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

After taking a look at the final 1994 and dissecting the 2012 DEIS plan, we have come to the conclusion that the Forest Service is NOT overseeing the entire ODNRA properly and is leading our beautiful national treasure into extinction.

 

Looking from the outside in, there is not much difference between the 2 documents, just the dates. The main issue of non-native vegetation still has not been addressed.  What is the plan to control and/or remove non-native?  We would not be having such issues if the Forest Service had not originally planted the Shore Pines or the very invasive European Beach Grass. The spider web trail system (our beloved trails) that are destined for closure would not exist as you have seen over time from previous photos.  Most of the spider web trails go thru what the Forest Botanist mentioned on page 70 of the DEIS document “shore pines planted on previously unstabilzed sand which has grown into forest that has little of the plant diversity that you would expect in a natural woodland”.  Since 1972 when the Government recognized the dunes as an Oregon Dunes National Recreation Area, the dunes have been dying a slow death and you, the Forest Service, have done NOTHING to stop it and, if anything, have accelerated the problem.

In the DEIS, we have seen nowhere near what the economic impacts to the countries (Lane, Douglas & Coos) would be.  Did you consult with all 3 counties?  If so, we would like to see the document you sent to the counties and what their response was.  In the DEIS the FS said that there was little economic impact. We would like to know who or where you got your information from.  We have tried to search out your resources to no avail but I did find this on the working group’s final draft page 80.  “As discussed in the “Recreation Capacity” issue narrative, OHV use levels in the south coast region and on the ODNRA have increased steadily over the years. There have been a number of studies and analyses of the contributions to local economies that this use represents. In 1999, OSU published results of the Oregon Off-Highway Vehicle User Survey, undertaken to provide a reliable estimate of the economic impact of motorized recreation in Oregon. In estimating economic impacts, the study identified the jobs and income that are the result of OHV recreation and assessed the revenues generated from motorized recreation in the state.”

In your DEIS report on page 137,”traffic counts of vehicles entering the primary access corridors into the ODNRA indicate that recreation use and visitation to the ODNRA has remained essentially flat for the past decade.”  The working group’s document and the DEIS were both prepared by you with two different economic impacts?  On the same page, “A 2011 Forest Service economic analysis concludes that OHV use at the ODNRA contributes about 2.5 million annually to the three counties within which the ODNRA is located (Coos, Douglas and Lane).  It accounts for about 82 jobs within the three-county area”.  Seriously, a handful on larger ATV shops will contribute that 2.5 million annually to the ODNRA just by themselves.

This document is heavily flawed beyond usability by cantering towards your bookend only which does not meet the OHV community’s interest what-so-ever.  It needs to be discarded and revisited with more RESPECT to the taxpayer’s bookend with data and science that is current and CORRECT.  This is why we feel this DEIS booklet is simply the first card dealt into the poker game…..certainly not the last one.

Lance and Barbara Rowland

                                                                                          Heidi Murphy 
                                                                                          3621 NW 131^st St.
                                                                                          Vancouver, WA. 98685

Mr. Jerry Ingersoll, Forest Supervisor and Ms. Angie Morris, Recreation Planner
855 Highway 101
Reedsport, OR.  97467    

November 5, 2012

      I am commenting on the Draft Environmental Impact Statement, Oregon Dunes NRA Management Area 10 C Designated Routes Project document released on 10/26/12.  I work within government and produce reports based on fact and data.  I understand the great amount of time that goes into writing the report, analyzing the data, and vetting it amongst all stakeholders and those within the agency.  However, I have noted multiple discrepancies and conclusions based on either incorrect or no data at all, which I will describe. NEPA policy requires agency decision makers to make informed decisions [1502.24 Methodology and Scientific Accuracy].  It states that agencies shall insure the professional integrity, including scientific integrity, of the discussions and analyses in environmental impact statements.  I have also found multiple instances in which the Forest Service is not following NEPA policy, which I will detail.  These, in combination, lead me to distrust the validity of this entire document.  I am asking the Forest Service to rewrite this plan, considering the relevant data, and redo their “Oregon Dunes NRA Management Area 10 C Designated Routes Project” document.  I advocate for a plan which calls for the restoration of the dunes, to include areas that are currently designated as 10 C to be reallocated as 10 B.  In the Forest Service document, “Off Highway Vehicle (OHV) Designated Routes Working Group Oregon Dunes National Recreation Area” dated October, 2010, Siuslaw National Forest, the Forest Service states, “It appears that there are areas where eliminating non-native vegetation such as European beach grass and restoring historically open sand areas would be a reasonable management objective” (page 71).  Let’s proceed on this path stated by the Forest Service, of dunes restoration.  Both OHV riders AND the environmentalists are already aligned on this goal.

