Jerry Ingersoll, Forest Service Supervisor
November 14, 2012
c/o Angie Morris, Recreation Planner
Siuslaw National Forest
855 Highway 101
Reedsport, Oregon 97467
RE: ODNRA Designated Routes project
Dear Mr. Ingersoll,
As you are likely aware I have been involved in OHV activities to
include safety legislation, funding for law enforcement, as well as for the
Forest Service and other agencies. I
have been supportive and have worked at including all stakeholders in an attempt
to bring them together for the benefit of all.
Sadly I am very disappointed that the OHV community’s efforts to work
cooperatively together are nothing more than naïve disillusionment on our
part. Your process could not have made
that more clear.
Let’s go back a few years.
Initially we tried to partner with the Forest Service in getting the
existing trails mapped. We were told the
intent was to map and keep but forbid new trails. Your GPS equipment wouldn’t work at the time
so we used ours – at the FS direction. A
lot of time was spent in mapping all of the areas only to find out from the FS
that you could not use the data.
Ironically I believe you have used this data against us – you have to map
it to close it and close it is clearly what has happened.
Nonetheless, we are the believing public. We chalked it up to a misunderstanding and
moved on. When the committee was formed
we noticed the lack of OHV participants involved and felt it odd that others
would have an equal or greater say to OHV matters. Simply put, why would a mushroom grower (a
commercial grower) have as much or more say on a recreational issue? Consider also their use is part-time, limited
in area, and rarely disturbed by the OHVers.
They use our trails to access their picking areas. This is just one example but there are more….
Looking at the bigger picture one has to wonder about common
sense. We have the FS dictating a plan
when the FS has failed for years to manage the area. We have the FS looking at environmental
impact statements regarding “damage” done by the OHVers when clearly the biggest
threat to the dunes is the many invasive non-native species the FS intentionally
planted years ago and has neglected to control.
By the FS actions and inactions they have become the biggest risk to the
ODNRA and yet we still allow them to remain in control of the area? Ironically OHV activity is one of the best
tools we have available to save the dunes.
Even environmental groups support OHV activity in this area. We are not the problem – mismanagement by the
FS is.
I find the history of the ODNRA just as disturbing. It was initially designed as a recreational
area, because it was not considered at the time to be useful for any other
purpose – including commercial timber.
At some point it was determined non-native and very invasive beach grass
was a great idea. Building a foredune
was included in this master plan with the intent to halt the shifting sands and
protect our roadways and towns. Plant a
little scotch broom and non-native pine and wahlah – we have ourselves another
government idea gone badly. Years pass
and all is considered a success as the dunes are quickly overtaken and
“stabilized”. In the original plan the
intent was to manage and control the invasive species the FS planted. Lack of funding and the fact that the
planners underestimated how difficult and fast spreading the beach grass was, it
rapidly spread to other areas. How many
acres have already been lost by a very poor plan and then a lack to manage it
responsibly?
Now we are protecting the invasive species the FS planted that will
eventually be the death of the dunes and rather than looking at how to fix a
problem they have created they look to one of the only successful tools
available and restrict it further? I
would like to see an environmental impact done on the damages to the ODNRA over
the past hundred years as a result of the FS actions, and inaction. You are clearly barking up the wrong tree on
this one…..
Unless this is a political agenda… and then it all makes
sense. We serve a Green God and there is
a huge push to protect the environment.
Okay, then in this case we are all on the same team, right? If the goal is to save the Dunes then two
things need to happen. The first is to
remove these lands from the FS care.
Clearly the FS has not been able to adequately manage them. Additionally, they are not a viable
commercial forest and have been designated recreation. There is a direct conflict. Return these public lands to the State for
management. Secondly, manage the area to
remove and manage the invasive species that were intentionally planted to
include restoration to the dunes original state before the government agencies
came up with their brilliant plan.
Pretty simple really. What we
shouldn’t do is more of the same with the same agencies because it is clearly
not working.
I am certain my remarks have been expressed a hundred ways a
thousand times or more. It falls on deaf
ears. I am also quite aware if it is not
specific to the plan then it will be discarded.
So let’s hit the specifics with regard to this
plan.
Specifically I firmly believe the FS has intentionally misled the
public using deceptive practices. One
example is with terminology. The OHV
public, as well as the public in general, defines trails as what you refer to as
“user created trails”. Then you define
authorized trails as what we would consider roads. It is referring to a “freeway” as a single
dirt road. Very misleading and I believe
very intentional. I have been riding
with my family since about 2003 in the Northern riding area. We did not participate in OHV activity until
then. I would consider us a very law
abiding family. We follow the
rules. We stayed on the trails and
stayed off of those signed closed. We
have ridden those trails with law enforcement and have never been told they were
off-limits. No tickets were written, no
signs ever went up on those trails. Now
other trails were posted so it would leave the common person to believe if well
used trails didn’t have a sign posted then it was legal to ride there. Many of these trails have also been
maintained – possibly by the FS themselves and are considered to meet Trail
Class 2 standards (Page 140 “Little input was needed because all designated
routes proposed are existing
user-developed routes needing little, if any improvement to meet Trail Class 2
Standards”). Trees fall and yet the
downed trees are cut up and removed from the trail. So for years millions of visitors to these
areas have been riding these trails without event. New trails that are started are quickly
posted closed. The message was – these
are open, these are closed.
BUT – now the FS refers to these trails as illegal user created
trails and identifies only the roadways (that you deceptively call trails) as
the only legal avenue for travel. Then
you post a sign, about a year ago, on one of these roadways that instructs
riders to stay on the trails. Very
deceptive and the timing is suspect.
