March 15, 2016 Chris O’Brien On behalf of Russell Hays, Forest Supervisor Lassen National Forest 2550 Riverside Drive Susanville, CA 96130
[email protected] By Electronic Mail Re: Comments on Lassen OSV Use Designation DEIS Dear Supervisor Hays, Thank you for the opportunity to comment on the Lassen National Forest’s Over-Snow Vehicle (OSV) Use Designation Draft Environmental Impact Statement (DEIS). The Lassen National Forest is the very first forest in the country to undergo winter travel management planning under the Forest Service’s new regulation governing OSV use, subpart C of the Forest Service travel management regulations.1 The rule 1 36 C.F.R. part 212, subpart C. 1 requires national forests with adequate snowfall to designate and display on an “OSV Use Map” specific areas and routes where OSV use is permitted based on protection of resources and other recreational uses. OSV use outside the designated system is prohibited. We are pleased to see that many sections of the DEIS provide a relatively thorough discussion of the impacts associated with OSV use. Unfortunately, the Forest Service has failed to apply that information and analysis to formulate a proposed action and alternatives that satisfy the requirements of the new subpart C regulations. To ensure that rule implementation is off to the right start and avoid the specter of litigation that has plagued summertime travel management planning, it is critical that the Lassen’s OSV use designation planning process: Satisfy the Forest Service’s substantive legal duty to locate each area and trail to minimize resource damage and conflicts with other recreational uses – not just identify or consider those impacts.