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Old 07-16-2010, 01:49 PM
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Exclamation How NON-Motorized activists will restrict Snowmobile access to US Forest Service Land

July 15, 2010
Now This Is Scary

//www.snowest.com/news/index.cfm?ID=2482
If you thought that environmental groups and their allies in Congress would be happy with just locking up vast in Wilderness to eliminate motorized recreation, boy were you wrong.

We received an e-mail today titled: Petition to Remedy Snowmobile Exemption from Travel Management Rule. It is being circulated by the Winter Wildlands Alliance.

Here is an excerpt from the e-mail that is being circulated nationwide. I am emailing with the hope that you and your organization will sign on to the attached petition asking the Department of Agriculture to remove the over-snow vehicle (OSV) exemption from the 2005 Travel Management Rule and thereby bring snowmobiles and other OSVs under the same management standards as other classes of off-road vehicles. The 2005 Travel Management Rule restricts off-road vehicle use to designated routes, trails and areas on National Forest System lands.”

With the e-mail there is an attachment (see the attached PDF) that goes into great detail about what the Winter Wildlands Alliance (along with anyone else who will sign on) is proposing. In short, they want to eliminate cross country travel from all national forest lands.

Go ahead and have a look. It might just ruin your whole day.

Stay alert sledders and be involved in keeping public lands open to the public and not restricted to a select few.

Last edited by mountainhorse; 07-22-2010 at 12:53 PM.
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Old 07-16-2010, 01:51 PM
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-- DRAFT --
July 8, 2010

PETITION TO AMEND THE 2005 TRAVEL MANAGEMENT RULE BY REMOVING THE OVER-SNOW VEHICLE EXEMPTION AND REMEDYING THE DISCRETIONARY MANAGEMENT OF OVER-SNOW VEHICLES ON NATIONAL FOREST SYSTEM LANDS

Submitted By:
Winter Wildlands Alliance, with
[list of co-signing organizations]

Petition to Remove OSV Exemption and Remedy Discretionary Management of OSVs – Draft 2

TABLE OF CONTENTS
INTRODUCTION 3
BACKGROUND ON OVER-SNOW VEHICLES AND THE TRAVEL
MANAGEMENT RULE 3
Legal Background and Argument 5
Policy Background and Argument 8

RELIEF REQUESTED 12
IMPACTS FROM OVER-SNOW VEHICLES 15
ENVIRONMENTAL IMPACTS SUMMARY 15
Air and Water Quality 16
Soil and Vegetation Damage 16
Noise Pollution 16
Wildlife Disturbance 17

TRAVEL PLANNING AND CLIMATE CHANGE 19

PUBLIC SAF ETY 20

CONFICTS WITH OTHER RECREATIONISTS 21

CONCLUSION 27

References 28
Appendices:
Appendix A List of Petitioners
Appendix B Winter Recreation on Western National Forest Lands Report
Appendix C Environmental Impacts from Over-Snow Vehicle Use
Appendix D Documentation of User Conflict Due to Over-Snow Vehicle Use
Petition to Remove OSV Exemption and Remedy Discretionary Management of OSVs – Draft 3
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Old 07-16-2010, 01:51 PM
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INTRODUCTION
On behalf of the ___ organizations (hereafter “Petitioners”) (See Appendix 1) representing a
combined membership of more than ___ million members, we congratulate the United States
Department of Agriculture (USDA) and United States Forest Service (USFS) on significant
progress in implementing the 2005 Travel Management; Designated Routes and Areas for Motor
Vehicle Use Rule (CFR Parts 212, 251 and 261) and in your good faith efforts to protect our
National Forest System (NFS) lands and waters from the negative impacts of off-road vehicles
(ORV).

In recognizing the progress made through the 2005 Travel Management Rule in managing
wheeled ORV use, the Petitioners call upon the USDA and USFS to apply management
standards to over-snow vehicle (OSV) use that are consistent with standards for other classes of
ORVs and that meet the criteria of the Executive Orders which the 2005 Rule is intended to
implement. Petitioners assert that USDA and USFS have a legal obligation to amend the Rule as
requested in order to protect America’s National Forest resources, including clean air and water,
quiet, wildlife, soils, vegetation, and non-motorized recreationists, from the substantial adverse
impacts of OSV use.

We hereby petition the U.S. Department of Agriculture to amend the 2005 Travel Management;
Designated Routes and Areas for Motor Vehicle Use Rule (CFR Parts 212, 251 and 261) by
removing the OSV exemption (36 CFR Part 212.51(a)(3)) and remedying the language making
the management of OSVs a discretionary decision of the local responsible official. (36 CFR Part
212.81) This Petition for Rule Change is filed pursuant to 5 U.S.C. § 553(e).
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Old 07-16-2010, 01:53 PM
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BACKGROUND ON OVER-SNOW VEHICLES AND THE TRAVEL MANAGEMENT
RULE

In 1972 President Nixon issued Executive Order 11644 (later amended by President Jimmy
Carter with Executive Order 11989) in order to “establish policies and provide for procedures
that will ensure that the use of off-road vehicles on public lands will be controlled and directed
so as to protect the resources of those lands, to promote the safety of all users of those lands, and
to minimize conflicts among the various uses of those lands.
” (E.O. 11644, Sec. 1)

Since that time, the USFS has regulated the use of all ORVs, including snowmobiles and other
OSVs, on national forest lands on the basis of a uniform set of standards. However, in December
2005 the USDA repealed the regulations (former 36 CFR Part 295) that, based on E.O. 11644
and E.O. 11989, provided for this uniform system of regulation (70 FR 68264) and published
final rulemaking (70 FR 682684) to promulgate revised regulations governing travel
management on National Forest System lands (hereinafter referred to as “the 2005 Travel
Management Rule” or “Rule.” The 2005 Rule requires the USFS to designate NFS roads, trails,
and areas that are open to motor vehicle use and to identify such on a Motor Vehicle Use Map.
(36 CFR Parts 212.51 and 212.56)

The explanatory discussion that accompanies the publication of the Rule in the Federal Register
makes an eloquent case for the need to manage all off-road vehicles on NFS lands, stating,
“…the magnitude and intensity of motor vehicle use have increased to the point that the
intent of E.O. 11644 and E.O. 11989 cannot be met while still allowing unrestricted
cross-country travel. Soil erosion, water quality, and wildlife habitat are affected. Some
National Forest visitors report that their ability to enjoy quiet recreational experiences is
affected by visitors using motor vehicles. A designated and managed system of roads,
trails, and areas for motor vehicle use is needed.” (70 FR 68265)

Furthermore, the background discussion acknowledges,
[s]nowmobiles are ‘off-road vehicles’ under E.O. 11644 and subject to the direction to
‘provide for administrative designation of the specific areas and trails on public lands on
which the use of off-road vehicles may be permitted, and areas in which the use of offroad
vehicles may not be permitted’ (E.O. 11644, Sec. 3(a)). Moreover, snowmobiles are
‘motor vehicles’ under this final rule
. Since the Rule regulates motor vehicle use, the rule
must address snowmobiles
.” (70 FR 68273)

The Department acknowledges that E.O.s 11644 and 11989 cover all motor vehicles used offroad
and do not distinguish between winter and summer and that the Rule must address
snowmobiles. However, the rule writers seem to contradict their own logic by concluding:
“…the Department believes that cross-country use of snowmobiles presents a different
set of management issues and environmental impacts than cross-country use of other
types of motor vehicles.

Therefore, the final rule exempts snowmobiles from the mandatory designation scheme
provided for under § 212.81, but retains a manager’s ability to allow, restrict, or prohibit
snowmobile travel, as appropriate, on a case-by-case basis (§ 212.81). (70 FR 68273).”

Although the Rule summary states that the Rule is “consistent with provisions of Executive
Order 11644 and Executive Order 11989 regarding off-road use of motor vehicles on Federal
lands,” (70 FR 68264) Petitioners assert that the Rule is flawed insofar as it exempts
snowmobiles and other OSVs from the mandatory designation scheme provided under Part
212.51 and applies the designation criteria only when over-snow vehicle use is restricted or
prohibited. A different set of management issues and environmental impacts does not justify the
decision of the Department to repeal standards for the use of snowmobiles that were formerly in
36 CFR Part 295 without establishment of a replacement set of standards.

Importantly, the Rule contains no standards to guide land managers in their decision whether to
allow OSV use. In other words, the regulation contains within it a clear preference or bias in
favor of continued unrestricted OSV use. See Nat’l Wildlife Fed’n v. Morton, 393 F.Supp. 1286,
1292 (holding BLM’s implementing regulations invalid because they created a “subtle, but
nevertheless real, inertial presumption in favor of ORV use”). This is a clear violation of the
ORV Executive Orders, which in fact require that impacts be minimized from designating ORV
(which, by definition, includes OSVs) trails and areas, not somehow minimized only when
prohibiting their use.

