Center for Biological Diversity * Center for
Central Sierra Environmental
Planning and Conservation League
Public Employees for Environmental Responsibility * Sequoia ForestKeeper
Sierra Club * The Wilderness Society
The above groups strongly support the U.S.D.A. Forest Service Region 5 (
The Forest Service must ensure that all interested stakeholders are given the opportunity to participate in the route designation process. Given that this process will not designate wilderness areas or hiking or equestrian trails, there must be safeguards in the process to ensure that the recreation rights of hikers, equestrians, birders, botanists, and other “quiet recreationists” are not usurped through this process. Designation of routes at this time should be minimal, both to ensure the full and timely analysis of routes to be designated and to provide other forest users equal opportunity to claim their own recreational rights. We are very concerned that allowing interim use on non-system inventoried routes lends legitimacy to unauthorized, user-created routes.
The Route Designation Guidebook produced by the Regional Office defines a well-thought out process for forests to follow as well as criteria for designating OHV routes. We believe all forests should be required to follow these guidelines. However, it should not be considered as the sole criterion for designation. Listed below are criteria that we believe must be included in every forest route designation process.
1) OHV Route Designation should be directly tied to a forest’s ability to sustain, manage and afford an OHV system, specifically including enforcement ability. Provision must be made for regularly monitoring illegal OHV activity and linking monitoring to corrective action. OHV route designation alternatives should include Adaptive Management provisions that link illegal activity to reduced opportunity. This may help create the peer pressure needed to end illegal use and continued creation of unauthorized routes.
2) Incursions into sensitive lands may require the designation of non-motorized areas surrounding the sensitive lands to minimize the potential for illegal entry.
3) OHV Route Designation must comply with Executive Orders 11644 and 11989, including ensuring that impacts to wildlife, vegetation, soils, residents and other recreationists are minimized. The term minimize has been much misused by the Forest Service; indeed, the Forest Service Handbook suggests “minimal restriction” on OHVs, only to the extent of protecting other resources. This language and direction is contrary to the intent of the EOs; it is the effects of OHVs on other resources that must be minimized.
To this end, the Forest Service should, at the front end of this project, identify those resources and other uses of the
4) Consistent with and using the Guidebook criteria, each route must be fully evaluated by appropriate, qualified members of an interdisciplinary team. Recreation technicians should not be charged with evaluating the impacts of dirt bikes on wildlife. Nor should a deer biologist evaluate impacts to amphibians. Evaluation should be truly interdisciplinary, with team members sitting down in the same room, at the same time, to discuss their respective issues with specific routes. There should be an “evaluation sheet” that shows who and when determined the rating for each route.
5) Due to the sheer number of roads and trails, each
6) Designations must consider cumulative effects of the OHV routes on both natural and cultural resources and other forest users.
7) There is a grave danger that, because this process is not designating hiking or equestrian trails or wilderness areas, OHV recreation will take precedence over non-motorized recreation. In order to ensure against this, no routes should be designated where there is controversy over use on that route. Also, no OHV routes should be designated in Forest Service recommended wilderness areas, inventoried roadless areas or areas currently identified for potential wilderness by the public or Forest Service.
8) Redundant routes should be eliminated. Access should neither be confused with, nor lead to, excess.
9) Maximum road/trail density for specific areas should be determined, considering wildlife and/or water quality issues. Capability models for ESA-listed and Management Indicator Species (MIS) should be used to determine maximum route density. Prior to designation of routes, the
10) Loops or potential loops should be evaluated carefully. While loops may be desirable from a recreation and management perspective, these can also result in an undesired increase in OHV activity that displaces other forest users. Campers or picnickers who seek peaceful seclusion use many dead-end routes.
11) OHV routes should be designated in “zones” with consideration of traditional, quiet recreation, and ensure that large areas of the forest remain relatively quiet for traditional forest users.
12) Careful consideration should be given to the type of OHV use designated on each route; four-wheeling may be compatible with family camping areas; dirt bikes and ATVs may not.
13) Pay heed to the results of the California Department of Parks and Recreation survey which found, in 1998, that the highest unmet recreation needs were for walking and hiking, not off-roading. (Public Opinions and Attitudes on Outdoor Recreation in California 1997: An Element of the California Outdoor Recreation Planning Program, March 1998.)
14) Route designations should take into consideration the forest’s budget for road maintenance as well as its recreation budget. Recreation budgets should be equitably allocated between motorized and other recreation needs.
15) Roads identified for closure in Roads Analysis should be restored, not designated for OHVs. All routes not designated should be restored unless specifically designed and needed for administrative use.
16) Routes should not be designated through or near cultural sites. The integrity of such sites should supercede route designation. Removal or burial of sites is not an acceptable mitigation and does not meet the requirements to minimize impacts.
17) Routes should not be designated in desert riparian areas, and elsewhere only where a perpendicular crossing is absolutely necessary and can be constructed without sediment from trail affecting the riparian zone.
18) OHV use is directly connected to the other three forest threats: noxious weeds, fragmentation and fire. Tires spread weeds; roads and trails fragment habitat and vehicles are a common cause of wildland fire. OHV route designation must consider how a route will contribute to or mitigate these other threats.
Level 1 and 2 roads
The Forest Service has far more system roads than it can properly maintain, and these system roads continue to degrade water quality, watershed health, and wildlife habitat. Many system roads have outlived their usefulness and pose significant threat to the environment. A reduction in overall road mileage is needed to improve habitat quality and watershed health, and to bring agency infrastructure into alignment with its current budget.Addressing route issues requires a multi-step process.
First, the agency must analyze its current route system to determine which routes are needed for public or administrative purposes. This analysis should include Level 1 and 2 system roads as well as system trails and non-system routes and trails.
Second, the agency must determine which of these routes are environmentally sustainable and can be maintained with the agency’s current budget.
Third, the agency must designate the optimal route system on USFS lands, taking into account public and administrative needs, environmental concerns, and agency budget.
Fourth, the agency must gate or otherwise prevent ORV access onto those roads deemed necessary for administrative use, but are not appropriate for ORV use.
Finally, the agency should remove those roads and non-system routes that are not designated for public or administrative use, beginning with those routes that cause the most damage to the environment.
 We expect full compliance with the EOs, notwithstanding the recent weakening of Forest Service implementing regulations.
 We support the new Forest Service regulations that change the term “unclassified” to “unauthorized,” and believe it will help the public understand the illegality of user-created roads and trails.