Natural resources report for January 2023

| Rose Winn, Cal4Wheel Natural Resources Consultant | Natural Resources Consultant Reports

SEQUOIA AND SIERRA NATIONAL FOREST LAND MANAGEMENT PLAN OBJECTIONS

The Forest Service (FS) has completed the final stages of revising the forest plans for the Sierra and Sequoia National Forests. Objection Resolution meetings were held on November 15-17 to discuss the draft Records of Decision and Revised Forest Plans with members of the public who had submitted comments and objections to the plan revisions. Issues within the plan revisions that are of key concern to OHV enthusiasts include:

  • OHV trail closures in the Piute Mountains of Sequoia National Forest
  • Violation of federal law within the planning process and overhaul of Pacific Crest Trail management
  • Bias of heavy input from the Pacific Crest Trail Association
  • Minimized public input from the OHV community throughout the planning process
  • Neglect to balance the Recreation Opportunity Spectrum
  • Disregard for the Forest Service’s contracted obligation to preserve multiple-use access to public lands, with explicit bias towards non-motorized recreation

Read Cal4Wheel’s objection letter via this link: https://bit.ly/seq-sierra-plan-objections

The Objection Resolution meetings were attended by three groups within the OHV recreation community: Cal4Wheel, Stewards of the Sequoia, and CORVA. Multiple extreme environmentalist organizations were also in attendance, including: the Center for Biological Diversity, CalWild, Sierra Forest Legacy, the Pacific Crest Trail Association, and many more. Unfortunately, the FS disregarded the points of concern raised by Cal4Wheel and other OHV enthusiasts, while giving full attention and credence to the requests and suggestions raised by environmentalists. Additionally, the FS did not follow their own policies for protocol and process within the objection resolution meetings.

An Objection Response has been issued by the FS for this project. Cal4Wheel will consider taking further action to seek review of the Objection Response to determine whether FS violations of protocol within the Objection Resolution meetings may nullify the validity of the project’s final Record of Decision.

For more information about the Sequoia & Sierra National Forest Land Management Plan Revisions, visit the project website.

SIERRA NATIONAL FOREST MOTORIZED RECREATION PLAN OBJECTIONS

Sierra National Forest (SNF) has recently completed the final stages of planning and public comment for the Motorized Recreation Plan (MRP) Update project. With this project, SNF had made a commitment to the motorized recreation community to examine routes that were not previously analyzed and decided, for potential addition to the Forest Service (FS) System of roads, OHV areas, and motorized trails. The purpose and intent of the plan was to evaluate over 550 miles of OHV routes that were closed in 2008 to consider designating them as active routes in the MRP. The actual outcome of this project was a major disappointment, as the FS opted to add only 30 miles of routes back to the MRP, of which only 10 miles are for full size OHVs.

On September 29, I submitted Objections on the MRP update. Cal4Wheel asserted that the limited addition of mileage was insufficient and does not serve to fulfill the purpose and need for the project - which is to enhance motorized recreation in SNF, provide a linked system of routes that accesses more diverse riding opportunity, create looped routes, and increase access to dispersed camping and recreation. Additionally, Cal4Wheel called on the Forest Service to fulfill their contracted responsibility to balance the Recreation Opportunity Spectrum by analyzing all un-inventoried, non-system, and user-created OHV routes for consideration of addition to the MRP. Read the full objection letter via this link: https://cal4wheel.com/documents/C4WDA-Sierra-National-Forest-MRP-Objections.pdf.

An Objection Resolution meeting was held on December 6. Only two groups attended this meeting: Cal4Wheel, and Stewards of the Sierra National Forest. A gentleman who is a mountain biking enthusiast also attended.

Unfortunately, the FS did not take action to improve the outcomes of this project based on suggestions and feedback provided by Cal4Wheel and other OHV recreationists. In the Objection Resolution meeting, it quickly became obvious that the FS had already reached decisions on all elements of the project, and they were completing the Objection Resolution meeting simply to check the box and demonstrate that the meeting had been held. This was quite an upsetting to experience, which I and representatives from Stewards of the Sierra National Forest made clear, given that the OHV community had invested countless hours into sharing research, suggestions, and support over the three years during which this project was completed. As a result of our expressions of distress, we secured extended time beyond the original scope of the meeting to discuss our concerns further and emphasize that the project was ultimately a huge disservice to the OHV community, as well as to outdoor recreation enthusiasts and the general public. Of positive note, the FS responded affirmatively to our grievances and committed to partner with Cal4Wheel and Stewards of the Sierra National Forest further to actually analyze non-designated OHV routes for consideration of adding them back onto the Motor Vehicle Use Map. Cal4Wheel will remain vigilant in this process moving forward to ensure that the FS follows through on their commitment.

