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!!FOREST PLAN ALERT!!!
Send in your comments now
August 4, 2004

"An appeaser is one who feeds a crocodile, hoping it will eat him last."
-Prime Minister Winston Churchill

This statement by Churchill should be taken to heart by IMBA.

Now is your chance to protect your access to the Cleveland, San Bernardino, Angeles and Los Padres National Forests and show the Sierra Club and CBD that their tactics of hiding behind their rhetoric of "Protect and Restore our Forests!" did not fool you. The draft plans for the four national forests of Southern California are being finalized, and your comments will affect the next 15 years of your recreational access to these forests. Protect your access by commenting by the August 11th deadline.

Please comment with the suggested comments below by email and by mail or fax. Please cc the Warrior's Society on your emails. We want your comments in the event we take this issue to court.

Please send this link to every cyclist you know in California. We need to make sure the Forest Service (and the Sierra Club and CBD) hears our message and protects and improves recreation in these four forests for the next 15 years.

Thank you for getting involved in this critical matter; the only enemy we have is apathy - your freedom is worth defending.

EMAIL:

socalforests@fs.fed.us

MAIL:

Southern California Forest Planning
Re: (Specific forests you're commenting on: Cleveland, San Bernardino,
Angeles, and/or Los Padres)
USDA Forest Service Content Analysis Center
PO Box 22777
Salt Lake City, UT 84122

FAX:

You may also fax your comments to: (801) 517-1015

You should tell them who you are, where you ride, what your concerns are. Please comment on the following 4 issues:

A. Proposed Wilderness Designations
B. Proposed Wild and Scenic River Designations
C. Proposed Research Natural Areas and Special Interest
D. The Sierra Club and Center for Biological Diversity's (CBD) Conservation Alternative 6

Pick one or two of the points provided to for each of the 4 issues along with the issue introduction. Place the required general comments at the beginning of your letter/email. Try to put the general comments and introductions in your own words based on our suggested text. If you can, also make some modifications to the points we suggest and mix the order you place the issue in so all the letters are somewhat different.

Be sure to include the number footnotes, if any, of the points contain them.

REQUIRED GENERAL COMMENTS

You applaud the Forest Service for its choice of Alternative 2 for the Cleveland National Forest and Alternative 4 for the San Bernardino, Angeles and Los Padres National Forests. The plans should NOT restrict recreation to official, system trails until and unless a thorough inventory and travel planning process occurs with public involvement. Until then, the plan should only require bikes to stay on existing trails.

A. PROPOSED WILDERNESS DESIGNATIONS

INTRODUCTION - We support the conservation of our public lands but feel the restrictive wilderness designation ties the hands of the Forest Service in its ability to address changing forest conditions, such as the current overgrowth, drought, beetle infestation and the devastating fires this combination of factors have fueled.

Since 2000 we have lost 19 million acres of habitat to devastating fires. The toll of these devastating fires resulted in the death of many species, the loss of human lives and the destruction of hundreds of homes as well. The current multi-year drought, overgrowth, and beetle infestation has left our forests in an extremely unhealthy state, a virtual tinder box ready to explode into devastating fires.

The Sitton Peak (1), Mono (2), Sugarloaf (3), and Cutca (4) recommended wilderness areas also contain multiuse trails, which would no longer be the case if they are designated as wilderness. This is in direct conflict USFS REC: #3(5), to provide outdoor recreation opportunities.

(1) USDA-Forest Service, Pacific Southwest Region. Draft Management Plan, Part 2: Cleveland National Forest Strategy. May 2004 R5-MB-042 - Land Management Plan Strategies, Suitable Land Uses, Land Use Zones, Recommended Wilderness (RW) - Sitton Peak

(2) USDA-Forest Service, Pacific Southwest Region. Draft Management Plan, Part 2: Los Padres National Forest Strategy. May 2004 R5-MB-043 - Land Management Plan Strategies, Suitable Land Uses, Land Use Zones, Recommended Wilderness (RW) - Mono

(3) USDA-Forest Service, Pacific Southwest Region. Draft Management Plan, Part 2: San Bernardino National Forest Strategy. May 2004 R5-MB-044 - Land Management Plan Strategies, Suitable Land Uses, Land Use Zones, Recommended Wilderness (RW) - Sugarloaf

(4) USDA-Forest Service, Pacific Southwest Region. Draft Management Plan, Part 2: Cleveland National Forest Strategy. May 2004 R5-MB-042 - Land Management Plan Strategies, Suitable Land Uses, Land Use Zones, Recommended Wilderness (RW) - Sitton Peak

