Alternative 6

Five alternatives are proposed in the DEIS. Alternative 3 proposes to add zero trails to the transportation system, yet there is no alternative that proposes to add all of the inventoried trails to the system. That should be one of the alternatives considered, especially when Alternatives 2, 4, and 5 are very similar. There are several flaws in the document, which are discussed in detail in the rest of SAC’s comment document. One major flaw that continually surfaces is the plan has no alternative that addresses repair of resource damage on the routes that will not be designated. It is irresponsible for a land manager to ignore the existing resource damage that is cited as the exact reason for designating routes in the first place. By ignoring the existing damage, and letting it fester, it will only worsen. Without people in vehicles using the routes, the worsening resource damage may even go undetected. The DEIS states in several sections that the specialists are relying on “passive restoration”, which means to just walk away without removing the road or trail template, restoring the drainage regime, encouraging revegetation, or using other active restoration methods. A plan needs to be proposed in the Final EIS that will commit the Forest Service to evaluate the routes that are not designated in the final decision.

So SAC insists that the Forest Service include an alternative that addresses resource damage restoration. This alternative considers issues that are not addressed in any of the existing alternatives. The Forest Service worked with the Wilderness Society to develop Alternative 3, so we are certain that they would want to be consistent with this action and work with SAC to develop Alternative 6. The issues that should be considered in Alternative 6 are:

Alternative 6

Sierra Access Coalition insists the Forest Service add an Alternative 6 for public consideration. The five existing alternatives in the DEIS don’t adequately address all the issues and alternatives that should be considered. Although specific restoration projects are not within the scope of this project, a comprehensive plan to address resource damage that has been caused by past use must be considered. Ignoring the damage and expecting it to return to a natural condition on its own is unreasonable, unscientific, and irresponsible.

Alternative 6, at a minimum, should consider the following points which are not evaluated in any of the five existing alternatives:

• Using the 1109 miles of inventoried routes as a baseline, initially remove only those routes with egregious damage. As budgets allow, the remaining routes should be analyzed annually and the Travel Management Plan could be amended.
• Develop a comprehensive plan for resource damage mitigation or decommissioning on routes that are not being proposed for designation. This would include the creation of a recreation based travel management team composed of one OHV specialist from each district, possibly funded by green sticker grant funds.
• Until a route is identified for decommissioning it must be left on the transportation system.
• The public needs to be informed annually which routes are being proposed for closure or decommissioning. These actions must no longer be “buried” in large unrelated project proposals, as they have been in the past, but must be proposed categorically under travel management resource restoration projects so the proposals are readily evident to the public.
• This alternative must provide a balanced recreation experience for all OHV vehicle types and skill levels.
• Each major community on the Plumas NF must have an open riding area (approx. 80+ acres) within a 20 minute drive. In the past, this was an “open forest” and each community had motorized recreation opportunities adjacent to them. The other alternatives eliminate that historical use. Include communities such as Quincy, Indian Valley, Chester, LaPorte, Portola, Graeagle, Oroville, Paradise, and others .
• Continuous routes that consist of a combination of county and sytem roads should be consistent with county road use, to allow uninterrupted loop opportunities for green sticker vehicles.
• The California Highway Patrol must be the agency with authority to interpret the California Vehicle Code as it pertains to forest maintenance level 3 roads. The CHP has jurisdiction and the Forest Service needs to accept their interpretation.
• Cross country travel must be allowed for direct access to dispersed campsites with no distance limits.
• Access to firewood trees must be allowed.
• Access for the disabled and elderly must be analyzed.
• A map is attached (see Exhibit 1.1) that displays all routes that need to be included in Alternative 6 and need to be analyzed. It shows routes that were not analyzed in red. We labeled as many routes as we could using the GIS data supplied. However for the routes in red that do not have identifiers on them we are unable to cross reference to the spreadsheets that were supplied. The attached spreadsheet (Exhibit 1) has the route numbers that we believe were not analyzed.

SAC believes Alternative 6 would be the best alternative for addressing cumulative effects on the environment because it would address the mitigation or restoration of resource damage. With a quality, well managed plan, the user groups are going to be more likely to continue volunteering for mitigation and trail maintenance needs.