Clerk of the Board Use Only Butte County Board of Supervisors Agenda Item: Agenda Transmittal 3.18 Subject: Board Comment Letter - Lassen National Forest Over-the-Snow Vehicle (OSV) Use - Revised Draft EIS Department: Public Works Meeting Date Requested: November 14, 2017 Contact: Dennis Schmidt Phone: 530.538.7861 Regular Agenda Consent Agenda Department Summary: (Information provided in this section will be included on the agenda. Attach explanatory memorandum and other background information as necessary). On March 8, 2016, the Board of Supervisors approved a comment letter on the Draft Environmental Statement (DEIS) for the Lassen National Forest (LNF), supporting Alternative 4 of the Proposed Actions and opposing all other Alternatives that limited OSV access or restricted additional acreage from OSV travel. On October 6, 2017, the LNF issued a Revised DEIS that proposed additional limitations in the area of the Pacific Crest Trail, and offered Alternative 5, which significantly reduces the amount of motorized OSV acreage in the LNF (a 33% reduction), and particularly affects the Jonesville Snow Park, increasing the amount of land from 16,181 to 42,524 acres for non-motorized use. The Forest Advisory Committee (FAC) reviewed the RDEIS, solicited public feedback, and gathered data from the Hillslider's Club, which has been responsible for grooming the snowmobile trails in the Jonesville Snow Park for the past 20 years. The Federal/State Land Use Committee has reviewed the RDEIS and the conclusions of the FAC, as well as the opinion of the Board of Supervisors from their March 2016 letter, and recommends the Board of Supervisors send the proposed comment letter to the LNF. Fiscal Impact: Does not apply. Personnel Impact: Does not apply. Action Requested: Approve letter and authorize the Chair to sign. Administrative Office Review: Casey Hatcher, Economic and Community Development Manager BILL CONNELLY BOARD OF SUPERVISORS First District Administration Center LARRY WAHL 25 COUNTY CENTER DRIVE, SUITE 200 - OROVILLE, CALIFORNIA 95965 Second District Telephone: (530) 538-7631 MAUREEN KIRK Third District STEVE LAMBERT Fourth District November 14, 2017 DOUG TEETER Fifth District Chris O’Brien, on behalf of Dave Hays, Forest Supervisor Lassen National Forest 2550 Riverside Drive Susanville, CA 96130 Re: Comment Letter ‐ Lassen National Forest Over‐Snow Vehicle Use Designation Revised Draft Environmental Impact Statement Dear Chris, and Supervisor Hays: The Butte County Board of Supervisors (“Board”) respectfully responds to the U.S. Department of Agriculture‐Lassen National Forest’s Revised Draft Environmental Impact Statement (“RDEIS”) on the proposal to designate Over‐Snow Vehicle (OSV) Use within the Lassen National Forest. The Board and the Butte County Federal/State Land Use Coordinating Committee have reviewed the Lassen National Forest Proposed Over‐Snow Vehicle Use Designation RDEIS and have actively solicited feedback from recreationists and other stakeholders via the Butte County Forest Advisory Committee and through direct contact with stakeholders. The Board understands that the Forest Service’s 2005 Travel Management Regulations requires the designation of roads, trails, and areas on national forests and grasslands that are open to motor vehicle use. Subpart C mandates the designation of routes and areas for over‐snow vehicle use. The Board strongly opposes Alternatives 2 and 3, as stated in its letter of March 8, 2016, due to the proposed reduction in the amount of available land for OSV use. Alternative 5 has been added in the RDEIS. The following comments pertain to this Alternative, which the Board also strongly opposes: 1) According to the RDEIS document, there are 75,169 acres available for non‐motorized recreation within 10 miles of plowed trailheads 44 miles of cross‐country ski trails and other non‐motorized routes available for non‐motorized recreation within 10 miles of plowed trailheads. There are 185,983 acres/ six non‐motorized trails with a total of 148 miles for non‐motorized use. Of the areas listed in the RDEIS that have groomed motorized trails with some proximity to the non‐ motorized areas, none appear to be in or near the areas utilized by visitors to the Jonesville Snow Park. 2) Alternative #5 reduces the Forest’s legal riding acreage by one‐third, and significantly affects Butte County’s only organized winter sports center – the Jonesville Snow Park, increasing the non‐ motorized area from 16,876 acres to 42,524 acres. This reduction in acreage is not supported by any reported conflicts or resource damage of any significance, nor was there an indication of any other resource that needed protection. The Hillsliders Club that grooms and manages this Snow Park is of the opinion that this would cripple their program and adversely affect numerous visitors without deriving any particular benefit to non‐motorized visitors already enjoying the Jonesville Snow Park. Our public lands are everyone’s land, and there is a history of little to no conflicts in this area. So why confiscate that acreage and make it illegal to ride there? There is simply no good reason to support such a reduction, and we strongly oppose any Alternative that reduces acreage without sound reasoning and legal foundation. 