      The Forest Service must follow NEPA (National Environmental Policy Act)/Council on Environmental Quality (CEQ) policy.  I will further describe how the Forest Service has failed to follow this policy:

      ·   Alternative 1 (page iii of the DEIS) states, “No Action; no additional routes designated and enforcing all user-developed routes as closed.” 

      A no –action alternative is required by CEQ (40 CFR 1502.14(d).  This alternative forms the basis of comparison between meeting the project needs and not meeting the project needs.  This alternative provides baseline information for understanding changes associated with the action alternatives. 

      However, we are not presented with a no-action alternative in the DEIS dated 10/2012.  A no-action alternative would entail no closures.  The Forest Service is aware of how to write a no-action alternative.  This is evidenced in their Record of Decision, Oregon Dunes National Recreation Area Management Plan Final Environmental Impact Statement, written by the USDA Forest Service, dated 7/12/1994.  In this document on page 21, Alternative C, provides a “no action” alternative that states, “Alternative C would continue management under the existing NRA management plan. It is the "no action" alternative. Management would continue to focus primarily on recreation resources with approximately a 50/50 mix in ORV and non-motorized opportunities”...

      The DEIS provides no baseline information for understanding the changes associated with the action alternatives.

      ·   Economics and safety are removed from scope per page 12 of the DEIS document dated 10/2012.  The DEIS states that “of the eight issues, six were believed to be directly related to the decision to be made and measurable among the various alternatives, such that differences between the alternatives for that issue could be readily and clearly displayed.”  The two issues that were removed from scope include economics and safety.  Comments from the public cannot be removed as “out of scope” on these topics and reasons are as follows:

            Congress used the phrase “human environment” in NEPA, so when an EIS is prepared and economic or social and natural or physical environmental effects are interrelated, the EIS should discuss all of these effects per 1508.8 [40 C.F.R. 1508.8]  The DEIS clearly does not discuss effects of safety nor economics, while NEPA mandates that they do.  “The agency has the responsibility to make an informed judgment, and to estimate future impacts on that basis, especially if trends are ascertainable or potential purchasers have made themselves known. The agency cannot ignore these uncertain, but probable, effects of its decisions.”

            Economics: on page 15 of the DEIS, it states, “The alternatives being considered in this action only indirectly affect local economies, primarily through their effects on ODNRA visitation.”

            According to the report entitled, The Economic Impacts of Off-Highway Vehicle (OHV) Recreation in Oregon, Main Report, prepared by Oregon State University, Sept. 4, 2009, 81.4 million is spent on OHV trip expenditures on the South Coast, rather than the 2.5 million the DEIS states.  OHV trip expenditures account for 829 jobs within the three-county area rather than the 82 jobs reported in the DEIS.  This is quite a staggering difference and something that I’m quite certain the three counties would want and required to be informed about (as noted that they were informed on page 144 of the DEIS).  These counties now need to be informed with the correct information.  The Forest Service is quite aware of this research.  The document is cited on page 97 of the “Off Highway Vehicle (OHV) Designated Routes Working Group Oregon Dunes National Recreation Area” dated October, 2010, Siuslaw National Forest document, however, not cited within the DEIS.  In a personal conversation with the OSU Library on 11/5/2012 with Victoria Heiduschke, Learning Commons Coordinator, The Valley Library,  I found that OSU has conducted no further economic studies with a later date than Sept. 4, 2009 nor had any other entities, which makes it clear that no newer data was used, and that the data is cited incorrectly as to appear as less of an economic impact to the three counties.