(5) USDA-Forest Service, Pacific Southwest Region. Draft Management Plan, Part 2: Los Padres National Forest Strategy. May 2004 R5-MB-043 - Land Management Plan Strategies, Prospectus, Program Strategies and Tactics, Public Use and Enjoyment, Recreation, Rec. 3: Recreation Participation

POINT #1 - The USDA Forest Service is under mandates from both the Forest Service National Fire Management Plan and the Healthy Forests Restoration Act of 2003 to "improve the capacity of the Secretary of Agriculture and the Secretary of the Interior to plan and conduct hazardous fuels reduction projects on National Forest System lands and Bureau of Land Management lands aimed at protecting communities, watersheds, and certain other at-risk lands from catastrophic wildfire, to enhance efforts to protect watersheds and address threats to forest and rangeland health, including catastrophic wildfire, across the landscape, and for other purposes."

POINT #2 - Wilderness designations severely impact the ability of the USDA Forest Service to meet the mandates of the Forest Service National Fire Management Plan, State Fire Management Plan and the Healthy Forests restoration Act of 2003.

Other environmental laws currently offer protection.

» The NEPA (National Environmental Policy Act of 1969) process offers protection.
» The ESA (Endangered Species Act of 1973) offers protection.
» The Clean Water Act offers protection.

B. PROPOSED WILD AND SCENIC RIVER DESIGNATIONS

INTRODUCTION - We support and encourage safe, responsible and diverse recreation opportunities that encourage family and community-oriented activities. We feel there are many different ways to experience and enjoy nature in a respectful manner that will not impact the rivers proposed for the Wild and Scenic Designation.

POINT #1 - My comments are specifically related the Santa Ana River (1) and Bear Creek (2) proposed designations.

The issues brought up regarding these designations are also applicable to these other proposed Wild and Scenic River designations.

Only "free-flowing" streams are eligible for designation under the Wild and Scenic River Act. Rivers to be designated "Wild" or "Scenic" must be "flowing in a natural condition without impoundment, diversion, straightening, rip-rapping or other modification of the waterway." Bear Creek and the Santa Ana River do not qualify under these conditions.

Bear Creek is not free-flowing because Bear Valley Dam impounds the stream to create Big Bear Lake. USFS circumvents the clear language of the Wild and Scenic Rivers Act by implying, incorrectly, that Bear Creek begins at the outfall from the dam. Even there, Bear Creek does not flow "freely" because the stream is strictly regulated by the State Water Resources Control Board (a fact acknowledged by USFS in their Eligibility Inventory for Bear Creek).

USFS also acknowledges that various different diversion works operated by Southern California Edison impede the natural flow of the Santa Ana River. Once again, USFS redefines the river into "segments" between the diversions in order to assert that portions of the Santa Ana River are eligible for designation as a Wild or Scenic River. In essence, by establishing such segments, USFS is saying that Bear Creek and the Santa Ana River are free-flowing between the dams and diversions. The very existence of these hydrologic structures disqualifies the streams from any further consideration under the Wild and Scenic Rivers Act.

(1) USDA-Forest Service, Pacific Southwest Region. Draft Management Plan, Part 2: San Bernardino National Forest Strategy. May 2004 R5-MB-044 - Appendices, Appendix A, Special Designation overlays, Wild and Scenic Rivers, Eligible - Santa Ana River

(2) USDA-Forest Service, Pacific Southwest Region. Draft Management Plan, Part 2: San Bernardino National Forest Strategy. May 2004 R5-MB-044 - Appendices, Appendix A, Special Designation overlays, Wild and Scenic Rivers, Eligible - Bear Creek

POINT #2 - My comments are specifically related the Palm Canyon (1) and Piru Creek (2)

Piru Creek and Palm Canyon do not have year-around continuous flow, even on wet years. This calls into question whether they can actually be said to have "outstanding remarkable values and water quality". During much of the year, there are extended stretches that are dry or stagnant. This is not what most would consider "outstanding water quality" nor does this in any way support the USFS goal of improving watershed condition.

Wild and scenic designation of Piru Creek and Palm Canyon is in direct conflict USFS REC: #3 (3), to provide outdoor recreation opportunities. This is in direct conflict with the Forest Service Management Plan. The Wild and Scenic designation splits the Piru OHV recreational area in half. Piru Creek and Palm Canyon are intersected by several popular recreational trails. Piru Creek has the Snowy Trail, Miller Jeep Trail and Piru Creek Trail and Palm Canyon has the Palm Canyon Trail. This trail is not numbered: however it is used by hikers, mountain bikers, and horseback riders. The other trails that feed into the Palm Canyon Trail (Palm Canyon) include Pinyon Trail, Live Oak Canyon Trail, Dutch Charlie Trail, and Potrero Canyon Trail.

