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WINTER TRAVEL MANAGEMENT
 
In June 2014 the Forest Service released a draft of the revision to the Travel Management Rule as it pertains to Winter Travel.  This revision's main purpose was to make travel management for winter travel mandatory rather than discretionary to forests.  The draft recognizes the importance of cross country travel to snowmobiling and defines this as a factor in travel management.  CSA submitted comments on the revision.  A final draft should be released later this fall.  CSA is cautiously optimistic that it will not be terribly cumbersome to winter motorized recreation.
 
MOLAS PASS ISSUE
The Tres Rio Field Office of the BLM is proposing a closure of an area of Molas Pass where approximately 4 miles of groomed trail (Silverton Snowmobile Club) passes.  This trail passes over area that is apparently encompassed by the West Needles Contiguous Wilderness Study Area.  Recent changes in BLM management protocols is being used as justification for closing this motorized route.   A new management manual released by the BLM is being used as the "smoking gun" for prohibiting motorized recreation on WSA's. 
 
However, after some pretty specific research, CSA is not sure that any of the arguments laid out by the Field Office holds water.  There is question as to the validity of the WSA to start with and the management manual does not have any statement (that we can find) that prohibits current/historic use from continuing as long as there is no impairment to Wilderness characteristics.  It has been determined by land managers that the groomed route is not impairing Wilderness characteristics.
 
CSA is continuing to dig into documentation to ferret out the answers.  As this continues to unfold we will report our findings.  An article was printed in the Durango Herald on 2/12/13 decribing the proposed decision.
 
April 1, 2013-Scott Jones and Janelle Kukuk attended a San Juan County Commissioners meeting in Silverton on March 27.  Also at the meeting were Connie Clementson and Jeff Christenson from the Tres Rios Field Office and Matt Janowiak from the Columbine District of the San Juan National Forest and Jim Lokey, president of the Silverton Snowmobile Club and several club members.  Many were allowed to speak expressing their displeasure with the proposed closure.  Darlene Markus from Congressman Scott Tipton's office and John Whitney from Senator Michael Bennet's office were present as well.  
 
Further research into the history and standing of the West Needle Contiguous Study Area did ultimately prove that the WSA is legitimate but for reasons that no one has been able to identify it is an area that was intended to be released from the WSA listing but never was.  CSA wrote a letter to Congressman Tipton's office (copying Senator Udall's and Senator Bennet's office) asking for legislation to be drafted to release this particular 1240 acre parcel of land from the WSA listing.
 
At the meeting on March 27, many expressed the desire for the Congressman's and Senator's office to pursue this route ASAP.  In the meantime a request was submitted to the BLM staff to consider a special dispensation for continued use on the land by winter motorized recreation until the release was law.  BLM staff felt that the only hope for that was to prove snowmobile use of the area pre-1976.  Many in the room felt that they could, with pictures and personal accounts, prove this very thing.
 
April 26, 2013-A delegation of 5 CSA members returned from Washington DC this week with news on the Molas Pass issue.  On April 23, the 5 representatives visited all 7 Colorado House of Representative members' offices and both Senator's offices and discussed proposed legislation that will include language to release a portion of the WSA that is impacted by snowmobiling. Our last visit of the day was to Congressman Tipton's office where a member of the House Resource committee walked us through the legislation and got final input from us.  We have also worked with Senator Bennet's staff on the same legislation.  Today, we sent letters to both Tipton's and Bennet's offices in support of the legislation entitled the Hermosa Watershed Protection Act.  We anticipate introduction of the legislation in both houses next week.
 
September 19, 2014-Finally the Hermosa Watershed Protection Act has cleared one of several hurdles.  The bill was passed out of the House Natural Resource Committee to the full House for a vote.  The legislation has been tweaked several times since April of 2013 but the main purpose of the legislation as it relates to Molas Pass stayed intact - Molas Pass will be saved for snowmobile recreation.  In the current version of the legislation the area surrounding the Molas Lake area will become a Special Winter Management Area that has winter motorized recreation and grooming written into the legislation.  Several phone calls and face to face meetings took place to get to this point and there is certainly excitement that this hurdle has been cleared.  The legislation is still in committee on the Senate side and there is no word as to when it might be passed to the full Senate.  Another request has been made to the BLM to consider delaying their deadline for closing since the legislation is moving.  However, it is unclear at this point in time whether this can or will happen.
CSA will continue working coincidentally with the BLM and the Legislators to follow these individual course of actions.  Check back for updates. 

Lynx Management
CSA,COHVCO and many other groups have been very concerned about the failure of many federal land managers to address recreational activity in lynx habitat with best available science.  Best available science has specifically concluded almost all recreational activity has no impact on lynx that might be in the area. Many land managers continued to manage based on out of date management documents, where there was theoretical concerns about recreational usage. Stakeholder concerns have resulted in the issuance of new management documents that avoids these types of issues in the future by clearly stating roads and trails in habitat are not a major factor for the lynx and that most snow compaction in the Southern Rockies is the result of natural processes rather than recreational usage.  The issuance of new management document supersede previous document avoids these types of issues in the future by clearly stating roads and trails in habitat are not a major factor for the lynx and that most snow compaction in the Southern Rockies is the result of natural processes rather than recreational usage. These documents clearly state that only major ski areas may impact lynx behavior and provide extensive analysis that weighs heavily against any claim of Wilderness areas being a benefit for the lynx.