            Safety: on page 14 of the DEIS, it states, “Currently, there is no accurate, reliable way of tracking injuries to OHV riders within the riding areas at the ODNRA.”  In fact, the Oregon Health Authority (OHA), Injury Prevention and Epidemiology Program does just that.  In my professional capacity as a Research Analyst with the OHA Injury Prevention and Epidemiology Program, I presented at the Oregon ATV Law Enforcement Conference held in Redmond, OR during April of this year on ATV safety data for the Oregon Dunes.  The ODNRA is within the sentinel area (Coos Bay, Winchester Bay, Florence, and Sand Lake) and data does, in fact, exist.  Instances of both injuries and deaths are submitted to the OHA by local law enforcement within each jurisdiction among other data collection methods.  So, in fact, there is a baseline to consider the alternatives against.  The DEIS further states that “Past history at the Dunes seems to indicate that even in popular, most congested areas of the ODNRA vehicle on vehicle accidents are rare and most rider injuries occur in lower density areas, due to people operating machines beyond their skill/competency level, and not from crashing into one another.”  This is obviously not based on data, since it was stated that “no data exist.”  The DEIS further states on page 14 that “Rider density can be a partial detriment to rider safety…”  According to the Oregon Dunes National Recreation Area Visitor Survey, Robert Burns, March 2008, the majority of 2006 visitors felt that the number of people they saw (crowding acceptability) was unacceptable, 75% of those surveyed.  With preferred alternative four, 84 miles of riding area would be closed.  Page 67 of the DEIS states that 46% of the dunes are open to motorized use.  However, upon review of the breakout on page 8 of the DEIS, it illustrates that actually only 40% of the dunes are open to motorized use as follows: 10(B) Off-road vehicle open 21% 5,930 acres, 10 (C) ORV on designated routes 15% 4,455 acres, and 10 (D) Developed Corridors 4% 1,050 acres.  The sum of these three is actually only 40% of dunes open to motorized use rather that the 46% stated on page 67.  Concentrating riders into a smaller area within this acreage only adds to the problem of crowding.

            ·   NEPA does not mandate closure.  All alternatives proposed within the DEIS mandate some level of closure.

            ·  The Forest Service did not follow the working group’s recommendations when stating the “preferred alternative” within the DEIS.  The working group’s recommendations were most closely aligned with Alternative 5 in the DEIS.  In the Forest Service document, “Off Highway Vehicle (OHV) Designated Routes Working Group Oregon Dunes National Recreation Area” dated October, 2010, Siuslaw National Forest, the Forest Service states, “It appears that there are areas where eliminating non-native vegetation such as European beach grass and restoring historically open sand areas would be a reasonable management objective” (page 71).  Other key issues discussed by the working group included favoring plans that called for “Dispersing use in this area would enhance rider safety” (page 42).

      

            ·   The Forest Service does not use their own data when referring to the “Trail riding experience.”  On page iii of the DEIS it is stated that “Open sand, largely unrestricted riding, had been and remains the primary draw for OHV recreationists to the Oregon Dunes ODNRA.”

      Trail riding is only marginally lower than open dune riding (open dunes riding preferred by 36.4 % of respondents, trail riding, 31.8%).   This is data directly from the Forest Service, “Oregon Dunes National Recreation Area Visitor Survey”, Robert Burns, March, 2008, page 43.  Again, the Forest Service clearly knows about this data.  It is referenced in the “Off Highway Vehicle (OHV) Designated Routes Working Group Oregon Dunes National Recreation Area” dated October, 2010, Siuslaw National Forest, yet not cited in the DEIS.

      ·   Federal law, R.S. 2477, passed by Congress in 1866 states that any travel route (Prescriptive Easement Roads) that was in use before the federal government took an action that changed how the land along that route is managed—must remain open to public use, to ensure the public has access to roads that predate the creation of the Forest Service in 1905.  They could be deemed, by a vote of the commissioners, as public rights-of-way under R.S. 2477.  See definition of “Prescriptive Easement Roads” below.