The terrain within the Piru and Palm Canyon areas is so extreme that development or misuse has virtually been non-existent. No substantiation has been provided to neither refute these statements nor provide evidence of a need for a change in status.

(1) USDA-Forest Service, Pacific Southwest Region. Draft Management Plan, Part 2: San Bernardino National Forest Strategy. May 2004 R5-MB-044 - Appendices, Appendix A, Special Designation overlays, Wild and Scenic Rivers, Eligible - Palm Canyon

(2) USDA-Forest Service, Pacific Southwest Region. Draft Management Plan, Part 2: Los Padres National Forest Strategy. May 2004 R5-MB-043 - Appendices, Appendix A, Special Designation overlays, Wild and Scenic Rivers, Eligible - Piru Creek

(3) USDA-Forest Service, Pacific Southwest Region. Draft Management Plan, Part 2: Los Padres National Forest Strategy. May 2004 R5-MB-043 - Land Management Plan Strategies, Prospectus, Program Strategies and Tactics, Public Use and Enjoyment, Recreation, Rec. 3: Recreation Participation

POINT #3 - Other environmental laws currently offer protection.

» The NEPA (National Environmental Policy Act of 1969) process offers protection.
» The ESA (Endangered Species Act of 1973) offers protection.
» The Clean Water Act offers protection.

C. PROPOSED RESEACH NATURAL AREAS AND SPECIAL INTEREST AREAS

INTRODUCTION - We understand the purposes of proposing Research Natural Areas and Special Interest Areas but are concerned with the effect these designations will have on the public's ability to access these areas.

Point #1 - The issues brought up regarding these specific proposed Natural Research Areas and Special Interest Areas, Chiquito Springs (1) and Aliso-Arrastre (2) are/may also be applicable to the other proposed Natural Research Areas and Special Interest Areas.

Our main concern regarding these proposed designations are the statements related to recreational access "Uses that retain the research values for which the site is designated are appropriate " and "Uses that are compatible with maintaining the target of the areas designation are appropriate. "

No indications are given as to what recreation activities will be acceptable or whether these recreation activities may possibly be limited in the future.

The Forest Service is mandate by USFS REC: #3 (3) to provide outdoor recreation opportunities. This mandate may conflict with the purposes of Research Natural Areas and Special Interest Areas. Allowances should be made to protect existing uses or to provide for the re-routing of existing trails or roads to mitigate any impact on these areas.

For example, Chiquito Springs contains one of the most popular trails in the Cleveland National Forest, the San Juan Trail. The description of area states "The San Juan and Chiquito trails are very popular with mountain bikers. There is some potential for disturbance by off-trail biking." This statement assumes impact, when in reality there has been no disturbance by off-trail biking, and due to the terrain and brush, including poison oak, there is no incentive or reason to "go off trail."

In the case of the proposed Aliso-Arrastre Special Interest Area, the description of area states "The area of the proposed SIA has many other forest uses occurring including transmission line corridor (lines, roads), clay mining operation, Forest Service system roads, Los Angeles County Roads, plantations, private in-holdings, and hiking and riding trails." The description does not indicate that any of the existing recreational uses will be eliminated or restricted.

(1) USDA-Forest Service, Pacific Southwest Region. Draft Management Plan, Part 2: Cleveland National Forest Strategy. May 2004 R5-MB-042 - Land Management Plan Strategies, Suitable Land Uses, Special Designations Overlay, Proposed Special Interest Areas - Chiquito Springs

(2) USDA-Forest Service, Pacific Southwest Region. Draft Land Management Plan, Part 2: Angeles National Forest Strategy. May, 2004 R5-MB-041 - Land Management Plan Strategies, Suitable Land Uses, Special Designations Overlay, Proposed Special Interest Areas - Aliso-Arrastre

(3) USDA-Forest Service, Pacific Southwest Region. Draft Management Plan, Part 2: Los Padres National Forest Strategy. May 2004 R5-MB-043 - Land Management Plan Strategies, Prospectus, Program Strategies and Tactics, Public Use and Enjoyment, Recreation, Rec. 3: Recreation Participation

POINT #2 - The Forest Service has failed in the case of all the proposed designations to inform the public on the ultimate impact these proposed designations will have on their recreational access. This information should have been provided before these areas were proposed for these designations.

