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HomeMy WebLinkAboutEmail from Brian Ring - County Concerns Working with US Forest Service Menchaca, Clarissa From: Ring, Brian Sent: Wednesday, December 6, 2017 9:21 AM To: Connelly, Bill; Kirk, Maureen; Lambert, Steve;Teeter, Doug;Wahl, Larry Cc: McCracken, Shari; Menchaca, Clarissa Subject: USFS Letter Attachments: Butte County USFS Letter.pdf Good morning all— Please find the attached letter that will be sent out today outlining a number of concerns the County has had in working with the US Forest Service over the years. Thanks. Brian Ring Assistant Chief Administrative Officer Administration 25 County Center Drive, Oroville, CA 95965 T: 530.552.3311 1 M. 530.570.7688 1 F: 530.535.7120 1 au BOARD OF SUPERVISORS ��"� �.��•, BILL CONNELLY sdS FirstDistrict ADMINISTRATION CENTER LARRY WAHL °• '"•� �• "�� 25 COUNTY CENTER DRIVE,SUITE 200 -OROVILLE,CALIFORNIA 95965 Second District aaa„� nyyd TELEPHONE:(530)538-7639 MAUREEN KIRK Third District STEVE LAMBERT Fourth District DOUG TEETER December 5,2017 Fifth District Mr.Tony Tooke,Chief United States Forest Service 1400 Independence Ave,SW Washington, DC 20250-1111 Subject: Butte County Dear Chief Tooke: On behalf of the Butte County Board of Supervisors, I am writing to share our experience working with the United States Forest Service(USFS)to address key issues facing Butte County. Butte County contains parts of two National Forests:the Lassen and the Plumas. The issues surrounding forest management,wildfire prevention and suppression,and recreational access are very important to our citizens and Board. Elected officials and County staff have written volumes of letters in support of additional funding for the Forest Service to address some of the challenges presented by these issues. Through the County's Forest Advisory Committee and other venues,we have actively attempted to engage the local ranger districts as well as the Lassen and Plumas National Forest Supervisors to build relationships,but these efforts have at times been hampered by continuous personnel turnover in these positions with the USFS. Developing a sound,open path of communication to effect coordination between the local forests and counties has been a challenge. Past letters from the County regarding recreational access have urged the creation of a Coordination Council with representatives from surrounding counties, USFS and California Highway Patrol participating.The Council could also allow public participation in addressing the differences that exist between counties and the Forest Service. Forest Management and Wildfire Prevention The County has communicated its top priorities to Lassen and Plumas Forest Supervisors,as well as to our state and federal Legislators.Among these is an increased emphasis on preventing wildfires through proactive timber harvest projects,fuel reduction projects and effective grazing practices.This includes aggressive salvage of timber burns and insect mortality areas and restoration treatments of at-risk watersheds to address creeks and streams that are choked by excessive brush growth. We recognize that current regulations limit the allowable speed and scope of these actions and believe National Environmental Policy Act reform is necessary to aid our efforts in this area. The County recognizes the difficulty the Forest Service faces in preserving funding for proactive forest management and wildfire prevention in the face of significant suppression costs in recent years.The Board has been a consistent supporter of increased funding for forest management and development of a comprehensive fire funding solution to resolve the borrowing issue and the erosion of budget due to increasing suppression costs. Travel Management and Recreation Butte County has made numerous requests for revised motorized Travel Management Plans allowing mixed use on ML-3 roads,as evidenced by letters as early as 2005,and the lack of progress has been frustrating. Many roads with this M L-3 designation in Lassen and Plumas Forests provide access to well- utilized campsites and beneficial access to recreation in both forests.Additionally,the existing Ml.-2 roads are often fragmented and do not provide adequate travel connectivity. While the counties in which Lassen and Plumas Forests reside allow off-highway vehicle (OHV)travel on their roads,the Forest Service prohibits it on hundreds of miles of unpaved roads that look exactly the same as County roads. Since many of the roads are connected,OHV users frequently do not know if they are on County or Forest roads.Addressing this disparity has long been a priority for counties and a recent field trip to Lassen National Forest provided yet another perspective about the core issue. Even after more than nine years of counties'efforts to provide reasonable accommodation and broker a compromise,the USFS still seems indifferent to the desires of the general public. The Board of Supervisors approved a letter(attached)on Tuesday, November 14t' which opposes alternatives which would reduce the amount of available land for Over-Snow Vehicles (05V). It also includes language opposing the unreasonable restrictions against traveling adjacent to and crossing the Pacific Crest Trail. Enhanced outdoor recreation for residents and visitors provides important economic development opportunities for our rural areas. Non-wilderness