Basically what it appears you have done is to mislead the public once
again. They are staying on the trails
but what you haven’t said, or enforced, or defined well for the public is that
you meant roads, I mean trails, or you know, user created trails are illegal but
you can stay on the trails that really are roads.. oh, it gets so
confusing. Meanwhile people continue to
ride on the trails as they feel it is legal.
It also makes this process much easier for you. By your definition you are not closing trails
– only user created trails. To the
public it simply means you are closing all of the trails and they can only
legally travel on the roads that you call trails. (page 68 “Currently, the public are not
reasonably aware that travel through MA 10C is permitted on designated routes
only.”) Since
1994?
That brings us to Alternative 1 – this clearly shows the deception
to the public. It says no action will be
taken. It will remain as it is. Many in the public will be ecstatic with this
option BUT it is because no change for them means they can legally continue to
ride on all the trails they have been riding on for years but just can’t create
new ones. For the FS it means they go
back to the 1994 plan that was never implemented or signed and all “trails” will
be closed.
That brings me to my second point.
10-B was open for riding meaning you could ride cross-country, create as
many dang trails around the plantation pine and clumps of invasive grass as
desired. Now that it has grown in with
invasive specie’s we have to protect it and there is an accusation that the
trails were made illegally by the riders?
This makes no sense. The entire
area was open to riding – the mismanagement by the FS to not contain the
invasive species is the issue. You are
taking away an area based on your mismanagement? You are banning OHV use in areas where it is
literally needed? Those trails that you
close – do you expect them to revert to sand or grow over with more invasive
species? It is the free flowing sand
that needs protected. So clearly
Alternative 1 would be the worst option for the OHVers and the
environment.
Converting 10B to 10C – That opens up a huge can of worms for the
FS. To protect the dunes the reverse
would be most beneficial. Open up more
areas for travel not less. (page 129,
etc. “Designating additional routes
would lessen the magnitude of resource impacts on nearby currently
designated routes by distributing OHV use in the riding area.”) Travel keeps the invasive species at
bay. As far as impact from OHV activity
– clearly when you are talking about changing what was open to OHV use to
restricted access because of the flora and fauna you must consider if we were
such a negative impact then these areas wouldn’t have allowed the flora and
fauna to thrive. ( Page 73 – “The effect
of all alternatives on TES botanical species is no impact and further discussion is
not needed”) OHV use has not been enough to keep those areas open – why would
you then exacerbate the problems by banning a “tool”?
With regard to the other options:
Basically all the options are to close and offer no solution to the
actual problem at hand. This is in part
by starting with Alt. 1 suggesting to the public there will be no change when in
fact it is a total trail closure. I can
stress how deceptive this is. When your
starting point is flawed it makes it nearly impossible to take a comprehensive
appraisal of the other alternatives.
This document and its supporting evidence was not made in a way that the
public can understand or reasonably comment.
Most will be discouraged and confused.
Was this intentional misleading or an unintentional act simply due to
your depth and understanding of the topic?
Either way, it is your responsibility to insure it is easy enough for the
public to understand so they can make an informed comment. I do not believe you have
succeeded.
Clearly most in the OHV world will opt for Alternative 5. It appears to give the OHV community
something when it is really simply still taking a massive amount away. It is the only option that allows access to
the lake. As I understand it the FS in
managing this area is instructed to manage for a variety of recreational
uses. This is the only option that will
allow my family to continue to swim, fish (page 113 “The direct and indirect
effects are not measurable….”), boat, and relax by the lake. We spend many hours there at each visit and
swim there year round. Clearly, by the
many remarks received, other families heavily use this area as well. I was disappointed that our remarks seemed to
have been ignored.
Obviously when only given these choices I too would pick
Alternative 5. It is like picking
between bad or worse and I feel that this whole process has been flawed and
misleading from the start. Clearly the
outcome is what I had expected based on the Land issues in other areas. The FS saved the most heavily used for last
so they wouldn’t bring attention to the less used and easier to close
areas. The benefit to the OHV riders at
the ODNRA is the outrage being expressed currently by all outdoor
recreationalists affected by the massive closures of public lands is leading
into legislative and legal changes. I
believe the FS will be temporarily effective in implementing their chosen option
but feel the public will at some point have their fill and we will see a change
to this process and access. Do I feel I
have any course of action – that my comments will make any difference
whatsoever? Clearly no. Likely it is a
waste of time and likely that is what the FS hopes to accomplish. You are required to take public input but
that doesn’t mean you have to consider it.
Sadly I feel there is a solution to the actual threat to the ODNRA
that will never be explored. Without
legal intervention the public will be left out of the process then restricted
from PUBLIC lands. Who then will be held
accountable when the dunes are no more?
I suggest the FS should focus on returning the ODNRA to its pre 1930’s
condition. If OHVs are not a threat and
the FS is then who should really be the one restricted? Do your jobs and clean up the mess you have
created. The OHV community is an asset –
not a liability. We should be treated as
a partner rather than a pest.
Lastly I have one request for a response. The data was not listed and likely not
studied but I feel it is imperative to any decision made. What is the NEPA data for leaving things with
the current use to include all user created trails. There should have been an option for this as
well rather than or in addition to the Alt. 1 where no action would be
taken. If no action would be taken then
you need to take into consideration the continued use without change. This process is incomplete without that
information. It too should be an option
for the public to comment on. I await
your reply and ask that my comment be made a part of the legal record.
Thank you,
Linda Minten
37733 Robinson Dr.
Scio, Oregon 97374
503-394-2180