POINT #3 - Proposed Research Natural Areas and Special Interest Areas must be consistent with the mandates of the Forest Service National Fire Management Plan and the Healthy Forests Restoration Act of 2003 to "improve the capacity of the Secretary of Agriculture and the Secretary of the Interior to plan and conduct hazardous fuels reduction projects on National Forest System lands and Bureau of Land Management lands aimed at protecting communities, watersheds, and certain other at-risk lands from catastrophic wildfire, to enhance efforts to protect watersheds and address threats to forest and rangeland health, including catastrophic wildfire, across the landscape, and for other purposes."

Proposed Research Natural Areas and Special Interest Areas must allow appropriate mechanized access for wildfire mitigation. This includes specific language protecting the health of the land, allowing for appropriate treatments, such as hazardous fuels reduction projects, if neighboring county, city or private lands are at risk from deteriorated conditions in proposed Research Natural Areas and Special Interest Areas.

D. THE SIERRA CLUBS CONSERVATION ALTERNATIVE 6

INTRODUCTION - The USDA Forest Service's reasoned decision not to adopt the restrictive fire management proposals being advocated by Conservation Alternative 6 is commendable. Since 2000 we have lost 19 million acres of habitat to devastating fires. The toll of these devastating fires resulted in the death of many species, the loss of human lives and the destruction of hundreds of homes as well. The current multi-year drought, overgrowth, and beetle infestation has left our forests in an extremely unhealthy state; a virtual tinder box ready to explode into devastating fires.

There is a need to conserve and manage our public lands, but a more balanced approach that supports active management must be implemented. Conservation Alternative 6 would place restrictions on fire agencies in fighting fires and subject them (or governments) to possible lawsuits for not protecting TES (threatened and endangered species) and for violating the ESA Endangered Species Act) requirements.

POINT #1 - At this time we do not see a great need for new roads or trails, but we do see a need to protect roads and trails we've used historically. The proposals being advocated by the Conservation Alternative 6 would result in the loss of what has been estimated to be up to 60-70 percent of our recreational access. For example, the Conservation Alternative 6 road standards, combined with their Road Removal and Restoration (RRR) proposals and standards related to mountain biking, would remove mountain bikers from 99 percent of the trails in the Trabuco District in Orange County. This would greatly affect the public's recreational access.

POINT #2 - The goal of the Conservation Alternative 6 is to remove as much public access as possible. Their proposed mountain bike recreational policies would force mountain bikers onto roads, but these roads will also be subject to removal. Their Road Removal and Restoration (RRR) proposals that identifies roads for removal and "obliteration" would have a dramatic effect on recreational access. For example, here in the Trabuco District of the Cleveland National Forest, Maple Springs Road (the road that begins at the end of Silverado Canyon) Trabuco Canyon Road (the road the leads to the Holy Jim Trail), the Indian Truck Trail and the Harding Truck Trail would not meet their qualifications. I'm sure this is the case with many of the roads in the other National Forests as well.

POINT #3 - The Conservation Alternative 6 proposals for recreation would ban mountain bike recreation from large portions of the Southern California National Forests, restricting mountain bike recreation to only the few fire roads that remain open if the Road Standards and Road Removal and Restoration proposals of Conservation Alternative 6 are implemented.

POINT #4 - Conservation Alternative 6 proposes that "The Forest Service shall designate all existing and potential Wilderness Areas and Roadless Areas over 1,000 acres in size as Primitive under the ROS (Recreation Opportunity Spectrum)."

A major portion of the four national forests are designated as "roadless." Although Roadless Inventoried Areas must be reviewed as a part of the forest plan revision process, the Roadless Area Conservation Rule is enjoined from implementation by a lawsuit in Colorado and there are two additional suits pending. But we should still proceed as if this initiative/designation will be implemented.

For example, here in Orange County, all our single-track trails are in the Trabuco Roadless Area. Many of the trails in the other three national forests are probably also in a named Roadless Area. The "Primitive" ROS management designation prohibits mountain bikes and while wilderness areas must be at least 5,000 acres in size, this rule would in fact create de facto wilderness designations in areas (designated as roadless) that are as small as 1,000 acres in size. Managing these areas under the "Primitive" ROS designation would radically affect mountain bike access.

Point #5 - The requirements proposed by Conservation Alternative 6 would have severe impacts on mountain biking, especially if the Forest Service is unable to accomplish the mandated trails assessment in the 1 year time period required in Conservation Alternative 6. Failure to comply would give grounds to file a lawsuit to close these trails to mountain bikes because the Forest Service is in violation of the standards put forth in Conservation Alternative 6. To survey these trails and bring these trails up to the standards stated in Conservation Alternative 6 would take funds and personnel the Forest Service does not have.


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