3) The restriction to 12” snow depth only, with no allowance for reaching groomed trails from the trailheads, could reduce access to groomed trails. This is unnecessary, as snowmobilers must use good judgement and not travel across gravel or pavement or brush and rocks unless they are adequately protected by a minimum depth of snow, or their expensive equipment would be severely damaged. 4) The restrictions regarding accessing the area on and around the Pacific Crest Trail (PCT) are unnecessary, impractical and unenforceable. Due to snow depths, it is literally impossible to determine where the PCT is located in winter, and there has been no documented history of pedestrian traffic on the trail in the open OSV travel areas due to its remoteness, its danger, and the inability to reliably locate the trail in the winter. Additionally, the trail is generally located in and around trees, which is a dangerous place to be when the snow reaches its usual depths in the winter. OSV enthusiasts and skiers/snowshoers wisely avoid such areas due to the hazardous conditions. If the LNF decided this element of Alternative 5 were truly an imperative, seasonal signage would need to be installed, which would be logistically difficult and very expensive. And GPS mapping is not workable with any degree of accuracy and reliability. 5) The reference to no OSV travel over open or flowing water is sometimes impractical due to occasional snow melt streams that are encountered during cross country travel. We see no reference to resource damage cause by this practice. Additionally, the crossing of small streams is typical by motorized travelers in much of the LNF – we see no measurable difference between tires going through a stream vs. ski and track crossing. The Board supports ONLY Alternative 4, with the following comments: Allow winter OSV motorized recreation use and trail grooming when uncompacted snow depths equal or exceed 12 inches. Exceptions are allowed on designated OSV trails overlaying existing paved, dirt, and gravel National Forest System roads and trails in order for OSVs to access higher terrain and legal snow levels when snow depths are less than 12 inches, as long as this use does not cause visible damage to the underlying surface. However, a 12‐inch minimum snow depth of uncompacted snow will be required for OSV trail grooming activities and cross‐country OSV use. The Board believes that the 12” depth for groomed trails is reasonable, and allowing for 6” or even less on snow over graveled or paved roads to allow users to get from parking areas to the groomed trails and open areas is justified and should have minimal effect on the environment, as there is no vegetation on such roads. 2 Alternative 4 allows OSV use below 3,500 feet, when there is adequate snow depth, as described above as the stated minimum snow depths already effectively determine where OSV travel is appropriate. Prohibit cross‐country OSV use in the entire area from SH36 up SR89 to Lassen Volcanic National Park and across McGowan Lake Road to NFS road 31N17 with one exception: within this OSV prohibited area, designate for OSV use the trail from the intersection of 30N16 (McGowan Lake Road) and 30N16C to allow OSV use from this intersection west out to the 31N17 road. Therefore, OSV use would be restricted to only this designated OSV trail within this area. This alternative would groom the same snow trails for OSV use as the modified proposed action. For future considerations, the Board restates the desire to see a provision for additional miles of OSV groomed trails and Non‐motorized trails as funds (grant funds or budgeted funds) become available. Additionally, the Board would like to see additional parking areas made available for safe trailering and unloading of OSV equipment, and increased signage indicating whether the trails are shared use or restricted. The Board is in complete opposition to Alternatives 2 and 3, and 5 believing there is ample non‐ motorized trails and open protected areas under the current plan; especially closure of the Colby Mountain area, for the following reasons: 1) This area is currently managed by the Butte Meadows Hillsliders in partnership with The US Forest Service, Butte County, Plumas County, and Sierra Pacific. This collaboration is an excellent, sustained example of goals contained in the 1992 Lassen National Forest Land and Resource Management Plan (LRMP): • Provide stable and cost‐efficient road and trail systems (pg. 4‐3); • Provide a wide‐range of outdoor recreation opportunities to meet public demand (pg. 4‐4); • Provide diverse opportunities for off‐highway vehicle recreation (pg.