recreation pians should retain a multi-use focus, considering trails and open areas that may be utilized by OHV and OSV as well as equestrians,hikers, mountain bikers,skiers and other non-motorized activities. Communication and Coordination During recent USFS public meetings we have attended,input from the public is solicited; however,there appears to be no mechanism in place to document and respond to the requested input. It leaves one with the impression that the USFS does not really place great import on what the local area public has to say about issues that concern them the most. Further, despite numerous letters and conversations with Plumas and Lassen National Forest(which have included Congressman LaMalfa)about the critical nature of road 24N04 as a link between a County road(Concow Road)and access to the High takes Recreational Area,communication with regard to this road has been nonexistent. We just recently learned from Sierra Pacific Industries(SPI)that the Plumas National Forest abandoned their easements on road 24N04. Historically,this road had been partially maintained by Plumas National Forest. By abandoning their easements, Plumas National Forest has given all access control to SPI which will most certainly limit public access to this land. Butte County established a Forest Advisory Committee(FAC)locally to take an active role in soliciting and utilizing public input at the local level,and to provide a forum for the USFS and other state and federal agencies for providing information and responding to public concerns. We invite all pertinent Federal Agencies to attend these meetings to avail themselves of the forum we have created to improve communication and understanding. Given the nature of set public meeting dates,including the Board of 2 Supervisors' established schedule,30-45 day comment periods make turn times for Board comments on Schedule of Proposed Action projects problematical. We recommend a 60-day comment period be sta ndard. Most state and federal agencies planning documents require consideration of local agency general pians; however,we have seen no evidence that the Butte County General Plan has been considered,or mentioned in any project planning documents, i.e. "in accordance with"or"contrary to"the provisions of the general plan. The Board of Supervisors will continue to advocate for the creation of a Coordination Council that could provide a communication platform similar to that of the FAC, but on a more regional scale. Such an avenue is needed for improved communication and cooperation to develop mutually agreed upon plans and address key issues before they become larger problems. The USFS and the counties hosting our national forests have a common interest in ensuring the safe enjoyment of our forests for the foreseeable future. We welcome any opportunity to further discuss a satisfactory means of achieving the desired results for the local area counties travel management concerns and/or improved forest management and wildfire prevention programs. Sincerely, —6A 6)76� Bill Connelly,Chair Butte County Board of Supervisors cc: Members, Butte County Board of Supervisors The Honorable Doug LaMalfa, Member, United States Congress 3 (4-Dv BOARD OF BILLCONNELLY / �+ p First Dislric! SUPERVISORS LARRY WAHL Second District MAUREEN KIRK Third District STEVE LAMBERT Fourth District November 14,2017 DOUG TEETER Fifth District Chris O'Brien,on behalf of Dave Hays,Forest Supervisor Lassen National Forest 2550 Riverside Drive Susa nvi Ile,CA 96130 Re: Comment Letter - Lassen National Forest Over-Snow Vehicle Use Designation Revised Draft Environmental Impact Statement Dear Mr. O'Brien and Supervisor Hays: The Butte County Board of Supervisors ("Board") respectfully responds to the U.S, Department of Agriculture--Lassen National Forest's Revised Draft Environmental Impact Statement ("RDEIS") on the proposal to designate aver-Snow Vehicle (05V) use,within the Lassen National Forest. The Board and the Butte County Federal/State Land Use Coordinating Committee have reviewed the Lassen National Forest Proposed Over-Snow Vehicle Use Designation RDEIS and have actively solicited feedback from recreationists and other stakeholders via the Butte County Forest Advisory Committee(FAC)and through direct contact with stakeholders. The Board understands that the Forest Service's 2005 Travel Management Regulations requires the designation of roads,trails,and areas on national forests and grasslands that are open to motor vehicle use.Subpart C mandates the designation of routes and areas for over-snow vehicle use. The Board strongly opposes Alternatives 2 and 3,as stated in its letter of March 8,2016,due to the proposed reduction in the amount of available land for OSV use. The RDEIS fails to mention one exceedingly important consideration for open,non-motorized winter recreation,which is that the entire area of Lassen National Park,which is over 106,000 acres,and is located in the center of the Lassen National Forest,is closed to OSV travel but is open for other,non-motorized recreationists to enjoy the quiet,wilderness winter experience. Alternative 5 has been added in the RDEIS. The following comments pertain to this Alternative,which the Board also strongly opposes: 1) According to the RDEIS document,there are 75,169 acres available for non-motorized recreation within 10 miles of plowed trailheads,44 miles of