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Cal4Wheel Opposes Forest Service Proposed Rule on Land Uses & Special Use Permits

| Rose Winn, Cal4Wheel Natural Resources Consultant | Access Issues

The Forest Service published a proposed rule in March 2023 to amend its special use regulations to update the processing and monitoring fee schedules based on current Agency costs, provide for recovery of costs associated with processing special use proposals, and to remove the exemption for commercial recreation special use applications and authorizations that involve 50 hours or less to process or monitor. I submitted comments to oppose the Proposed Rule for Land Uses: Special Uses; Cost Recovery, Strict Liability Limit, and Insurance. The Rule is problematic on multiple levels, including:

  • The Rule itself violates Congressional direction, Congressional intent, and FS operational guidelines.
  • It would minimize our ability to stage organized group events in national forest.
  • The FS did not provide public notice about the Proposed Rule, it was published covertly with zero outreach or announcement to impacted stakeholders and the general public. 
  • Members of the public who engage in organized outdoor recreation, including Cal4Wheel, are among the most immediately and significantly impacted by this proposed rule. In direct violation of the FS claim to promote grassroots participation in decisions and activities, the FS neglected to communicate, host public meetings, or otherwise coordinate any element of this proposed rule with organized outdoor recreation groups.
  • Outdoor recreation is one of the primary, dominant uses of national forest lands within the scope of the multiple-use objective. This Proposed Rule significantly negatively impacts public access for outdoor recreation in FS managed lands.
  • The Proposed Rule imposes additional, unnecessary red tape and bureaucratic hoops for the public to jump through, along with a significant increase in the cost of fees to secure special use permits, and thus excludes large segments of the population from the opportunity to continue enjoying access to public lands.

The comment urged the FS to abandon the Proposed Rule in full, immediately. Read the full comment letter: C4WDA - Forest Service Proposed Rule Docket FS 2023-0001-0073 Comment.pdf


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