The Rule further directs the responsible official to consider “sound emissions and other factors
including “[s]peed, volume, composition and distribution of traffic on roads;” (36 CFR § 212.55)
Petitioners assert that all of these criteria apply equally to OSV use as to other classes of ORVs
and should not depend on a discretionary decision by the responsible official to prohibit OSV use
before the criteria are considered.

In addition, the Rule introduces an entirely new definition of “over-snow vehicle.” The rulewriters,
“[I]n order to improve clarity and ensure equitable treatment of over-snow vehicle use,”
(70 FR 68273) define over-snow vehicles to include not only snowmobiles but also snow-cats,
snow groomers and treaded ATVs
. While such clarity is warranted, the fact remains that these
additional vehicles are now also excluded from the mandatory regulatory framework of the Rule.
Petitioners assert that this exclusion of OSV use from the requirements imposed on other
motorized uses of NFS lands is in direct contradiction to the Executive Orders which the Rule is
intended to implement, as well as the statutory requirements of the National Forest Management
Act and other laws mandating the protection and sustainable management of NFS lands and
resources, including vegetation, wildlife, water, and air quality, and must be remedied
immediately.

Legal Background and Argument
The Rule summary published in the Federal Register states that the Rule is “consistent with
provisions of Executive Order 11644 and Executive Order 11989 regarding off-road use of
motor vehicles on Federal lands.” (70 FR 68264) However, Petitioners assert that insofar as it
exempts snowmobiles and other OSVs from the mandatory designation scheme provided under
36 CFR 212.51 and applies the designation criteria only when over-snow vehicle use is restricted
or prohibited, the Rule is arbitrary, capricious, an abuse of discretion, or otherwise not in
accordance with law within the meaning of these terms as they are used in the federal
Administrative Procedure Act (APA) (5 U.S.C. §§ 701-706).

The 2005 Rule requires the Forest Service to address the issue of motor vehicle use on NFS
lands. (“motor vehicle use on National Forest System roads, on National Forest System trails,
and in areas on National Forest System lands shall be designated.” 36 CFR 212.51(a) (emphasis
added
). Over-snow vehicles were specifically exempted from this provision. (36 CFR
212.51(a)(2)) In contrast to this requirement for a mandatory evaluation of the impacts from
summer motor vehicle use, the language that addresses use of over-snow vehicles frames the
process as optional and states “If the responsible official proposes restrictions or prohibitions
on use by over-snow vehicles under this subpart, the requirements governing designation of
National Forest System roads, National Forest System trails, and National Forest System lands
in §§ 212.52, 212.53, 212.54, 212.55, 212.56, and 212.57 shall apply to establishment of those
restrictions or prohibitions.” (36 CFR 212.81(c) (emphasis added). So, even though over-snow
vehicles have an undeniable impact on forest resources and users as described in detail later in
this petition, the 2005 Rule fails to require that the Forest Service ever address this issue: (“the
Department is preserving the authority currently in part 295 to allow, restrict, or prohibit use by
over-snow vehicles, including snowmobiles, on a discretionary basis in part 212, subpart C.”
(70 FR 68284) emphasis added)) This omission is a clear violation of the ORV Executive Orders
that the 2005 Rule was intended to implement, and as such should be remedied immediately.

As justification for the OSV exemption, the Department offers only that it “believes that crosscountry
use of snowmobiles presents a different set of management issues and environmental
impacts than cross-country use of other types of motor vehicles” and “[t]herefore, the final rule
exempts snowmobiles from the mandatory designation scheme provided for under 36 CFR Part
212.81, but retains a manager’s ability to allow, restrict, or prohibit snowmobile travel, as
appropriate, on a case-by-case basis (36 CFR 212.81).” (70 FR 68273) Petitioners assert that the
similarities between OSV management issues and environmental impacts and those presented by
other classes of ORVs overwhelmingly outweigh the differences between these factors. Within
wheeled ORVs there are many different management issues as well. At any rate, a different set
of management issues and environmental impacts does not justify the decision of the Department
to repeal in their entirety standards for the use of snowmobiles that were formerly in 36 CFR Part
295, without establishment of a replacement set of standards, thus creating a framework in which
OSVs are not subject to any mandatory regulatory standards at all.

For the following reasons, petitioners assert that insofar as the 2005 Rule 1) exempts OSVs from
the mandatory designation scheme and 2) puts off the application of the ORV Executive Orders
to OSV use until a local responsible official decides in his or her discretion to “restrict or
prohibit” OSV use under 36 CFR Part 212.81(c), the 2005 Rule is both a) in direct conflict with
the ORV Executive Orders, and b) arbitrary and capricious for purposes of the APA.
With respect to the ORV Executive Orders:

(1) OSVs are “off-road vehicles” within the definition in the Executive Orders.
Section 2 of Executive Order 11644 states: “‘off-road vehicle’ means any
motorized vehicle designed for or capable of cross-country travel on or
immediately over land, water, sand, snow, ice, marsh, swampland, or other natural
terrain.” Thus, the E.O.s apply with equal force and to the same extent to OSVs as
they do to other classes of ORVs included in the definition.

(2) The Executive Orders require promulgation of regulations “to provide for
administrative designation of the specific areas and trails on public lands on
which the use of off-road vehicles may be permitted, and areas in which the use of
off-road vehicles may not be permitte
d…” While the 2005 Rule complies with
this requirement of the E.O.s with respect to wheeled ORVs, its exemption at §
212.5(a)(2) of OSVs from the Rule’s designation scheme places the 2005 Rule
into direct conflict with this requirement with respect to OSVs.

(a) In particular, the exemption of OSVs from designation requirements of the
completely free from application of the standards set forth in the E.O.s for
permissible ORV use: “Those regulations shall direct that the designation of
such areas and trails will be based upon the protection of the resources of the
public lands, promotion of the safety of all users of those lands, and
minimization of conflicts among the various uses of those lands.
The
regulations shall further require that the designation of such areas and trails
shall be in accordance with the following --

1. Areas and trails shall be located to minimize damage to soil, watershed, vegetation, or other resources on public lands.

2. Areas and trails shall be located to minimize harassment of wildlife or significant disruption of wildlife habitats.


3. Areas and trails shall be located to minimize conflicts between offroad vehicle use and other existing or proposed recreational uses of the

same or neighboring public lands, and to ensure the compatibility of such uses with existing conditions in populated areas, taking into
account noise and other factors.”


(3) In addition to the mandatory minimization criteria, the E.O.s require public
involvement, enforcement, monitoring and immediate closure of areas or trails
where a respective agency head “determines that the use of off-road vehicles will
cause or is causing considerable adverse effects on the soil, vegetation, wildlife,
wildlife habitat or cultural or historic resources…
” The Department’s decision in
the 2005 Rule to exempt OSVs from all of these requirements unless a local
responsible official makes the discretionary decision to restrict or prohibit OSV
use represents a clear violation of the Executive Orders. 1

For these reasons and the many other reasons described throughout this petition, the
Department’s repeal of Part 295 combined with its exemption of OSVs from the mandatory

1 The treatment that the 2005 Rule gives to OSVs contains many similarities to the implementing regulations
promulgated by the Bureau of Land Management (BLM) that the U.S. District Court for the District of Columbia set
aside as in violation of the Executive Orders in the case of Nat’l Wildlife Fed’n v. Morton, 393 F.Supp. 1286
(D.D.C. 1975). First, like the invalid BLM regulations, the OSV exemption in the 2005 Rule creates an “open” until
“closed” regulatory framework for OSVs. The court in the NWF case found that such a framework creates an illegal
“inertial presumption” in favor of OSV use. See id. at 1292. As described in the NWF case, the Executive Orders
“manifestly contemplate[] evaluation of the land not only for purposes of restricting ORV use but also for
designation of areas on which the use of off-road vehicles may be permitted.” Id. (emphasis in original). The OSV
exemption in the 2005 Rule impermissibly restricts evaluation of OSV use to those situations in which the
“responsible official proposes restrictions or prohibitions.” 36 CFR § 212.81(c). Second, the discretionary nature of
whether a responsible official will propose restrictions or prohibitions violates the Executive Orders because “[l]and
which the authorized officer does not choose to designate or redesignate as closed or restricted may never be
evaluated for designation,” failing to ensure that all public lands will be evaluated and designated in accordance with
Section 3(a) of the E.O. Id. at 1294. Third, if a responsible official indeed decides, in his or her discretion, to
restrict or prohibit OSV use, thereby subjecting the designation to 36 C.F.R. § 212.55(b), the Forest Service has
impermissibly “diluted the standards emphatically set forth in Executive Order 11644.” See id. at 1295. In fact,
because the 2005 Rule excludes an entire class or category of ORVs, namely, OSVs, from its mandatory regulatory
standards, the case can convincingly be made that the 2005 Rule violates the E.O.s in respects that greatly exceed in
severity the grounds on the basis of which the court in the NWF case felt compelled to invalidate the rules before it.


regulatory standards in the 2005 Rule violate the Executive Orders, necessitating their
replacement with legally valid OSV regulations.

