Articles tagged with: comment letters

Cal4Wheel opposes expansion of critical habitat for Sierra Fisher

Cal4Wheel opposes expansion of critical habitat for Sierra Fisher

Cal4Wheel submitted comments to oppose the proposed expansion of critical habitat for the Sierra Fisher. The US Fish & Wildlife Service (FWS) released a revised version of the 2021 critical habitat proposal for the southern Sierra Fisher. The revision proposes designation of approximately 595,495 acres of critical habitat in portions of Fresno, Kern, Madera, Mariposa, Tulare and Tuolumne counties in California, which is an increase of 41,041 acres from the initial proposal.

Cal4Wheel's comments urged the FWS to objectively weigh all points of impact from this proposed listing – not only impact on Fishers, but also, impact on:

  • Other species of flora and fauna that reside in the same habitat as Fishers
  • General health and resilience of public lands where Fishers reside
  • Real and impending increased risk of catastrophic wildfire if additional restrictions on human activity are imposed on Fisher habitat as a result of approving this proposed rule
  • Social and economic welfare of humans who reside, conduct commerce, and recreate within the range of habitat occupied by Fishers
  • The accurate, factual impact of various human activities on the health of Fisher habitat and conservation of this species, including but not excluded to OHV recreation
  • The imperative for FWS to use the most current, accurate, best available science to clearly demonstrate the need and justification for this proposed designation of critical habitat

Read the full comment letter via this link

Photo courtesy US Fish & Wildlife Service

Cal4Wheel opposes listing of three species of salamanders as endangered or threatened

Slender Salamanader

Cal4Wheel submitted comments to oppose the listing of three species of Salamander as "Endangered" or "Threatened." After reviewing the proposal for listing, Cal4Wheel cited evidence of: 

  • Negative impacts to other species, OHV recreation, local economies, and balanced forest management 
  • Missing data within the analysis of need to provide protected status to each Salamander species

 Review the full comment letter via this link

Red Rock Canyon comments submitted

Red Rock Canyon comments submitted

Red Rock Canyon State Park recently released a Preliminary General Plan & Draft Environmental Impact Report for public review and comment. This Plan was crafted following four years of prior scoping, analysis, and public comment. 

Cal4Wheel reviewed the Plan and believes that SP has failed to resolve critical concerns that were raised, along with suggestions for remedy, during prior public comment opportunities. Additionally, some components of the Plan may place California State Parks at risk of executing a range of legal violations. In this comment letter, these issues are described in detail, with offer of recommendations to remedy each of the following:

  1. Misalignment with SB 155
  2. Equity of access for disabled visitors
  3. Violation of the California Desert Protection Act, and California Public Resource Codes (PRC) Sections §5002.2 and 5019.53
  4. Misuse of “Zones” to severely restrict public access
  5. Elimination of motorized access within Birds of Prey Natural Preserve

Review the full comment letter via this link

Cal4Wheel submits comments on BLM's Environmental Assessment for Moab area trails

Cal4Wheel submits comments on BLM's Environmental Assessment for Moab area trails

Cal4Wheel submitted comments to the Bureau of Land Management (BLM) regarding their Environmental Assessment for an update to the Labyrinth Rim / Gemini Bridges Travel Management Plan (TMP). The Labyrinth Rim / Gemini Bridges area is located just outside of Moab, Utah. It is a national destination for OHV enthusiasts as it boasts a network of over 1,100 miles of trails through stunning red rock canyons, arches, and exquisite desert landscapes. This area is also the host site of the annual Easter Jeep Safari. BLM's proposed update could close over 400 miles of trails. Cal4Wheel objected to the proposed closures and advocated that BLM should consider increasing trail mileage rather than reducing it, given that BLM already closed over 700 miles of trails in this area in 2008. Additional trail closures would negatively impact user safety, potential resource damage, the local Moab economy, and the national OHV economy.

After analyzing the TMP Environmental Assessment, Cal4Wheel believes that the BLM has failed to resolve critical concerns and legal violations on the following Plan components:

  • NEPA analysis
  • Economic impact analysis
  • Omission of local resident and user insight
  • Cumulative impacts
  • Regulatory discrimination of disabled persons
  • Analysis of impacts to species of concern

Additionally, Cal4Wheel called on the BLM to abandon the current progression of the TMP update, return the full plan to its formative stages to conduct a valid evaluation of the issues noted above, and provide forums for relevant, robust public comment.

