. This is law. They decided they did not need it.
After misguided management, over 80% of the then open sand of the ODNRA is now nonnative vegetation the USFS planted. We all see it but most of it is hidden because it is in the area that we do not ride in. Their main focus, energy and money should be concentrated in managing this tsunami of invasive beach grass. Restoration should be their only thought, not OHV closures. OHV is the ONLY defense against this nonnative vegetation. On top of that we pay them to kill the grass. Even the Greenes agree with us on this point. They say that our impact is minimal so should not be considered. We say why would you want to stop anything that will help kill the grass? Restoration; Restoration; Restoration!
In the Draft Environmental Impact Statement (DEIS) they say that the economic impact cannot be measured so it will not be considered. COOS, DOUGLAS and LANE COUNTIES depend on the ODNRA and economics do matter. They use some pretty fuzzy math. In less than 50 years there will be no open sand. Nobody will come to the ONDRA, hikers or OHV if the USFS continues to focus on OHV closures not Restoration.
The proposed actions are detrimental to the health of the sports and economy on the Oregon coast that rely on these areas, not to mention the safety and enjoyment of the clubs, people, and families that currently use the dunes for recreation. The trails in question have been around for decades, and while the 10c management plan calls for "controlled opportunities" for OHV use, the plan did not accommodate the growth of the various OHV users of the ODNRA. The Forest Service needs to start over in their assessment to develop new alternatives to provide reasonable solutions that will accommodate the user experience and protect the wetlands and vegetation, which may include opening more "open areas" to OHV use, or formulating a plan for the creation and maintenance of a designated trail system.
Respectfully
Eric