BRC is issuing a National Action Alert regarding a seriously important national issue currently in play in Michigan's Huron-Manistee National Forests. The issue may affect how federal agencies implement a well-established recreation management tool, the Recreation Opportunity Spectrum or "ROS."
Michigan based OHV, snowmobile and hunting advocates have done a yeoman's job of responding to the threat, but we would like to bring a bit of nationwide pressure to bear.
Below are details about the situation and why it important for you to respond, as well as simple instructions. We know how busy you are, especially at this time of year, so we've made it as simple as possible.
Thanks in advance and, as always, if you have any questions or concerns, please contact BRC.
Brian Hawthorne Ric Foster
Public Lands Policy Director Public Lands Department Manager
BlueRibbon Coalition BlueRibbon Coalition
208-237-1008 ext 102 208-237-1008 ext 107
Huron Manistee National Forests Revision Affects ROS
Please email comments today!
The 2006 Huron-Manistee NF Forest Plan was challenged in U.S. District Court in July of 2007. The challenge was brought by a anti-access/anti-hunting activist attorney who is seeking to ban all firearm hunting and motorized uses in areas with a Semi-Primitive Non Motorized (SPNM) Recreation Opportunity Spectrum classification.
Initially, the courts ruled in favor of the Forest Service which had allowed firearm hunting and snowmobile use in SPNM areas. However, an appeal was filed with the U.S. Sixth Circuit Court of Appeals which successfully reversed the prior decision. The appeals court found deficiencies in how the agency applied the Recreation Opportunity Spectrum (ROS) in the agency's evaluation of snowmobiling and firearm hunting activities. The court found the agency failed to correctly analyze "noisy" activities occurring in SPNM areas of the Forest. As a result the court directed the Forest Service to perform additional analysis.
The Forest Service has released a Draft Supplemental Environmental Impact Statement (DSEIS) for public review and comment. Early on in the process hunting, snowmobiling and motorized access groups, including BRC, raised significant planning issues and also suggested alternatives that might be formulated in response. Sadly, the Huron-Manistee only partially responded to our comments.
WHY IS THIS IMPORTANT:ROS is a useful tool for any agency in the business of managing recreation. The ROS provides an objective way to evaluate recreational opportunity and identifies six key classifications: Primitive (P), Semi-Primitive Non Motorized (SPNM), Semi-Primitive Motorized (SPM) Roaded Natural, Roaded Modified and Rural.
In land use planning, ROS can be used as an inventory, a "desired future condition," a guideline or as a standard. This lawsuit may result in land managers utilizing the ROS classifications only as a standard, which may result in significant closures in the future.
WHAT YOU NEED TO DO:The Huron Manistee NF is taking comments on their DSEIS until December 23, 2011. Hunters and recreationists, both motorized and non-motorized, should comment in support of Alternative 3 and in strong opposition to Alternative 2.
We have included a few comment suggestions and easy instructions below. You may also wish to access the Michigan Snowmobile Association's (MSA) excellent comment suggestions here:
BRC'S THREE-STEP ACTION ITEM
STEP-BY-STEP INSTRUCTIONS ON HOW TO EMAIL YOUR COMMENTS:
NOTE: Please be polite and, if possible, make your comment letter as personal as you can.
STEP 1: Open your email program and start a draft email. Address the email to
email@example.com. Put "Comments on Forest Plan DSEIS"
in the Subject Line.
STEP 2: Use the comments below as a guideline for comments in your email.
Cut and paste is okay, but try to make your comment letter as personal as possible.
STEP 3: Take just a minute to add a bit about where you live, where you like to ride and how
important hunting and snowmobiling is to you and your family. Be certain to include
your name and address. A return email address is NOT sufficient! ("anonymous" emails
are often discarded).
EXTRA CREDIT: If you can add any personal testimony about your experiences enjoying this spectacular area, please take a minute to add that to your email.
Then click "Send" and you're done!
Sample comment letter:
To: Huron-Manistee National Forests
Attn: Kenneth Arbogast
1755 S. Mitchell Street
Cadillac, MI 49601
Of the Alternatives presented in the DSEIS, I strongly support Alternative 3.
Allowing snowmobile use and firearm hunting is consistent with the application of the ROS tool. Each of the SPNM areas have a long history of successfully managed hunting and motorized recreational uses. Many of the SPNM areas are known, and managed for, a snowmobile and hunting "niche."
Of the Alternatives presented in the DSEIS, I strongly oppose Alternative 2. Alternative 2's elimination of the currently authorized hunting and snowmobile uses is inconsistent with the ROS inventory and decades of historical use. Alternative 2 fails to provide needed recreational experience as documented in the DSEIS analysis.
The analysis proves that snowmobiling and firearm hunting has been authorized in these areas for generations and most forest visitors support their continued use. The analysis also clearly proves that there is no duplication of these activities across state and federally managed lands.
The DSEIS documents a need to provide additional snowmobile opportunity. Michigan has the largest number of registered snowmobiles in the United States yet, on a per capita basis, the fewest miles of snowmobile trails in the country. All trails on these forests are critical to meeting the high demand for snowmobile trails in Michigan. The analysis shows a need for more trails, not fewer.
The analysis proves that Alternative 2 will not provide "high probability of isolation from the sounds of human activity." Instead, Alternative 2 unfairly and arbitrarily targets only certain uses for elimination.
The 2006 Forest Plan incorrectly tied ROS to Management Area standards and guidelines. Alternative 2 compounds this error by arbitrarily eliminating recreational uses that should be allowed in these areas. Conversely, Alternative 3 attempts to correct the original flaws in the 2006 Plan by amending the Management Area designations.
Closing snowmobile use on open public roads is arbitrary and not at all related to the facts on the ground, the existing recreational "niche" of these areas and the documented need to provide a wide range of winter recreation.
As a non-profit, grassroots organization funded primarily by membership dues and donations, we greatly appreciate your support. Visit http://www.sharetrails.org/make-a-difference-now to help fund our efforts to protect your trails!
The BlueRibbon Coalition is a national recreation group that champions responsible recreation, and encourages individual environmental stewardship. With members in all 50 states, BRC is focused on building enthusiast involvement with organizational efforts through membership, outreach, education, and collaboration among recreationists. 1-800-BlueRib - www.sharetrails.org