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Home My WebLink AboutEmail from Kyle Felker - Lasen OSV Revised DEIS Menchaca, Clarissa From: Moak, Peggy Sent: Monday, November 13, 2017 12:58 PM To: Menchaca, Clarissa Cc: 'Kyle Felker';Teeter, Doug Subject: FW: SAC Attachments: Talking Points Butte BOS 20171113.docx; inability to chage as conditions changejpg Clarissa, please submit this email and attachments from Kyle Felker as Pubiic Comment to the Board members for agenda item 3.18, pertaining to a letter from the Board on the Lassen OSV Revised DEIS. I have one other public comment, as well, coming in a minute. Thank you! Peggy Moak Butte County Treasurer-Tax Collector Treasurer-Tax Collector's Department 25 County Center Drive, Suite 125,Oroville, CA 95965 T: 530.538.7443 ( T: 530.538.77011 F: 530.538.7648 Twitter I Facebook I YouTube I Pinterest -----Original Message----- From: Map It [mailto:mapit400@gmail.com] Sent: Sunday, November 12, 2017 8:07 PM To:Teeter, Doug<DTeeter@buttecounty.net>; Moak, Peggy<pmoak@buttecounty.net> Subject: SAC Doug and Peggy This is our revised talking points that I will be using Tue.This is suitable for distribution. Question or concerns please call. ------------ Kyle Felker 530 251-6112 t Talking Points Assumptions • LNF will be the first forest with an OSV plan and will set the template for other NFs to follow. (The other 4 National Forests are on hold until the LNF has a final OSV plan) • Conflicts are user created and may not even exist. There is no documentation to support this allegation. • Future LMP revisions will not reanalyze Subpart C. Motorized and non-motorized meeting in Chester Motorized and non-motorized users met in Chester on Nov. 7 in an attempt to find common ground. It was a very productive meeting. We 100% agreed: • The 12" minimum snow depth is not necessary • The date restrictions are not necessary • The 3500' elevation restriction is not reasonable • PCT 1,000 Ft Wide Barrier. 3,50+0' Elevation restriction This elevation restriction would prevent riding out of the lower areas, even if there is adequate snow. Ground conditions should dictate when OSV use is allowed. Pacific Crest Trail Virtually all of the alternatives propose a 1000' buffer around the PCT. In our meeting in Chester, all participants recommended the proposed PCT 1,000 ft. non- motorized management area be deferred until the Lassen revises their forest plan in a couple of years. • This is consistent with direction in the FS planning rule and agency manuals and handbooks, which all say decisions regarding land allocations are part of the forest planning process. It is required as a higher level decision, not an OSV project decision. • The implications of the proposed PCT non-motorized management area are unknown. For example, is it just a seasonal OSV prohibition or is it a permanent, year-round prohibition of all motorized uses? • Participants suggested the Lassen should clearly state in their OSV ROD the FS will defer the PCT non-motorized area until the forest planning process begins, so there will be a commitment to doing that. • The PCTA website says the trail is not designed for winter snow use. This is a safety issue for skiers. Adequate Snow or Ice • The 12" minimum snow depth is not reasonable and is not supported by any research or science. • A 12" minimum is not required by the Subpart C Final Rule. It is an arbitrary depth that has been chosen by the FS without any validation, and the DEIS has not shown how the FS defines "adequate snow". No Snow Depth measurement plan has been included in the DEIS. • The State Historic Preservation Office (SHPO) has agreed for timber operations that 12" is adequate to protect cultural resources when skidding logs. This not applicable to OSVs that don't even though the ground. But the FS is using this SHPO agreement to prevent OSV use. • If FS is addressing protection by inches, FS has not addressed upper limits. • Ground conditions should dictate when OSV use is allowed. Measurements • The DEIS does not include a Snow Depth Measurement plan. The public needs to be able to comment on the plan that will potentially shut them out of the forest. • Measurements at trail heads may not represent snow depth in the area where people are riding. For example, if the snow is measured at Jonesville, it could close down the entire area that stretches up to Lake Almanor where the snow is deep. • FS cannot react to the needs of OSV on weekends. • Ground conditions should dictate when DSV use is allowed. Management Area • The DEIS proposes to split the LNF into 8 management areas. Snow depth would only be measured at one trail heads. • Ground conditions should dictate when OSV use is allowed. • The 8 management areas may also include large areas designated for only non-motorized use, including expanding wilderness and Lassen National Park with wider adjacent non-motorized areas. Dates • The arbitrary date restrictions are unreasonable. • Rather than dates,the restrictions should be based on current site conditions. • Dates must not be determined by Christmas Tree cutting. • Ground conditions should dictate when OSV use is allowed. NO Pro OSV Alternative • The DEIS provides an inadequate range of alternatives. There is no alternative that is Pro OSV. • All viable alternatives dictate closures only for the benefit of non-motorized interests. • Non-motorized users currently can go anywhere on the LNF. Including the highest valued snow play area- Lassen Volcanic Park. The same is not true for OSV. Lock out does not equal Good Management ,. '�,,. I It' i� l�r(i/�/,�j��/lr�� %%'%�r%/i%%//ii/i rri/✓ I%�ri/ „i / --;, ,,, I ,,,f r �ICrir � 1 ,;l>I ' ! '(1 r /�/ir��i✓a, /r r /i�� N 1%. r r / rill l„ r1/ ,l � �i� f grin f,%/i J � �i✓/�i�r CJI OIOPPP LLI r, u Y , b; � IO Ir r r y 7� ✓rR.r.., �hx ' I, }i