Read the full comment letter via this link:

Creek Fire restoration project comments submitted

Burned area south of Shaver Lake courtesy of Inciweb

Cal4Wheel has submitted comments dated September 21, 2022 regarding the draft environmental assessment for the Creek Fire restoration project in the Sierra National Forest. Read the comment letter at this link

Of positive note, Sierra National Forest (SNF) responded in favor to several suggestions that Cal4Wheel shared during the Scoping phase of this project. An important revision that was added to the analysis is: existing recreational roads will not be decommissioned as part of the CFR project.

Within comments for the Environmental Analysis, Cal4Wheel advocated for restoration of historical OHV routes that have been previously closed in order to:

  • Enhance the local recreation economy
  • Eliminate bias in public land access against persons with disabilities
  • Capitalize on the unique and important opportunity for SNF to be a trendsetter in building new roads and trails as part of burn scar restoration, where new roads and trails may be designed to optimally traverse the landscape in a manner that idealistically balances the needs and interests of public access, wildlife, and forest ecology

Additionally, Cal4Wheel offered the ongoing support of club membership as volunteers to support the success of both immediate forest restoration and post-project maintenance needs.


Cal4Wheel comments on Williams Hill Recreation Area plan

Cal4Wheel comments on Williams Hill Recreation Area plan

Cal4Wheel has submitted comments to the Bureau of Land Management (BLM) regarding the Williams Hill Recreation Area's draft plan and environmental assessment. Cal4Wheel supports proposed alternative B, which will design an OHV trail network and other recreational improvements in the recreation area.

Read Cal4Wheel's comments here.

Cal4Wheel submits comments on proposed rule for Foothill Yellow Legged Frog

Cal4Wheel submits comments on proposed rule for Foothill Yellow Legged Frog

Cal4Wheel's Natural Resource Consultant, Rose Winn, submitted a comment to the US Fish & Wildlife Service (FWS) to oppose a proposal to list four population segments of the Foothill Yellow Legged Frog (FYLF) as "threatened" or "endangered." If the listing is approved, there is risk of OHV access closures throughout FYLF habitat, which includes millions of acres of public land in the Sierra Nevada Mountain range and the coastal region of California. While FWS claims to use the best available scientific and commercial data available to determine the final decision, there is evidence that the proposal and impending decision have been heavily influenced by environmental special interest groups like the Center for Biological Diversity. 

Read the full comment here for more details. Cal4Wheel is proud to advocate for preservation of OHV access in California's public lands to ensure that everyone may continue to enjoy OHV recreation throughout the state.

For more information about this proposed listing of the FYLF, check out the proposal announcement in the Federal Register, or the full proposed rule docket with accompanying documents and roster of public comments.

17 organizations write to oppose Oceano SVRA's draft Public Works Plan

17 organizations write to oppose Oceano SVRA's draft Public Works Plan

The undersigned businesses, associations, and enthusiast groups are opposed to several provisions in the proposed Oceano Dunes State Vehicular Recreation Area (ODSVRA) Public Works Plan (PWP) that was released on December 30, 2020. If implemented as drafted, the proposed PWP would fundamentally change the operation of ODSVRA which has been open to off-highway vehicle (OHV) use for many decades.

Friends of Oceano write letter in opposition to Oceano SVRA foredunes closure

Letter asks State Parks to delay closure

Friends of Oceano write letter in opposition to Oceano SVRA foredunes closure

The California Coastal Commission has issued an emergency permit requiring California State Parks to immediately close 48 acres of camping area ahead of the Christmas and New Year's holidays, resulting in a 50% loss of camping spaces on the dunes.

In response, the Friends of Oceano Dunes have written a letter addressed to State Parks asking them to delay the closure.

Comments submitted on Sequoia-Sierra National Forest Plan Revisions

Comments submitted on Cal4Wheel regarding the Sequoia-Sierra National Forest Plan Revision Update.

Download copy of letter


September 25, 2019

Plan Revision Team Lead

323 Club Drive

Vallejo CA 94592

Subject: Sequoia and Sierra Forest Plan Revision Update

Dear Planning Team:

These comments are submitted on behalf of the California Four Wheel Drive Association (Cal4Wheel) and its membership. Cal4Wheel represents clubs and individuals within the state of California that are part of the community of four-wheel drive enthusiasts. These comments are directed to the Revised Draft Environmental Impact Statement (DEIS) for Revision of the Sequoia and Sierra National Forests Land Management Plans. This document shall not supplant the rights of other Cal4Wheel agents and organizational or individual members from submitting their own comments and the agency should consider and appropriately respond to all comments received to this proposed planning project.

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