With respect to the issue of whether the 2005 Rule is “arbitrary and capricious” within
the meaning of those terms as they are used in the APA:

(1) Appendix D attached to this petition presents abundant, peer-reviewed scientific
evidence documenting the adverse effects of snowmobile use on the natural
environment.
This evidence conclusively demonstrates that, while the effects of
OSV use on the natural environment may be somewhat different in kind as compared
to the effects of wheeled ORVs, it is no less significant in degree or severity. In light
of this evidence there is no rational basis for the Department’s conclusion in the 2005
Rule that a repeal of the existing standards for OSV use in Part 295 combined with a
total exemption of OSVs from the mandatory standards of the Rule are justified on
the basis of a finding that “cross-country [i.e., off-road] use of snowmobiles presents
a different set of management issues and impacts than other types of motor vehicles.”
As a result, the repeal of Part 295 combined with the OSV exemption in the 2005
Rule are “arbitrary and capricious” for purposes of the APA.

(2) Appendix E attached to this petition presents numerically abundant, first-person
accounts of on-the-ground experiences of backcountry and Nordic skiers and other
non-motorized winter recreationists that provide extensive documentation of conflicts
between such users of National Forest lands and recreational snowmobilers
. This
evidence conclusively demonstrates that the management issue of conflict between
and adverse impact upon various groups of recreational users of NFS Lands is
literally identical with respect to winter recreationists as compared to their summer
counterparts. In light of this evidence there is no rational basis for the Department’s
conclusion in the 2005 Rule that a repeal of the existing standards for OSV use in Part
295 combined with a total exemption of OSVs from the mandatory standards of the
Rule are justified on the basis of a finding that “cross-country [i.e., off-road] use of
snowmobiles presents a different set of management issues and impacts than other
types of motor vehicles.” As a result, for this reason as well, the repeal of Part 295
combined with the OSV exemption in the 2005 Rule are “arbitrary and capricious”
for purposes of the APA.

For these reasons and the many other reasons described throughout this petition, the
Department’s repeal of Part 295 combined with its exemption of OSVs from the mandatory
regulatory standards in the 2005 Rule are “arbitrary and capricious” under the APA,
necessitating their replacement with legally valid OSV regulations.

Policy Background and Argument
In an effort to determine the rationale for the OSV exemption and discretionary authority
regarding management of OSVs in the 2005 Rule, Winter Wildlands Alliance submitted a
Freedom of Information Act (FOIA) request in February 2008 asking for “draft documents,
minutes or notes of all meetings, including the names of those in attendance, interagency and
intra-agency memoranda, and any documents you may have, from any source, that contain
discussions, instructions or otherwise direct the U.S. Forest Service how to proceed in:

• determining the final language of the following: Part 212—Travel Management:
o Subpart A, section 212.1 Definitions: “Over-snow vehicle” (entire definition)
o Subpart C (all)
• reasons for including Subpart B, section 212.51(a)(3)
• determining the final language of the following: Part 261—Prohibitions:
o Subpart A, section 261.14 (all)
o Subpart A, section 261.13(c)”

The USFS response included a Content Analysis Team “Summary of Public Comment” report
and a September 2000 General Accounting Office Report to Congressional Requesters titled
“Agencies Need to Assess the Impact of Personal Watercraft and Snowmobile Use,” but shed
little light on the rationale for the OSV exemption. Other than the reports mentioned above, of
the 52 pages released, 20 pages were withheld in their entirety and nine more pages withheld in
part citing Exemption 5 of the FOIA, the deliberative process privilege. An additional eight
pages referred to the Office of General Counsel for the U.S. Department of Agriculture were
withheld in their entirety citing attorney work-product privilege. Those pages released pertained
almost entirely to the mechanics of the OHV National Policy Team.

Just as the FOIA request yielded no substantive information regarding the rationale behind the
OSV exemption, there is no transparency in the rulemaking process. Furthermore, the nominal
justification offered for the decision to treat OSVs differently from other classes of ORVs is both
contradictory and in violation of the Executive Orders which the 2005 Rule is intended to
implement. As a policy matter, the distinction made between summer and winter use for the
mandatory designation scheme of roads, trails and areas open to motorized use was arbitrary and
against the manifest weight of the evidence.

Because of the noise and noxious exhaust fumes they emit, as well as their potential to inflict
serious injury in the event of a collision, OSVs are indistinguishable from other ORVs in terms
of their adverse impacts on non-motorized users of NFS lands.
The fact that snowmobile tracks
are not “permanent” (because snow melts) is irrelevant if while they exist they have adverse
impacts to other recreationists in the form of scarring the visual landscape and creating
hazardous ruts and ridges when the snow melts and refreezes. Similarly, as documented in the
Environmental Impacts section below and in Appendix D, snowmobiles have adverse impacts on
water quality, wildlife and wildlife habitat that are no less severe than those caused by other
ORVs.
And when snowmobiles are used in areas with inadequate snow cover – a common
practice – they do have a “direct impact on soil and ground vegetation.” In short, the similarities
and parallels between snowmobiles and other ORVs in terms of their impacts on the natural
resource values far outweigh the differences between them.
Certainly, OSV management should
not have been made contingent on a discretionary decision by the local responsible official
because adverse impacts are occurring now.

While there may be differences in the effects and management needs related to OSVs as opposed
to other classes of ORVs, USDA and USFS have never denied that OSVs cause significant
environmental impacts, nor could they. Moreover, the Department did not explain the difference
in management needs when promulgating the 2005 Rule. Information used to arrive at this
decision should have been disclosed to the public. In any event, a difference in management
needs should not have resulted in a wholesale abdication of the Agency’s duties under the
Executive Orders.

The Environmental Protection Agency, in its review of Travel Management Plans in accordance
with NEPA and the Clean Air Act, routinely points out the need for including over-snow
vehicles in the Travel Planning process. As an example, a June 29, 2007 EPA comment letter on
the Environmental Impact Statement for the proposed Designated Route and Motorized Use
Plan, Nez Perce National Forest, Idaho states, “EPA’s primary concerns are focused on the
following topics: exclusion of over-snow vehicles from the planning effort, road maintenance
and density, road closure/obliteration procedures, and road impacts to water quality impaired
streams and other sensitive areas.” (See Appendix B)

The EPA comment letter on the Nez Perce Plan goes on to address specific resource-related
concerns with the exclusion of OSVs from the planning effort:

“Purpose and Need
In identifying the purpose and need for the EIS, the NOI notes that
over-snow vehicles will be exempted from the planning process. EPA
recognizes that this is consistent with direction in the Final Travel
Management Rule at 36 CFR 212.51. We also note, however, that per
subpart C of the rule, local Forest Service officials retain authority to
manage use by over-snow vehicles to address local situations and
concerns and may establish restrictions based on the season of use or
local snow conditions that might not make sense nationally. The current
planning effort presents a unique opportunity to address over-snow
recreation on the Nez Perce National Forest in a holistic way, and we
encourage the Forest Service to include over-snow trails and use zones
on the motor vehicle use (MVU) maps. Snow compaction often retards
the melting of snow, leading to muddy trails and roads which are then
susceptible to damage and enlargement. Additionally, compaction can
lead to altered melting and discharge regimes, further increasing soil
erosion (Montana Fish, Wildlife & Parks 1993). Given the potential for
cumulative impacts, motorized wintertime trail use should be considered
together with motorized trail use in other seasons, and consideration
should be given to whether roads designated for wintertime use have the
necessary drainage features or sediment buffering devices to withstand
heavy or light spring traffic without delivering sediment to streams.

Other environmental impacts related to over-snow use that should be
considered as routes are designated include impacts to air quality,
sensitive vegetation, and wildlife. Snowmobile (and ATV) 2-stroke
engines mix the lubricating oil with the fuel and both are expelled as part
of the exhaust, and allow up to one third of the fuel delivered to the
engine to be passed through the engine and into the environment
virtually un-burned. As stated in the U.S. Department of the Interior
document, Air Quality Concerns Related to Snowmobile Usage in
National Parks, Feb. 2000, hydrocarbon emission rates from 2-stroke
snowmobile engines are about 80 times greater than those found in a
1995-96 automobile engine. A majority of these hydrocarbons are
aromatic hydrocarbons, including polyaromatic hydrocarbons, which are
considered to be the most toxic component of petroleum products. Care
should be taken to limit the exposure of trail users to these compounds,

particularly in areas of mixed use (recreationists on foot, snow shoes, or
skis tend to spend more time in a given area than recreationists utilizing
motorized vehicles).

In order to protect sensitive alpine vegetation, we recommend
consideration of a policy that prohibits off-trail snowmobile use until at
least 6 inches of snow has accumulated. Snow in alpine areas is highly
susceptible to wind movement which can leave bare or thinly covered
areas that would be difficult or impossible to avoid given the speed of
snowmobiles.
Also, the EIS should disclose areas that contain sensitive
vegetation and how the impacts to these plant species will be avoided or
minimized.

