Backcountry Horsemen of California

                                 San Joaquin Sierra Unit

 

June 4, 2009

 

Sierra National Forest

Attn: Travel Management Project Leader

1600 Tollhouse Road

Clovis, CA 93611

 

Subject: Equestrian Response to (OHV) Travel Management Plan DEIS

 

Preface: The Equestrian community has spent countless hours reading, studying and evaluating the Draft Environmental Impact Statement (DEIS) related to the Travel Management Plan as it relates to Off Road Vehicle (OHV) travel, specifically, cross country travel.  In most cases we support the control of vehicular cross country travel because of the environmental damage it causes to the land.  This in no way implies that we support the improper use of this DEIS to restrict normal vehicular use of the dispersed camping sites along approved Forest Service designated roads.  This DEIS has called the short spurs to these hundreds of historical camping and parking sites as OHV cross country access. This is a total disregard for the fact that these spurs can be traveled safely by any normal street vehicle, truck, motor home, or truck trailer combination and cause very little impact.  This has been the case for 60 or more years.  You have noted on Chapter 1, page 8 under Purpose and Need, that the Forest Service has considered the impact of the decision but have disregarded the public need for this access. The Forest Service DEIS states:

 

ÒProvide motor vehicle access to dispersed recreation opportunities (camping, hunting, fishing, hiking, horseback riding, etc.). A substantial portion of known dispersed recreation activities are not typically located directly adjacent to NFTS roads or NFTS motorized trails. Some dispersed recreation activities depend on foot or horseback access and some depend on motor vehicle access. Those activities accessed by motor vehicles are typically accessed by short spurs that have been created primarily by the passage of motor vehicles. Many such unauthorized Ôuser-createdÕ routes are not currently part of the NFTS. Without adding them to the NFTS and designating them on a MVUM, the regulatory changes noted above would make continued use of such routes illegal and would preclude access by the public to many dispersed recreation activities.Ó

 

1.    None of the 4 usable alternatives are acceptable to the equestrian community as they each have the same language related to parking along designated routes of – One Vehicle Length Off the Road – thus limiting access to the hundreds of historically used parking and camping areas for disbursed recreation. The implied definition of these locations is that they are considered OHV cross-country travel and now closed under the proposed DEIS Plan. We strongly disagree with this definition.

 

2.    The Equestrian Community has no realistic alternative in this Plan for continued use of the forest because there are virtually no camping areas for horses and mules. Most conventional campgrounds do not allow horses and mules and equestrian users have historically used the disbursed camping sites to recreate in the Sierra National Forest. The DEIS Plan does not have any way to reach these historical sites by vehicular means such as truck and trailers. These short spurs will now be closed.

 

3.    The maps show a few locations that are proposed for disbursed camping and parking but there is no assurance that the very stringent guidelines (templates) will allow this to happen. The BCHC/SJSU proposed 50 or more disbursed sites to consider. These should be given high priority to allow continued use of the forest by the equestrian community and not be shutout because of an improper definition of OHV cross-country travel. Horse trailers and pickups are not off highway vehicles and have easily reached these sites in the past.

 

4.    PARKING cars, trucks and large horse rigs along roads would create a HAZARD for all, especially children, pets and livestock.  EQUESTRIANS need safe and appropriate staging areas!  Even the Sierra Club Fresno rep thinks this level of closure is TOO EXTREME!

 

5.    The economic impact of virtually eliminating historical dispersed access to camp areas has been so grossly misstated.  Many hundreds of the public use these sites each year, including the equestrian community, and depend on the low cost and availability to make their recreation economically feasible.  This was totally not evaluated in the economic section of the DEIS.

In Conclusion:  The DEIS Travel Management Plan is a gross distortion of the original National intent to correct true OHV cross-country travel problem by bureaucratically calling the short spurs to the hundreds of dispersed camping and parking sites as closed for use. This causes the historical public use to be shut out of the National Forest and creates hazards that have been glossed over. Some Regional Forests have allowed 300 ft zones along the designated routes to solve this problem.  Forest Service Region 5 has chosen to slap the public in the face and force everyone into limited public campgrounds. This is done under the environmental guise that this historical dispersed use is damaging to the environment.  We in the Equestrian Community disagree and strongly oppose the adoption of this intent in the DEIS.

 

Respectfully;

 

 

Charles (Toby) Horst, Public Liaison Chair

San Joaquin Sierra Unit, BCHC