For more information on the MRP project visit the project website: https://www.fs.usda.gov/project/?project=55572

RED ROCK CANYON STATE PARK GENERAL PLAN UPDATE

Red Rock Canyon State Park (RRCSP) recently released a Preliminary General Plan & Draft Environmental Impact Report (EIR) for public review and comment. This Plan was crafted following four years of prior scoping, analysis, and public comment. The plan is intended to address changing conditions, analyze the latest information and data, and incorporate lands that were added to RRCSP since a General Plan was approved in 1982. While the 1982 Plan only covers the original 8,180 acres of the park, the Revised General Plan will include the entire area of approximately 25,000 acres currently under park ownership and management. The General Plan presents the long-term management framework for natural and cultural resource stewardship, interpretation, facilities, operations, and visitor experience. It is the primary management document for a State Park (SP), establishing its vision, purpose, and management direction for the future.

Cal4Wheel’s concerns with the Draft EIR include:

  • Nightmare Gulch will be permanently closed to all but hiking and horseback riding access due to alleged concerns over public safety and preservation of archeological sites
  • Part of Last Chance Canyon will be closed
  • Only street legal vehicles will be allowed, with the exception of a few connector routes
  • No Side by Sides (SxS) will be allowed in the park

Additionally, 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. Some of the Plan components may place SP at risk of executing multiple legal violations. I submitted a comment letter describing these issues in detail, and offered 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: https://bit.ly/red-rock-comments-121622

PROPOSED ESA LISTING FOR THE SLENDER SALAMANDER

The US Fish & Wildlife Service (FWS) has proposed listing the relictual slender salamander as endangered and the Kern Canyon slender salamander as threatened. FWS is also proposing to designate 2,685 acres of critical habitat for the relictual slender salamander and 2,051 acres of critical habitat for the Kern Canyon slender salamander. This is of interest to Cal4Wheel, as 92% of the proposed critical habitat falls within Sequoia National Forest and lands managed by the Bureau of Land Management.

Cal4Wheel submitted comments to oppose the listing of each 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: https://bit.ly/salamander-comments

PROPOSED EXPANSION OF CRITICAL HABITAT FOR SOUTHERN SIERRA FISHER

The US Fish & Wildlife Service (FWS) has released a revised version of the 2021 critical habitat proposal for the southern Sierra Nevada distinct population segment (DPS) of fisher. The revision proposes to designate approximately 595,495 acres of critical habitat in portions of Fresno, Kern, Madera, Mariposa, Tulare and Tuolumne counties in California, an increase of 41,041 acres from the initial proposal. The revision identifies areas essential to the conservation of the species, which is currently listed as endangered under the Endangered Species Act. 

More than 90 percent of the revised proposed critical habitat falls on federal lands managed by the U.S. Forest Service (USFS), National Park Service (NPS) and Bureau of Land Management. During the public comment period, the USFS, NPS and a species expert from a research institute recommended additional areas for inclusion as critical habitat, mostly consisting of public lands. After reviewing the information, FWS agreed that those areas serve as important reproductive habitat for the fisher. FWS states that the revised proposal is not expected to restrict recreational access on public lands, however, historical trends demonstrate that designation of critical habitat frequently results in restrictions and closures of public access to public lands, including recreational access.

I submitted comments on behalf of Cal4Wheel to oppose the expansion of critical habitat. The 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: https://bit.ly/cal4fishercomments

2023 OHV GRANTS – APPLICATIONS MAY BE SUBMITTED NOW!

The time has arrived for annual submissions for OHV grant funds through the California State Parks OHVMR Commission. The Grants and Cooperative Agreements (GCA) Program provides for well managed Off-Highway Vehicle (OHV) Recreation by providing financial assistance to eligible agencies and organizations that develop, maintain, operate, expand, support, or contribute to well-managed, high-quality, OHV Recreation areas, roads, and trails, and to responsibly maintain the wildlife, soils, and habitat in a manner that will sustain long-term OHV Recreation.

If you or your club is involved in any form of maintenance, restoration, management, or support of OHV recreation roads, trails, facilities, or riding areas… you are eligible to apply for grant funds. Additionally, grants are awarded for safety and education programs.

Grant applications are due on March 6, 2023. Details on grant guidelines and online application submission are available via this website: https://www.grants.ca.gov/grants/grants-and-cooperative-agreements-program-gca-g23/. If you have questions about OHV grants, please reach out to me: rwinn@cal4nrc.com.

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