Finally, the EIS should also disclose potential impacts to wildlife
from noise and potential displacement of wildlife from habitat in areas
open to motorized use. Special consideration should be given to elk
winter range habitat, and to the lynx, which may be outcompeted by the
coyote and bobcat when it loses its advantage in deep, uncompacted
snow (Koehler and Brittell 1990). “

It should be noted that the OSV impacts and management issues relative to OSV use highlighted
in these EPA comments occur on all NFS units where OSV use occurs. The Petitioners concur
with EPA’s assertion that the development of Travel Management Plans and Motor Vehicle Use
Maps present a unique opportunity to address over-snow recreation in a holistic way. Removal of
the OSV exemption and the discretionary clause from the Rule will ensure that holistic oversnow
recreation management is achieved system wide.

The social conflict dimension with respect to OSV use is well documented. The most telling
characteristic of the conflict between motorized and non-motorized recreationists is that the
impacts fall disproportionately on one type of forest user. That is, the presence of a few skiers,
snowshoers, snowboarders, climbers, winter hikers, hunters or anglers does not diminish the
recreational experience of snowmobilers, while the noise, exhaust, tracks and speed of just one
snowmobiler may significantly degrade the experience of many quiet recreationists over the
many miles traveled by that one snowmobiler in a comparatively short time period.


Furthermore, current management of OSVs on NFS lands is woefully out of balance with actual
forest use
. A 2006 Winter Wildlands Alliance report, Winter Recreation on Western National
Forest Lands, analyzes USFS data on winter visitor use and confirms that even though
snowmobiles represent 22 percent fewer annual visits than cross-country skiers and snowshoers,
OSV use nonetheless dominates 70 percent of national forest lands and 90 percent of groomed
winter trails in the 11 Western Snowbelt states (See Appendix C). Though the report focuses on
the Western states, available data from other regions confirm that the trend is consistent across
the American Snowbelt. The 2005 Travel Management Rule, because of its exemption of OSVs,
represents a missed opportunity to correct this imbalance. It also represents a missed opportunity
to engage both motorized and non-motorized user groups in arriving at collaborative solutions to
winter management. Petitioners urge the USFS to correct this imbalance by removing 36 CFR
Part 212.51(a)(3) and remedying the language making the management of OSVs a discretionary
decision of the local responsible official. (36 CFR Part 212.81)
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RELIEF REQUESTED
The Petitioners commend the USDA and USFS on implementing the 2005 Travel Management
Rule with respect to wheeled ORV use and we assert that the Department and Agency have a
legal obligation to apply management standards to over-snow vehicle (OSV) use that are
consistent with standards for other classes of ORVs and that meet the criteria of the Executive
Orders which the 2005 Rule is intended to implement in order to protect and preserve America’s
National Forest System resources, including clean air and water, quiet, wildlife, soils, vegetation,
and non-motorized recreationists, from the substantial adverse impacts of OSV use. The
Petitioners seek the following relief:

First, the Petitioners request that the Department remove the over-snow vehicle
exemption (36 CFR § 212.51(a)(3)) and all of Subpart C—Use by Over-Snow Vehicles (36 CFR
§ 212.80 and 212.81) with the exception of the final sentence, which reads “In establishing
restrictions or prohibitions on use by over-snow vehicles, the responsible official shall recognize
the provisions concerning rights of access in sections 811 (b) and 1110(a) of the Alaska National
Interest Lands Conservation Act (16 U.S.C. 3121(b) and 3170(a), respectively).” The Petitioners
suggest this sentence could be added as (c) at the end of § 212.51. In accordance with the above
changes, Petitioners request the Department also remove references to over-snow vehicles at
CFR § 261.13(c) and all of § 261.14 “Use by over-snow vehicles.”

Second, the Petitioners request that the USFS issue clear directives and guidelines as to
how NFS units should implement Winter Travel Management Planning. The Petitioners request
that the following issues and recommendations be addressed in the Winter Travel Management
Planning guidelines:

a) Criteria for which NFS units must implement winter travel management
planning.
The USFS should issue guidelines to set criteria for determining which
NFS units would be mandated to implement Winter Travel Management
Planning. The Petitioners suggest that all forests where documented OSV use
exists on any part of the unit be directed to implement Winter Travel Management
Planning. Travel Management Plans for areas with known sporadic, intermittent,
and/or minimal average snowfall but no documented OSV use should nonetheless
proactively include direction regarding winter OSV use. Proactive management
will avoid creating gaps in TMPs and setting false expectations for OSV use in
low snow areas that may occur only during above average snow seasons.

b) Minimum snow depths and seasonal closures. Regulations requiring minimum
snow depths for OSV use should be established and enforced to protect water
quality, soil, vegetation, and wildlife habitat. To do so, it may be necessary to
analyze and adopt seasonal closure dates and mandatory closure triggers based on
snow depths and wildlife factors. All winter plans must state that it is illegal to
drive OSVs on any bare ground and across vegetation of any type. Plans must
also state that it is the operator's responsibility to make sure their OSV tread does
not penetrate through the snow to the point where it touches dirt or vegetation.

c) Preserving quiet as a landscape characteristic. The background discussion to
the 2005 Rule notes that “[n]oise is a particularly important issue affecting OHV
use nationally,” and that “[t]he Forest Service anticipates developing a national
standard for OHV noise levels in future rulemaking.” (70 FR 68271) Winter
conditions and acoustics exacerbate the noise issue. Preserving quiet as a
landscape characteristic should be a centerpiece of Winter Travel Management. It
is well documented that sound travels farther in colder temperatures, across snow,
and when there is less vegetation cover. All of these conditions are present in the
winter months. Acoustic scientists and other researchers are actively developing a
greater understanding of the effects of noise on wildlife and the public. NFS
lands should provide an opportunity to escape the artificial sounds of everyday
life and offer a chance to listen to the natural sounds of nature. Therefore, as a
component of Winter Travel Management Planning, the USFS should carry out
thorough acoustic and soundscape research and analysis, set OSV noise emission
restrictions, and establish quiet zones in order to protect wildlife and the
experiences of public land visitors.

d) Public Input. For each winter TMP the USFS should convene and facilitate an
initial dialogue among diverse winter recreation groups to bring issues to the table
and set an action plan in motion to develop winter recreation management
decisions that protect natural resources and are fair to all winter recreationists.

e) Quiet Recreation Opportunities: In addition to providing motorized
opportunities, NFS units where OSV use occurs should provide accessible terrain
and a variety of high-quality, quiet recreation opportunities for non-motorized
snow-based recreation. Under most current management plans, opportunities for
OSV use far exceed opportunities for quiet winter recreation. Winter TMPs
should correct this imbalance. In addition, wherever possible, parking lots,
trailheads and staging areas for motorized use should be separated from those for
quiet use (non-motorized). NFS units should seek to designate non-motorized
winter recreation areas with a variety of terrain that are easily accessible
(generally within three to five miles of adequate parking) by human-powered
users.

f) Designated areas and cross-country OSV travel. By directing each NFS unit to
designate “roads, trails and areas” for motor vehicle use, the 2005 Rule includes a
tool for allowing cross-country OSV travel in appropriate areas. The Rule defines
“area” as “[a] discrete, specifically delineated space that is smaller, and in most
cases much smaller, than a Ranger District.” (§ 212.1) Areas designated for OSV
use on Winter Motor Vehicle Use Maps should be clearly defined using existing
and easily enforceable physical boundaries such as ridges, creeks, fences, roads,
etc. in order to facilitate adherence and enforcement. The 2009 Lewis and Clark
National Forest Little Belt, Castle and Crazy Mtn Over-The-Snow Motor Vehicle
Use Map provides an excellent example of how to designate these areas.

g) Monitoring and Enforcement: When OSV routes, trails and areas are
designated, the NFS unit should include in the implementation plan an adaptive
monitoring and enforcement plan with specific thresholds that once met or
surpassed trigger automatic mitigation efforts, including closure to OSV use
and/or adjustments to boundaries of open areas and designated routes and season
of use designations. Changes in resource needs, such as newly listed species or
changes in habitat use by listed species or species of concern should also be
considered in monitoring ongoing effects of winter recreation. The NFS unit
should also demonstrate that there are adequate resources to implement all aspects
of a plan prior to designating areas or routes open to OSV use. Resource-intensive
activities like OSV use should be realistically tailored to the current and
foreseeable budgets for designation, implementation, and enforcement.

h) Consistent standards for managing agency-recommended wilderness. All
NFS units should apply consistent standards in managing agency-recommended
wilderness areas. In order to preserve wilderness character, no OSV use should be
authorized in recommended wilderness areas or wilderness study areas. For those
few exceptions where existing snowmobile use is grandfathered in to
recommended wilderness or wilderness study areas through legislation (e.g., the
1984 Wyoming Wilderness Act stipulates that “snowmobiling will continue in the
same manner and degree” in the Palisades Wilderness Study Area), NFS units
should restrict OSV use in both scope and volume to the level at the time such
legislation is enacted and should not simply open these areas to unlimited OSV
use.

i) Future Trends. The USFS should take proactive measures to anticipate future
trends and technological innovations in OSVs and other vehicles in order to avoid
new and greater impacts and costly reactive responses. For example, agencies
should only open areas up to specific uses. If new uses evolve, before they are
allowed, the agencies must evaluate their impacts in context of all the ongoing
uses and the potential impacts to forest resources.

j) Adapting to Climate Change. Climate change will amplify the fundamental
need for comprehensive winter travel planning. The continued shrinking of the
winter landscape and snowpack from which to delineate winter recreation uses
will only intensify natural resource impacts and increase user conflicts. Climate
change will likely bring changes to snow elevations and snow lines, snow extents,
snowpack densities and snow moisture content. Climate change is also likely to
be a significant stressor on wildlife, especially those species dependent on snowcovered
winter habitat. Climate science and snowpack forecasting should be
considered by the USFS when prescribing where OSV use is appropriate and
where quiet recreation should be retained or restored. These prescriptions should
also take into account the importance of winter wildlands as wildlife refugia and
important habitat cores in the face of climate change.