cross-country ski trails,and other non-motorized routes available for non-motorized recreation within 10 miles of plowed trailheads. There are 185,983 acres/six non-motorized trails with a total of 148 miles for non-motorized use. Of the areas listed in the RDf1S that have groomed motorized trails,with some proximity to the non-motorized areas, none appear to be in or near the areas utilized by visitors to the Jonesville Snow Park. 2) Alternative S reduces the Forest's legal riding acreage by one-third,and significantly affects Butte County's only organized winter sports center—the Jonesville Snow Park,increasing the non- motorized area from 16,876 acres to 42,524 acres. This reduction in acreage is not supported by any reported conflicts or resource damage of any significance,nor was there an indication of any other resource that needed protection. The Hillsliders Club that grooms and manages this Snow Park is of the opinion that this would cripple their program and adversely affect numerous visitors without deriving any particular benefit to non-motorized visitors already enjoying the Jonesville Snow Park.Our public lands are everyone's land,and there is a history of little to no conflicts in this area. So why confiscate that acreage and make it illegal to ride there? There is simply no good reason to support such a reduction,and we strongly oppose any Alternative that reduces acreage without sound reasoning and legal foundation. 3) The restriction to 12"snow depth only,with no allowance for reaching groomed trails from the trailheads,could reduce access to groomed trails. This is unnecessary,as snowmobilers must use good judgement and not travel across gravel or pavement or brush and rocks unless they are adequately protected by a minimum depth of snow,or their expensive equipment would be severely damaged. 4) The restrictions regarding accessing the area on and around the Pacific Crest Trail(PCT)are unnecessary,impractical,and unenforceable. Due to snow depths, it is literally impossible to determine where the PCT is located,in winter,and there has been no documented history of pedestrian traffic on the trail in the open OSV travel areas due to its remoteness,its danger,and the inability to reliably locate the trail in the winter. Additionally,the trail is generally located in and around trees,which is a dangerous place to be when the snow reaches its usual depths in the winter. OSV enthusiasts,skiers,and snowshoers wisely avoid such areas due to the hazardous conditions. If the LNF decided this element of Alternative 5 were truly an imperative,seasonal signage would need to be installed,which would be logistically difficult and very expensive. Also, GPS mapping is not workable with any degree of accuracy and reliability. 5) The reference to no OSV travel over open orfiowing water is sometimes impractical due to occasional snowmelt streams that are encountered during cross country travel. We see no reference to resource damage cause by this practice. The Board supports ONLY a modified Alternative 4, pursuant to the following comments: • The Board believes that the 12"un-compacted depth for grooming trails is reasonable. • The Board agrees that no defined snow depth be designated for cross-country OSV travel or on designated OSV trails. • The Board does not believe OSV use be allowed with forest staff determinations through a combination of weather station data,observations at trailheads by staff,and when groomers decide conditions are right. This policy would lead to unnecessary delays in opening or resource damage occurring with delays in closing. 2 • The Board supports preventing resource damage, OSV use should be prohibited when such use causes resource damage. Clearly defining what resource damage is and informing the public on what not to do is the preferred OSV use approach. • The Board believes seasonal opening and closing announcements or date restrictions would be unnecessary when using a prohibition of resource damage policy. • The Board supports allowing OSV use below 3,500 feet. • The Board supports the following regarding the Pacific Crest Trail("PCT"): o Agrees with the Pacific Crest Trail Association that the PCT is not designed for travel when snow is on the ground. o Agrees with the 1982 Comprehensive Management Plan forthe PCT("CMP") assumption on page 23,"Crossing the PCT by snowmobiles would not be in conflict with the intent of congress if such use were part of a winter sports plan that permitted snowmobiles to use the land adjacent to the trail". o Agrees with CMP's Effects on the Management of Adjacent Public Land within Federal lands outside National Parks and Wilderness(57%of the trail)(p.21),"the trail must co- exist in harmony with all other resource uses and activities of the land as determined through the land management planning process.The trail will cross a mosaic of areas differing in primary management emphasis.This could be grazing, key wildlife habitat, special interests,such as;scenic or geologic,developed recreation,unroaded recreation, research,natural,or intensive timber management.Viewing and understanding this array of resources and management is one of the primary recreation opportunities to be made available over these portions of trail.Some activities such as road construction, logging, prescribed burning, herbicide application,mining,etc.,will require considerable informational and