6.Prescriptive Easement Roads.

These roads created are created by public use over time without the permission of the landowner. No deed or easement document signed by the landowner would exist on the county records.

      So, in conclusion, thank you for your time and efforts in preparing the DEIS.  However, due to the reasons I have outlined in detail above, the DEIS is not a trustworthy document.  I request that the document be re-written and that the overall goal shall be dunes restoration, by way of reallocating 10 C land to 10 B.

Best Regards,

Heidi Murphy

A Line in the Sand

360-901-8489

      The ODNRA is a very special place. We all agree. Each one of us has a different perspective on how to manage this special place. We do all agree that the dunes as we know them are being destroyed by man planted European beach grass, scotch broom and shore pine; all non-native vegetation.

      The 1994 plan is flawed for so many reasons. The single biggest is the fact that the USFS is not looking holistically at the ONDRA. They only look at 4,455 acres vs. the entire 28,900 acres. The second is the funding they had or perceived to have to restore some of the open sand was either used somewhere else or never there. Their “do nothing and close to OHV” policy is wrong. Even the environmental groups feel the same way about their do nothing policies. Please start managing the 28,990 acres and quit closing the only economically viable way to kill the grass.

      Either way, we are entering the final phase of the 10C process, for me we are simply asking the wrong questions. Questions raised by the 1994 Plan that continue to kill the open sand of the ODNRA, its beauty for all, and its economic viability. Will anybody come to this area if there were no dunes??? We do not believe so. That includes ALL visitors to this area. They will simply drive through without stopping. All the research, maps, pictures and boots on the ground agree that the open sand is quickly disappearing. The true question that needs to be asked is how we save the 28,900 acres we call the ODNRA from certain and quickly looming destruction. We are all losing and are either too stupid or unwilling to do anything about it. It reminds me of Winston Churchill’s battle with the British public about entering another war with Germany. We either do it now at a whole lot less cost or wait until it is too late and the cost is unbearable. Even now for some of the ONDRA it is too late. Let’s not make the rest die before we do something. Does the Forest Service not see this? Does the Forest Service know how to manage open sand? They seem to want to manage it the way they manage forest. Way different management techniques and if that is the case then the state or the counties should manage it. This is our home. Our love for the dunes and for many our jobs depend on keeping the ODNRA open sand dunes, not forest. We do not want to be harsh on the Forest Service or go into the blame game but we must start asking the right questions. I know their heart is in the right place but it is time to get out of the box of policy, procedures and bias and move in the direction and focus of restoration, not closure.

      We need to redraw the line in the sand. The book-ends of the Alternatives are too close all the 4,455 10C acres (Alt 1) or open up some of it based on most of the recommendations of the 2009 Work Group (Alt 5). We need to redraw that line. The first book end needs to starts with Alt 5 and end with open up all the 10C to 10B and get away from the silliness of closure to areas that are clearly non-native vegetation. Even on page 53 of the DEIS the Forest Service admits that all the 10C is non-native vegetation. Of all the confusing language of the document this ‘High” rating of ‘Risk of introducing or spreading invasive species via the reallocation from MA 10C to MA 10B stands out as the most telling argument of the whole document. They are saying that they need to close 10C so we cannot ride in it because when we leave 10C the non-native vegetation there will attached to our tires and we will introduce non-native vegetation to 10B open sand thereby killing the open sand. We get confused just explaining it. One needs only to look at the maps and the pictures to know that the non-native vegetation spreads much faster in areas of the ONDRA that has been closed to OHV. My God, this is so obvious that even a child can see it. OHV is not the problem, non-native vegetation is. Again; OHV is the only economically viable killer of non-native vegetation. OHV will even pay to kill the non-native vegetation. Anything to stop the destruction of open sand should be the NUMBER ONE PRIORITY of managing the ONDRA.

      Please stop the destruction of our ODNRA. Please, let’s all get together and rewrite the management to focus on Restoration, not closure.