Third, the Petitioners request that the USFS issue a timeline for completion of Winter
Travel Management Plans and Over-Snow Motor Vehicle Use Maps on applicable NFS units
similar to the timeline issued with the original 2005 Rule. We suggest a target deadline of five
years from the time the Rule Change is issued for applicable NFS units to complete Winter
Travel Planning. Petitioners also suggest that each Region where OSV use exists establish a
prioritized list and timeline of those NFS units to initiate winter Travel Management and that
each Region identify at least one forest where winter Travel Management will be initiated no
later than within one year of the Rule Change. The Petitioners assert that the broad cross section
of USFS employees and contractors who will have recently completed Summer TMPs and
MVUMs will be a great asset in expediting Winter Travel Planning.

Fourth, adequately fund Winter Travel Management planning and implementation so as
not to detract from other important ongoing USFS planning and implementation.

Time is of the Essence. Petitioners respectfully request a response from USDA and
USFS within 90 days of receipt of this petition.
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IMPACTS FROM OVER-SNOW VEHICLES
ENVIRONMENTAL IMPACTS OF OVER-SNOW VEHICLES

A growing body of scientific evidence indicates significant OSV impacts on animals, plants,
soils, air and water quality, and the ecology of entire winter ecosystems. While the severity of
OSV impacts will differ depending on the site-specific characteristics of an area, OSV use
clearly impacts any winter ecosystem on which it occurs. Appendix D, Environmental Impacts
from Over-Snow Vehicle Use, provides a detailed analysis of these impacts. Following is a brief
summary.


Air and Water Quality
The exhaust from OSVs is known to degrade both air and water quality. Two-stroke engines,
which represent the vast majority of OSV use on NFS lands, are particularly onerous. A twostroke
snowmobile can emit hydrocarbons and nitrogen oxides equivalent to 100 cars and can
create up to 1,000 times more carbon monoxide (EPA, 2002). Two-stroke snowmobile engines
emit dangerous levels of other toxins including nitrogen oxides, carbon monoxide, ozone,
aldehydes, butadiene, benzenes, and extremely persistent polycyclic aromatic hydrocarbons.
Several of these compounds are listed as "known" or "probable" human carcinogens by the EPA.
Winter recreationists are especially at risk because the concentration of these emissions increases
with elevation and cold (Janssen and Schettler, 2003).

Many of these pollutants from snowmobile emissions are stored within the snowpack (Ingersoll,
1998). During spring snowmelt, these accumulated pollutants are released causing elevated
acidity levels in surrounding waterways and resulting in higher death rates for aquatic insects,
amphibians and fish (Charette et al.,, 1990). The associated acidity fluctuations can disable a
watershed's ability to regulate its own pH level, which can trigger system-wide problems and
result in a long-term alteration of an entire ecosystem (Shaver et al.,, 1998).

Soil and Vegetation Damage
Over-Snow Vehicles cause significant damage to both soils and vegetation. Documented impacts
to vegetation from OSVs and the associated snow compaction includes delayed flowering in
plants in spring (Rongstad, 1980), lower soil bacteria (Wanek, 1973), elimination of some plant
species (Rongstad, 1980), inhibited seed germination, dispersal, and growth (Keddy et al. 1979),
abrasion and breakage of seedlings, shrubs, and other exposed vegetation (Stangl, 1999), as well
as treetop damage (WWA, 2009). This degradation of both soil and vegetation often leads to
increased soil runoff resulting in decreased water quality in nearby water bodies (Stangl, 1999).

Noise Pollution
Natural soundscapes are intrinsic elements of the environment and are necessary for natural
ecological functioning (Burson, 2008). Noise from snowmobiles severely affects the winter
soundscape and impacts both wildlife and other visitors. The problem of ORV noise including
OSVs was recognized in Executive Order 11644, which mandates that land management
agencies consider the noise impact on other recreational users when opening areas to ORVs. As
documented in Appendix E, non-motorized winter recreationists report that OSV noise greatly
reduces their enjoyment of recreating on NFS lands and is a leading cause of visitor use conflict.
Animals exposed to high-intensity sounds suffer both anatomical and physiological damage,
including both auditory and non-auditory damage (Brattstrom and Bondello1983). Indirectly,
the noise generated by OSVs can adversely impact animals impairing feeding, breeding,
courting, social behaviors, territory establishment and maintenance, increasing stress, and/or by
making animals or their young more susceptible to predation (Janssen 1978, Weinstein 1978,
EPA 1971, Bury 1978 Jeske 1985, and Vos et al. 1985,).


Wildlife Disturbance
Over-Snow Vehicles can cause mortality, habitat loss, and harassment of wildlife (Boyle and
Samson, 1985; Oliff et al., 1999). While most animals are well adapted to survival in winter
conditions, the season creates added stress to wildlife due to harsher climate and limited foraging
opportunities (Reinhart, 1999). Disturbance and stress to wildlife from snowmobile activities
during this highly vulnerable time is dire. Studies of observable wildlife responses to
snowmobiles have documented elevated heart rates, elevated glucocoritcoid stress levels,
increased flight distance, habitat fragmentation as well as community and population disturbance
(Baker and Bithmann, 2005).

In addition to the direct physiological stress of snowmobiles, evidence suggests that popular
winter trails can fragment habitat and wildlife populations. Winter trails through surrounding
wild areas or other core areas create more “edge effect” (the negative influence of the periphery
of a habitat on the interior conditions of a habitat) and thereby marginalize the vitality of some
species (Baker and Bithmann, 2005).

Ungulates
It has been widely documented that snowmobile activity disturbs wintering ungulates through
physiological stress (Canfield et al., 1999) resulting in increased movements (Dorrance et al.,
1975; Eckstein et al., 1979; Aune 1981, Freddy et al., 1986; Colescott and Gillingham 1998) and
higher energy expenditures (Canfield et al., 1999). The physiological stress from snowmobile
noise produces changes similar to those brought about by exposure to extreme heat, cold, or pain
(EPA, 1971). During winter, when efficient energy expenditure is extremely important to an
animal’s survival, an additional stressor such as noise can throw off an animal’s energy balance
and is a serious threat to predator-prey relationships, mating, and reproduction, raising young,
and staking out territories (EPA, 1971). Animal flight and evasive maneuvers resulting in
significant energy loss from elk, mule deer and other ungulates in response to snowmobiles are
well documented (Aune, 1981).

Indigenous Fish
The most diverse trout species in North America, native cutthroat trout are found along the
Pacific Northwest coast, in the Cascade Range, the Great Basin, and throughout the Rocky
Mountains – all areas of high OSV use. Similarly, bull trout, a threatened species protected under
the Endangered Species Act, depend on cold, clear water and are excellent indicators of water
quality. Many of the high-elevation streams and lakes in the proposed bull trout critical habitat
designation correspond closely with areas of high snowmobile use. These same waterways
provide important habitat for salmon and other native fish species.

A study on the impact of two-stroke emissions on trout, Balk et al., (1994) determined that
hydrocarbons disrupt normal biological functions (e.g. DNA adduct levels, enzyme activity),
including cellular and sub-cellular processes, and physiological functions (e.g. carbohydrate
metabolism, immune system). Serious disruption of trout reproduction and fry survival also
seems likely. (See also, Tjarnlund et al., 1995, 1996). Adams (1975) also found that the
influence of lead and hydrocarbon on stamina, measured by ability to swim against a current,
Petition to Remove OSV Exemption and Remedy Discretionary Management of OSVs – Draft 18
was significantly less in trout exposed to snowmobile exhaust than in control trout; the exposed
trout made fewer tries to swim against the current, and swam for shorter lengths of time before
resting.

Trout can be directly impacted by snowmobile traffic across ice. Snowmobiles riding on top of
ice can disturb trout concentrations in over-wintering areas. These disturbances place high
energy demands on trout, and can be serious in oxygen depleted water (NPS, 2003).