interpretive skills to be placed in a positive perspective from the standpoint of the user.The agencies should look at this as an opportunity to explain the multiple-use concept." o Lassen National Forest's minimization measures Sand 6(p.32). o A balanced mix of OSV open PCT crossing areas and designated OSV crossings. • The Board does not support Lassen National Forest's Minimization Measure number 4(p.32). Promoting the"entire" PCT for winter use by signing is not practical or safe. The Pacific Crest Trail Association warns of the dangers associated with winter use. The forest should analyze the natural dangers(i.e.avalanche and tree holes),cost and danger of rescuing users,and agreement by local public safety officials and governments who provide rescue response prior to adopting winter PCT use. The PCT CMP does not require designated snowmobile crossings unless signed and marked for use by cross country skiing and/or snowshoeing. • The Board seeks clarity on PCT crossings and adjacent use described in Alternative 2: o How many miles of PCT are within the Lassen National Forest? o How many miles of PCT are in existing non-motorized areas? o How many miles of PCT are in proposed Alternative 4 non-motorized areas? o Where is the 97.68 of adjacent use located on map? Are crossings shown on map on county roads? If yes,we question the forest's authority on designating county roads as crossings. ' + The Board supports prohibiting cross-country OSV use in the entire area from SH36 up SR89 to Lassen Volcanic National Park and across McGowan Lake Road to NFS road 31N17,with one exception:within this OSV prohibited area,designate for OSV use the trail from the intersection of 30N1.6(McGowan lake Road)and 30N16C to allow OSV use from this intersection west out to 3 the 31N17 road.Therefore,OSV use would be restricted to only this designated OSV trail within this area. • This alternative would groom the same snow trails for OSV use as the modified proposed action. For future considerations,the Board restates the desire to see a provision for additional miles of OSV groomed trails and Non-motorized trails as funds(grant funds or budgeted funds) become available. Additionally,the Board would like to see additional parking areas made available for safe trallering and unloading of OSV equipment,and increased signage indicating whether the trails are shared use or restricted. The Board is in complete opposition to Alternatives 2,3,and 5 believing there is ample non-motorized trails and open protected areas under the current plan;especially closure of the Colby Mountain area, for the following reasons: 1) This area is currently managed by the Butte Meadows Hillsliders in partnership with The US Forest Service,Butte County,Plumas County,and Sierra Pacific.This collaboration is an excellent,sustained example of goals contained in the 1992 Lassen National Forest Land and Resource Management Plan(LRMP); • Provide stable and cost-efficient road and trail systems(pg.4-3); • Provide a wide-range of outdoor recreation opportunities to meet public demand(pg.4-4); • Provide diverse opportunities for off-highway vehicle recreation (pg.4-4); • Provide diverse opportunities for winter sports(pg.4-4); and • Work in partnership with local communities to expand recreational facilities,programs,and trails on both public and private land(pg.4-5). 2) To operate and manage the Jonesville Snow Park the Hillsliders must coordinate with all of these stakeholders. Unlike other parks,the Hillsliders pay all expenses incurred at the park.This includes plowing of roads to the park,the parking lot,and maintaining equipment purchased by the Hillsliders,including toilets.The Hillsliders pay liability insurance which also covers the cross country skiers when they venture on Sierra Pacific Industries'land.This has been going on for over 25 years with Hillslider's money and volunteers.When the original snow park was set up an agreement was reached to set up groomed trails leading away from the park in one direction for snowmobilers and provide cross country/bicycle trails in the other direction.The Hillsliders paid for all of this including the signage for the cross country and bicycle trails.They also paid forthe bridges that allow cross country skiing and bicycle use. Motorized use is currently illegal on those trails according to the original agreement,and the cross country and OSV communities have worked together with no conflicts. 3) The Snow Park has become more popular overthe years and the Hillsliders have continued to manage this and make improvements.The number one usage,according to available data,is snowmobiling and number two is snow-play for families. In the third spot is cross country/snowshoeing,which is followed by mountain biking. The Hillsliders have managed this Snow Park for all stakeholders for many years. If the current program has worked for so long it should stay the same.No funds are received from Lassen National Forest for the operation of the Snow Park.This park would not operate without the Hillsliders volunteers and money. 4 4) Because of the varied and plentiful opportunities in the LNF it is a destination area for many people from out of the area.The Hillsliders have club members from both motorized and non-motorized sports,and from all over the North Valley(and as far south as the Sacramento area),east to Glen- Colusa and north to the Chester/Almanor area.The economic impact of winter sports hosted by the Jonesville Snow Park cannot be overstated. We must emphasize that closure of parts of the area utilized by these winter sports users,as suggested by Alternative 5,would cripple the Jonesville Snow Park and the Hillsliders'successful and long-standing grooming and maintenance program. Additionally,the counties surrounding this Forest benefit greatly from OSV use.All snowmobile trailheads and areas are shared use areas.Conflict is minimal.OSV users are usually educated as to which areas they can ride and stay out of the areas they know where riding is prohibited.There are very few tickets issued on this forest for non-compliance.Overnight parking is allowed at all snowmobile parking lots in the Lassen National Forest. Forest Service economists have defined economic analysis areas for all national forests and grasslands using a protocol that identifies interactions between Forest Service resource management and local economic activity.Based on this protocol,the Lassen National Forest's economic area of influence encompasses Butte,Lassen,Plumas,Shasta,and Tehama counties.These five counties form the social and economic analysis area for the Forest's study regarding impact of changes to the current DSV regulations. Based on membership figures from the Hillslider's records,we would also add Glenn, Colusa,and all counties between Sacramento and Butte counties. Two-thirds of their membership are from outside Butte County,meaning there is significant benefit to the local economy from these visitors to our area. The Lassen NF analysis states that an estimated 10,020 OSV visitors utilize the park's amenities annually, which benefits not only the recreationists, but also local businesses that provide supplies,food,and accommodations to users. The draft EES states:"Much of the Lassen National Forest recreation visitor spending contributes to economic activity in travel and tourism-related sectors.These sectors include retail trade, passenger transportation,accommodation and food,and arts,entertainment,and recreation.Travel and tourism sectors account for a larger share of employment in the analysis area counties than in California overall.This suggests that the analysis area economy is reliant on tourism (including outdoor recreation). According to the report,the contribution of OSV use to local economic activity,and the potential for restrictions to decrease these economic contributions,was noted by a Commenter:"It is critical that an economic analysis be completed as part of the environmental analysis...If the restrictions that are currently proposed in the NOI were implemented this year,there would be a great impact to local businesses and loss of jobs"(Sierra Access Coalition)." The Board agrees with this statement,and wishes to encourage additional tourism activity and the consequential economic benefit. The Board has reviewed the environmental impacts,and understands that the Lassen National Forest RDE1S concludes that,in all scenarios: 1) "On the Lassen National Forest,OSV travel on snow-free areas is prohibited in the current and proposed scenarios. By not allowing OSV use when and where there is less than 12 inches snow depth,the Lassen National Forest minimizes the possibility of direct damage to soils and ground vegetation. 2) Moderate snowpack levels have been shown to minimize the potential compaction from OSV use (Gage and Cooper 2009).With adequate snow depth, both on-trail and off trail OSV use would have minimal to no impact on the soil resource and would not likely lead to any loss of soil productivity. With adequate snow depths,cross-country OSV use is unlikely to affect soil stability. 5 3) it is expected the levels of pollutants for the Alternatives would fall within the ranges currently experienced and no violation of state or Federal ambient air quality standards would occur on the Lassen National Forest during the OSV season." 4) For endangered or sensitive species:for most,"may impact individuals,but are not likely to lead to a loss of viability or a trend toward federal listing". For the California Spotted Owl,"would impact individuals,but are not likely to lead to a trend toward federal listing or a loss of viability",for the Sierra Yellow-Legged Frog,"May affect,likely to adversely affect". However,this appears to be mitigated to the greatest extent possible by disallowing travel across non-frozen streams and lakes, and is no change from the existing conditions. Accordingly,the Board wishes to reiterate its supportfor Alternative 4,which minimizes closure of OSV areas and protects the economic viability of the tourism industry revolving around OSV as well as non- motorized recreationists,while still allowing for enhanced non-motorized experiences and increased flexibility for snow depths for both OSV riders and grooming of trails. The Board would also like to emphasize its opposition to Alternatives 2,3,and especially Alternative 5,which reduces the amount of open land available for OSV travel and has the most adverse and dramatic effect on Butte County winter sports and associated socio-economic impact. Thank you for the opportunity to comment. We look forward to your response. Respectfully, 1 Bill Connelly Chair, Butte County Board of Supervisors cc: Butte County Federal/State Land Use Committee Forest Advisory Committee Almanor Ranger District b