Subnivian Mammals
Many small mammal species depend on the space between the frozen ground and the snow to
live. When snow compaction from snowmobiles occurs, the subnivean (below snow) space
temperatures decrease, which can lead to increased metabolic rates in these small mammal
species. Compaction can also create barriers that restrict movement of these small species that
travel through tunnels in the subnivean space. As the subnivean trails are cut off these small
mammals are forced up to the surface where they are venerable to predation (Canadian Wildlife
Federation, 1998). Compaction can also restrict subnivian mammal movement to the point of
causing asphyxiation, as oxygen flow is restricted and carbon dioxide builds up to deadly levels
(Canadian Wildlife Federation, 1998). A decline in small mammal populations may impact the
many prey species that rely on them resulting in ecosystem level disturbance.

White-Tailed Ptarmigan
White-tailed Ptarmigan reside in alpine areas at or above timberline. They do not migrate and
remain in the alpine tundra above treeline during the winter (Braun et al. 1993). Human
disturbance including snowmobile activity can reduce the availability of winter forage for whitetailed
ptarmigan (Anrews and Righter 1992). In order to protect White-tailed Ptarmigan Braun
(1980) recommends the total exclusion of off-road vehicles from their habitat.

Threatened, Endangered and Rare Species
Over-snow vehicle use has been documented to directly, indirectly, and cumulatively impact
federally protected species. For imperiled species like the grizzly bear, gray wolf, lynx, and
wolverine OSV use can cause disturbance, adversely impact animal energetics, negatively
impact prey/carrion availability, cause habitat abandonment, and can otherwise impact
predator/prey interactions to the detriment of the species.

Canada Lynx: In 2000 the Canada lynx (Lynx canadensis) was listed as a Threatened Species
under the endangered Species Act for the lower 48 states. OSV trails that are created by winter
recreation and forest management activities enable coyotes to access lynx habitat not normally
accessible to them (Koehler and Aubry 1994, Buskirk et al., 2000, Brunnel, et.al., 2006).
Coyotes aggressively compete with, or prey upon, a number of different vertebrate species,
including Canada lynx, that are adapted and limited to deep snow (Buskirk et al., 2000).
Consequently, the presence of OSVs and compacted snow roads on public lands occupied by
lynx are likely to adversely impact the survival and viability of such populations. In an effort to
mediate competition with coyotes, Brunnel et al. (2006) recommends restrictions are placed on
snowmobiles in lynx conservation areas.

Wolverine: Wolverines occur naturally in low densities and are believed to be territorial (WCS,
2007). Wolverine parturition primarily occurs mid-winter during the month of February (WCS,
2007). Six of the seven natal dens located in the Greater Yellowstone Ecosystem by the Wildlife
Conservation Society (2007) were in areas without motorized use, i.e., designated wilderness,
areas inaccessible by vehicle, or national park. Other wolverine biologists have suggested refuge
from human activity is important for wolverine reproduction (Banci, 1994; Magoun and
Copland, 1996). Female wolverines appear to be quite sensitive to human disturbance in the
vicinity of natal and maternal dens, and may abandon dens and move their kits a considerable
distance if they detect human presence in the area (Copeland 1996, Magoun and Copeland 1998).
In a study of wolverines in Idaho, Copeland (1996) concluded that “technological advances in
over-snow vehicles and increased interest in winter recreation has likely displaced wolverines
from potential denning habitat and will continue to threaten what may be a limited resource.”

Wolves: Since wolf survival and production is affected by winter food intake, the availability
and accessibility of prey in winter affects wolf numbers (Nelson and Mech 1986). OSV trails,
whether created by snowmobiles or grooming equipment, may adversely alter predator-prey
dynamics, habitat use, predator and ungulate movement and distribution patterns, thereby
affecting the availability and accessibility of prey to predators, and also affecting community
structure and composition (Paquet et al., 1997). These trails can also facilitate predator
expansion into areas where they are more likely to have negative interactions with humans,
livestock and pets.

Grizzly Bear: The adverse impacts of OSV use, namely snowmobile use and trail grooming, on
grizzly bears are often overlooked. While most direct snowmobile impacts on grizzlies are
limited due to grizzly denning during the peak period of snowmobile use, scientific studies have
made it clear that other indirect impacts are adversely affecting grizzlies. Indirect impacts result
from the altered distribution and movement patterns of large ungulates, particularly bison and
elk, caused by snowmobile trail use (Knight et al., 1984; Mattson, 1997). This leads to a
subsequent decrease in the availability and accessibility of critical grizzly food sources, namely
carrion. In May 2008 U.S. District Judge Donald Malloy ruled that late-season snowmobiling on
the Flathead National Forest negatively impacts grizzly bear habitat when bears are emerging
from their dens and instructed the Forest to curtail spring OSV use (Woody, 2009). This may
also be relevant to other National Forests that provide potential habitat for the future
reintroduction of grizzlies.
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TRAVEL PLANNING AND CLIMATE CHANGE
As noted above, Climate change will amplify the fundamental need for comprehensive winter
travel planning. The continued shrinking of the winter landscape and snowpack from which to
delineate winter recreation uses will only intensify natural resource impacts and increase user
conflicts. Climate change will likely bring changes to snow elevations and snow lines, snow
extents, snowpack densities and snow moisture content. Climate change is also likely to be a
significant stressor on wildlife, especially those species dependent on snow-covered winter
habitat.

Petition to Remove OSV Exemption and Remedy Discretionary Management of OSVs – Draft 20
The Council on Environmental Quality (CEQ) has issued a draft guidance memorandum that
lays out direction for federal agencies to consider climate change impacts under NEPA. The
February 18, 2010 memo from Nancy Sutley, CEQ chair, states that “for Federal actions that
require an EA or EIS, the direct and indirect GHG emissions from the action should be
considered in scoping and, to the extent that scoping indicates that GHG emissions warrant
consideration by the decision maker, quantified and disclosed in the environmental document
(Sutley, 2010).”

Furthermore the December 18, 2009 Notice of Intent for the proposed National Forest System
Land Management Planning Rule lists as one of its Substantive Principles that “Plans could
proactively address climate change through monitoring, mitigation, and adaptation, and could
allow flexibility to adapt to changing conditions and incorporate new information.” (USDA,
2009). Petitioners hold that the same principals should apply to Travel Management Planning,
particularly with respect to OSV use.

Petitioners assert that, under the guidelines above, USFS should consider the effects of and to
climate change in OSV planning efforts or other decisions involving winter uses and that climate
science and snowpack forecasting should be applied when prescribing where OSV use is
appropriate and where quiet recreation should be retained or restored. These prescriptions
should also take into account the importance of winter wildlands as wildlife refugia and
important habitat cores in the face of climate change.
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PUBLIC SAFETY
Snowmobiles are extremely powerful, fast machines that have significant impacts on the safety
of other winter recreationists. Many stock snowmobiles today are built with 120- to 150-
horsepower engines, weigh up to 600 pounds, and can travel at speeds in excess of 100 miles per
hour. At such speeds, a snowmobile will travel 200 feet before being able to come to a stop
(National AG Safety Database). Horsepower and acceleration exceed that of many automobiles
and snowmobile horsepower to weight ratios are equal to or higher than any other class of
motorized vehicles manufactured today.

Excessive speed is responsible for many snowmobile accidents. Snowmobile operators are often
observed traveling dangerously fast on narrow trails despite numerous obstructions and
obstructed visibility.

A study in Alaska by Dr. Michael G. Landen of the New Mexico Department of Health found
that for 1993-1994, the injury death and hospitalization rates were greater for snowmobiles than
for on-road motor vehicles (Landen et al., 1999). During this period, 26 snowmobile injury
deaths were reported in Alaska (16 in northern Alaska alone) for a rate of 27 deaths per 100,000
snowmobiles compared with 176 on-road motor vehicle injury deaths or 17 deaths per 100,000
on-road motor vehicles per year. This corresponded to a rate of 17 snowmobile injury deaths per
100 million miles driven, compared with two on-road motor vehicle injury deaths per 100
Petition to Remove OSV Exemption and Remedy Discretionary Management of OSVs – Draft 21
million miles driven. During this same time period, 238 snowmobile injury hospitalizations also
occurred for a rate of 248 hospitalizations per 100,000 snowmobiles compared to 108
hospitalizations per 100,000 on-road motor vehicles in use.

Between 1990 and 1994 there were 479 snowmobile deaths recorded in the United States with
the majority reported in Alaska (63), Wisconsin (86), Minnesota (76), North Dakota (7), and
Maine (15) (Landen et al., 1999). A number of studies have been published documenting the
significant safety risks associated with snowmobile use (CDC 1995, CDC 1997, James et al.,
1991, Gabert and Stueland 1993, Waller and Lamborn 1975, Rowe et al., 1992, Eriksson and
Bjornstig 1982, Soininen and Hantula 1992, Rowe et al., 1994, Bjornstig et al., 1994).

The tremendous power, weight and traction of snowmobiles are incompatible with skiers,
snowshoers and other pedestrian users of winter trails and backcountry terrain.
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CONFICTS WITH OTHER RECREATIONISTS
Until the early 1990s the conflict that existed between motorized and non-motorized winter
recreation uses was localized; non-motorized forest visitors could still readily find places where
they could get away from the negative effects of snowmobile use. However, by the 1990s
snowmobiles were changing rapidly. More powerful machines and more skilled riders made
almost no area off limit to their use. These technological advances in snowmobiles have
dramatically altered winter use on NFS lands. Improvements in horsepower, weight, traction, and
fuel tank capacities enable snowmobiles to access places previously reachable only by
backcountry skiers or snowshoers.

As documented repeatedly and extensively in Appendix E, “Documentation of User Conflict
Due to Over-Snow Vehicle Use,” snowmobiles are incompatible with other forms of winter
recreation such as snowshoeing, cross-country and backcountry skiing, wildlife observation, and
winter hiking. Non-motorized winter recreationists report that the noise and smell of
snowmobiles greatly reduces their level of enjoyment in the peaceful winter environment
(Vitterso, et. all, 2004). The high speed of snowmobiles presents the danger of collision with
slower cross-country skiers and snowshoers (Blue Water Network, 1999). Many skiers report
that snowmobiles ruin ski trails (Baker and Bithmann, 2005).

Following are a few excerpts from letters to USFS to illustrate the scope of the issue.

Alaska
In Chugach National Forest conflicts between skiers and snowmobiles are common:
“Over the years that I have lived and skied in Alaska I have had numerous unpleasant
encounters with snowmachiners on the Chugach National Forest. The worst episode
occurred in 2008 in the Turnagain Pass area north of the Seward Highway when I was
surrounded by six snowmachines that deliberately circled my skiing partner and I,
repeatedly highmarking the slope that we were attempting to ski. The clear message was
that we were not welcome in “their” terrain. I no longer ski on the “snowmachine side”
of Turnagain Pass because backcountry skiing and snowmachining are incompatible
uses.” - Brad Meiklejohn, Eagle River, AK

California
In the Sierras, cross-country skiers have been forced out of their traditional use areas:
“Both as a public visitor to the Van Vleck area and as a long time volunteer (over 21
years) for the Eldorado National Forest I have been concerned about maintaining the
special non-motorized status that was protected by various Forest Orders for this area.
After the review in 2007 I became concerned when I heard that the Forest Orders had not
been reinstated. I have been told repeatedly by many Forest personnel that the reason
was the Travel Management/Route Designation process. The thought was that if no
routes were designated in the Van Vleck area there would be no need for Forest Orders.

Travel Management only covers wheeled vehicles and does not cover snowmobiles or
other specialized over the snow vehicles. Non-motorized recreationists are now paying
the price for this hole in management policy. This past winter I witnessed increasing
snowmobile use in the Van Vleck Area that will only escalate without enforceable Forest
Orders in place.” – Monte Hendrix, Pollock Pines, CA

“I no longer visit the Mt. Watson Road area because the high volume of snowmobiles, of
which commercial snowmobiles are the largest component, have robbed me of the
natural setting that the area once offered. It simply comes down to the fact that the noise,
smell, safety issue and a host of other negative impacts of the snowmobiles have ruined
the area for me and have driven me away.” - Marcus Libkind, Livermore, CA

“I am a cross-country skier who has enjoyed skiing in this area for over 20 years. This
popular area offers easy access and skiing opportunities for all level of skier. However,
to my dismay, I have noticed a sharp increase in snowmobile activity in the area over the
past several years, much of it in places where snowmobiles are allegedly prohibited. As a
person who enjoys the outdoors, I am offended by the presence of these snowmobiles for
several reasons, including potential safety hazards, excessive noise, and air pollution.
Nothing can destroy a winter wilderness experience like the presence of these machines
ripping up and down the mountainside, imprinting the pristine backcountry snowpack
with their track marks, punctuating the silence of the backcountry with their loud,
obnoxious roar, and fouling the pure alpine air with their noxious smell.” - Ken
Condreva, Livermore, CA

Colorado
On San Juan, White River, and Routt National Forests increasing snowmobile activity has
negatively impacted traditional non-motorized winter recreation:

“In the past several years (and most recently in late December/early January, 2010), we
have witnessed a marked increase in the number of snowmobiles that blatantly disregard
posted signage that explicitly prohibits snowmobile use in the area in question. This
results in a degradation of the environment as well as in the cross-country/snow shoeing
experience. The snowmobilers often drive very aggressively which poses safety concerns.
As well, the snowmobiles are extremely noisy and emit an offensive blue pall of
smoke/pollution that frankly ruins the backcountry experience.” – Dave and Michele
Harris, Superior, CO

“Trails, much less whole areas, where snowmobiles are restricted are few and far
between. Even when such a trail exists, it will often be in the same area as trails used by
snowmobiles so we have to listen to their noise anyway. Skiing in their ruts is dangerous.
Their fun ruins our fun.” - D. J. Inman, Centennial, CO

“If I could plead I would, but if I were to lose the opportunity to escape to the few
bastions where there is almost no conflict with the associated nuisance of noise and
pollution from snowmobiles I would be broken hearted. Those many of us who enjoy the
winter outdoor experience where the quiet observation of our natural environment exists,
desperately need an area protected from motorized use, especially when so many, many
miles of groomed trails already exist for snowmobile use.” - Leslie Lovejoy, Steamboat
Springs, CO

Idaho
Idaho skiers and snowshoers find their groomed trails destroyed and backcountry areas overrun
by OSV use:

“As an experienced Cross Country Ski Trail Groomer Operator, I have had many of the
groomed trails destroyed by snowmobiles, which is essentially destruction of expensive
property. Also as a Nordic skier I have seen many other machine groomed ski trails
trashed by snowmobiles. On the Targhee National Forest we have very few areas where
skiers can enjoy their sport without interference from snowmobiles and keeping these few
small snowmobile free areas is very necessary to prevent conflicts.” – Norman Kramer,
Idaho Falls, ID

“As citizens of a community that relies on a tourist-driven economy, we are sensitive to
user groups being excluded from certain areas, and believe that there is room for all of
us. However, motorized recreation is intrusive, disruptive, and often dangerous to other
users and should be limited, especially in the winter. Snowmachines need to be excluded
from many backcountry ski destinations to provide opportunities for muscle-powered
travelers. This is because, more than any other motorized vehicles, snowmobiles are
loud, pollute the air, and are frequently operated in dangerous and illegal ways.” –
Sarah Lynch, McCall, ID

Montana
On the Gallatin National Forest unregulated snowmobile use is endangering backcountry skiers:
“However, we were concerned about avalanche danger, and while skiing a line from
Sheep Mountains N summit to the E, one at a time to avoid triggering a slide and offering
rescue in the event of a slide, a group of four snowmobilers came up the slope while a
member of our party skied it. They high marked the slope, with complete disregard for
the potential to trigger an avalanche while a skier was on it.” - Ryan Jordan, Bozeman,
MT

Nevada
On the eastern side of the Sierra’s and the Toiyabe-Humboldt National Forest, increasing
snowmobile use and a corresponding lack of oversight are endangering the safety of winter
recreationists:

“On that day, like the other days I have been there lately, it was deserted before 8 a.m.,
but the noise of the snowmobiles was so loud that I was concerned that they were on "my
side" (the no-snowmobile side), and had to keep watching my back, so I wouldn't be
caught by surprise. It would have been a qualitatively different experience to ski in true
tranquility. Instead, my 'quality time in the woods' was threatened by loud noises, so loud
that I thought the vehicles were nearby.” - Lisa Foley, Zephyr Cove, NV

“The forest service has no ability to enforce speed limit or noise control measures. This
is not within their code to enforce. Additionally, the use of tethering behind snowmobilers
has increased in this congested area, causing great concern for other users as well as
presenting extreme danger to those being tethered behind the snowmobile. Again, the
forest service has no authority to control this behavior.” - Gail Ferrell, Reno NV
New Hampshire

Snowmobiles disrupt the peace and tranquility of New England trails in winter:
“I write to offer my comments about my experience in the northeast (and, in the past, in
the northwest) on trails that allow snowmobiles. It's easily summed up: as soon as I
know there are snowmobiles either allowed or (as all-too-frequently-happens) illegally
using a trail (as has happened on University of New Hampshire land in Durham, NH and
along the railroad tracks which lead to these trails, which those undertaking illegal RRbed
use soon access) I depart with great sadness. The risk of snowmobiler-skier, walker,
or dog collision is far too great and the noise and uncertainty (about when and where the
noisy machines are) too great and uncomfortable for my dog and I to risk continuing.” –
Diane P. Freedman, Ph.D., Durham, NH

Oregon
Tumalo Mountain, near Bend, has been the site of ongoing controversy:
“In the mid-1990s while skiing with my young sons down a nordic trail on Dutchman
Flat, a pack of snowmobilers came barreling down the slopes of Tumalo Mountain. They
burst through the trees and passed between my children and me, as well as immediately
in front of the boys. A minuscule variation in time, distance, velocity, or path of travel
would have been catastrophic. The cause of this near miss cannot be blamed on the
snowmobilers. The Forest Service was at fault, for it had failed to recognize the obvious
limitations of ‘shared use.’” - Dale Neubauer, Bend, OR

Utah
The current management plan for Logan Canyon has unfairly favored motorized use to the
detriment of non-motorized activity:

“I also would like to point out that a skier cannot escape the continual high pitched noise
of snowmobiles even when located in the center of the non-motorized designated area(s).
By decreasing the size of the motorized closure area, the proximity of the snowmachines
is even closer to the folks trying to find some peace and quiet in the mountains.” - Jim
Herrick, Logan, UT

“After our third run we were putting skins back on at the base of the hill when two
snowmobiles entered the hill at the top of the slope. One stopped next to my backpack, the
other down the slope a little distance. Both got off their machines and turned them off.
Our backpacks, new tracks, and me in my bright yellow parka were clearly visible to
both, and I shouted up to them in hopes they would stay off the slope. They were then
joined by one or two other snowmobiles and proceeded to track up the entire hillside,
using long traverses to cover the hill, they even erased our up-track. Within 5 minutes,
the hill had no untracked snow left on it, and they left the area. In addition to the
inconsiderate behavior in entering the same slope we were on, given the abundant and
deserted terrain up there, their behavior was extremely dangerous. During the time that
they were riding the slope directly above us (while we were trying to get skins on and get
out of the way), they crossed a convex, heavily wind-loaded slope (>30 degrees) several
times, thereby placing us in danger of being overtaken by any avalanche they triggered.”
– Bradley Ritts, River Heights, UT

Washington
The Alpine Lakes Area of Wenatchee National Forest has become a hot spot for conflicts
between user groups:

“During winter time, it is becoming increasingly difficult to visit the Alpine Lakes area
without experiencing levels of noise, smelly air and hazard from speeding machines that
exceed allowed or actual conditions in cities or towns.” - Donald Parks, Seattle, WA


Wyoming
Because of the OSV exemption in the 2005 Travel Management Rule, officials on the Bridger-
Teton and Shoshone National Forests refuse to undertake winter Travel Planning, resulting in
conflict on Togwotee Pass and within the Palisades Wilderness Study Area:

“All the way up, we heard the incessant whine of snowmobile engines coming from
below, as they were working their way up along a different route. Once over the top, we
enjoyed great powder skiing down a NE facing ridge covered with trees. For awhile, we
were not even bothered by engine noise, and were able to hear three-toed woodpeckers
drumming. That didn’t last long: soon we heard the whine of engines coming from the
Breccia Pass area (most likely from inside the wilderness boundary). On the way back,
the ravine was tracked out by snowmobiles, and we were forced to pick our way down
through foot-deep tracks. Near the bench we encountered hip-deep tracks, which we
needed to carefully circumnavigate, and which probably explained the revving of engines
we had heard on the way up. For the remainder of the descent it was always necessary to
watch out for deep ruts caused by snowmobiles.” - Peter and Eva Crane, Lander, WY
“Some are friendly and talk; others scream by at full throttle, shattering the solace,
sending what wildlife persists scurrying and devouring whatever powder they encounter,
the same powder that is one of my goals. In minutes they consume what takes me a day to
achieve. My heart sinks, my day is altered, the powder is dismembered, the experience
less exhilarating and the impact painful. My only refuge is tiny pockets of tightly spaced
trees that are currently un-navigable by them. Wilderness boundaries this time of year
are often just invisible barriers as meaningless as my presence.” - Ken Doer, Riverton,
WY

“Snowmobilers using this area, however, must go straight up or down the gullies,
exposing themselves and everyone below to avalanche danger. While this was fairly
uncommon even 5 years ago, the practice of “high-marking” using more powerful
snowmobiles has increased substantially over the past few years. Due to the engine noise
and the fact that we are often ascending in the trees, snowmobilers are likely to be
unaware that there are even skiers in the area.” - Darran Wells, Riverton, WY
“For over eighty years skiers have been touring and turning on Togwotee Pass. Recently,
we have come together for a common goal: the preservation of backcountry skiing on
Togwotee Pass. Motorized use, including snowmobiles and snowcats, near Togwotee
Pass has reached a level that conflicts with our values of quiet, solitude, and pristine air
and snow. These values were once available at Togwotee, but now are greatly
threatened.”- Jeramie Prine, Lander, WY

The disparity in opportunities for snowmobiles versus cross-country skiers and snowshoers is
large within NFS lands. Of the 116 million acres of NFS land within the 11 Western Snow Belt
states, approximately 81 million acres, or 70 percent, is open to snowmobiles. As for winter
trails, out of an estimated 20,389 miles of groomed trails in these same national forests, just
1,681 miles, or eight percent, of those groomed trails are designated as non-motorized (Rivers
and Menlove, 2006).

Significantly, of the approximately 35 million acres officially designated as non-motorized, more
than two-thirds of the acreage lies within designated wilderness areas. Motorized proponents
often point out that non-motorized users have exclusive use of wilderness areas. However, in
winter, the distances from plowed parking areas and trailheads make the vast majority of
designated wilderness areas inaccessible to skiers and snowshoers.

Despite the fact that the National Visitor Use Monitoring surveys on NFS lands in the 11
Western Snowbelt states show 28 percent more annual cross-country skier and snowshoer visits
than snowmobile visits, more than twice as many “backcountry” forest acres are open to
snowmobiles as are closed (Rivers and Menlove, 2006). When difficult-to-access wilderness
areas are taken out of the equation the disparity becomes more severe, with designated motorized
acreage outnumbering non-motorized, non-wilderness acreage by more than seven times.
Even more striking, there are 11 times more groomed trails open to snowmobiles than there are
groomed trails designated as non-motorized (Rivers and Menlove, 2006). This results in a ratio
of 14 times more skier and snowshoer visits per non-motorized mile than snowmobile visits per
motorized mile. This disparity between motorized and non-motorized opportunity and access is
repeated on a forest-by-forest and state-by state basis across the system. The result is dwindling
opportunity for skiers and snowshoers to find a quality recreation experience and escalating
conflict between motorized and non-motorized users on NFS lands.

The Petitioners contend that in most cases the designation “multi-use” is a misnomer and is de
facto single use: motorized. In other words, while skiers and snowshoers have access to multiuse
areas, because of the negative motorized impacts of OSV use, the opportunity for a quality
human-powered recreation experience is lost on NFS lands designated as multi-use because
those lands are in fact dominated by OSV use.
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CONCLUSION
As clearly documented in the foregoing evidence, the exemption of OSV use from the
requirements imposed on other motorized use on NFS lands by the 2005 Travel Management;
Designated Routes and Areas for Motor Vehicle Use Rule (CFR Parts 212, 251 and 281) is in
direct contradiction to Executive Orders 11644 and 11989 which the Rule is intended to
implement. Furthermore, because of adverse impacts on water and air quality, wildlife, wildlife
habitat and winter ecosystems, and because of the noise and the potential to inflict serious injury on other forest users, OSVs are indistinguishable from other classes of ORVs in terms of impacts on natural resources and other recreational uses.
Therefore, the USDA and USFS have a legal and ethical obligation to apply the same set of management standards to OSVs as to other classes of ORVs in order to protect and preserve America’s National Forest System resources, including
clean air and water, quiet, wildlife, soils, vegetation, and non-motorized recreationists, from the
substantial adverse impacts of OSV use.
Given this evidence, the USDA must amend the 2005
Rule by removing 36 CFR Part 212.51(a)(3) and remedying the language making the
management of OSVs a discretionary decision of the local responsible official (36 CFR Part
212.81) as requested by the Petitioners.





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Oliff, T.K., Legg, K., and Kaeding, B. 1999. “Effects of winter recreation on wildlife of the
Greater Yellowstone Area: a literature review and assessment.” Report to the Greater
Yellowstone Coordinating Committee. Yellowstone National Park.
Paquet, P.C., Poll, D., and Callaghan, C. 1997. The influence of snow cover on movements of
gray wolves.
Reinhart, D., 1999. Effects of Winter Recreation on Habituated Wildlife. National Park Service:
Effects of Winter Recreation on Wildlife: 151-153.
Rongstad, O.J., 1980. Research needs on environmental impacts of snowmobiles. In R.N.L.
Andrews and P. Nowak, editors. Off-road vehicle use: A management challenge. U.S.
Department of Agriculture, Office of Environmental Quality, Washington, D.C.
Rowe, B., Milner, R. Johnson, C., and Bota, G., 1992. Snowmobile-related deaths in Ontario: a
five year review. Can. Med. Assoc. J. 146: 147-152.
Rowe, B., Milner, R. Johnson, C., and Bota, G., 1994. The association of alcohol and night
driving with fatal snowmobile trauma: a case control study. Annual Emergency Medacine 24:
842-848.
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Department of the Interior, National Park Service, Air Quality Division. Report prepared by
Energy and Resource Consultants, Inc., NPS Contract No. CX-0001-4-0054.
Petition to Remove OSV Exemption and Remedy Discretionary Management of OSVs – Draft 32
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