CSA,COHVCO and TPA have partnered to provide a copy of these documents to every office that currently has a draft plan being developed or are areas where lynx management has been an issue previously.

Your input is needed on the Greater Sage Grouse Management Strategy to protect motorized access

The Department of Interior and Forest Service have released their draft plan for the management of the Greater Sage Grouse for public comment.  This proposal will impact the management of motorized recreation and many other uses on approximately 4 million acres of public lands in northwestern Colorado.  COHVCO actively supports any efforts to avoid the listing of a species on the ESA list, however, COHVCO is in favor of Alternative A of the proposal as we have many questions including:

1.  The status of the Greater Sage Grouse is currently unclear on the Endangered Species list - the Greater Sage Grouse was declared "warranted but precluded" under the most recent listing decision but this is no longer a viable listing status.  Alternatives should be developed or identified in the DRMP to address if the Greater Sage Grouse is listed or declined from the ESA list.

2a. There are large amounts of land that is modeled as grouse habitat but has not been actively occupied by grouse since the 1960's.  We question if this habitat remains viable and is properly classified as habitat.

2b. There are numerous references to snowmobile recreation in the California Park and Slater park areas but the proposed management of snowmobile recreation is never clarified. These areas must remain open as these are highly valuable snowmobile areas, Snowmobile usage does not impact leks or nesting behavior given the significant snowfalls that are required. California and Slater parks have not been occupied by grouse for a long period of time and are only modeled habitat.

3.  No new roads may be constructed in Grouse habitat areas.  This standard fails to address future multiple use, more specifically recreational use, or these areas and fails to address the time frame that closures will be compared against.

4.  Previous versions of the Management plan proposed to limit soil disturbance to 3% of habitat areas.  This proposal moves that standard to 5% but we believe this is too low and fails to provide flexibility for boundary areas with private property.

5.  Private land owner support will be critical to management of the Greater Sage Grouse as 50% of the habitat areas are privately owned.  Maintaining multiple use on public lands will generate significant support from private land owners in our opinion.

More information on the strategy is available here


Public meetings are currently scheduled for:

Public meetings will be held from 4 pm to 7 pm in October at the following locations:
  • October 15, in Craig, at the Memorial Hospital at Craig, 750 Hospital Loop
  • October 17, in Silt, at the BLM Colorado River Valley Field Office, 2300 River Frontage Road
  • October 22, in Walden, at the Wattenburg Community Center, 682 County Road 42
  • October 24, in Lakewood, at the Lakewood Heritage Center, 801 S. Yarrow St.
Comment Deadline: November 14, 2013

Send comments to:  
Mail to:  BLM-Greater Sage Grouse EIS, 2815 H Rd, Grand Junction, CO  81506
Electronically send to:  blm_co_nw_sage_grouse@blm.gov
Fax to: 970-244-3083
October 1, 2014 - CSA and 
COHVCO is involved in numerous Grouse planning initiatives with Federal, State and local agencies. The Greater Sage grouse plan proposal is currently out for comment. There are several areas of concern that we have since the plan is based on an endangered species that no longer exists, models larger tracts of lands as habitat areas that have not been occupied for a long time, caps road construction and tries to manage under absolute limitation for soil disturbance that will not work in areas where there are large tracts of private lands. Extensive comments were submitted on the proposed Resource Management Plan changes that were proposed by the BLM.

CPW and many other states submitted extensive comments against listing and Western Governor's Association summarized BLM response to these partners as an afterthought.  The Grouse process will prove to be an interesting case study in the BLM Planning 2.0 Process moving forward.  We are concerned that many of the Grouse process weaknesses are being carried through in the Planning 2.0 process as well.

COMMENTS SUBMITTED ON PINEY AREA NOPA SLATED TO CLOSE WINTER TRAVEL AREAS

CSA submitted comments stringently opposing plans by the Eagle/Holy Cross Ranger District to close a large area of winter travel area adjacent to the Red/White trail system in the Piney Ridge area.  It is their plan to restrict winter travel to designated routes only, however, because of current logging operation even the designated route is threatened.  The proposal is fraught with bad science, faulty suppositions and inequitable applications.  CSA will continue the dialogue with the White River National Forest and the Eagle/Holy Cross Ranger District.
 
October 1, 2014 - The future riding of snowmobiles in the Red and White area of the Eagle/Holy Cross Ranger district was put at issue as a result of a small timber sales that may have permanently closed the entire riding area encompassing thousands of acres.  As a result of local clubs' efforts and the Organizations efforts riding in this exceptional area outside Vail remains open for the future and clear management for any areas that are cleared is now in place.


COURT RULES AGAINST THE FOREST SERVICE IN WWA CASE

BOISE, ID (April 2, 2013)--Snowmobile advocates today responded to a recent decision in United States District Court for the District of Idaho, which directs the U.S. Forest Service to promulgate new motorized travel management regulations.  The decision was released on March 29, 2013, and declared unlawful the agency's 2005 Travel Management Rule for violating "plain language" in a forty-year old Executive Order and allowing it to be "discretionary" whether the Forest Service designates "areas of use or non-use" by snowmobiles.  The 2005 Rule was years and millions of dollars in the making.
 
While it is typical to conduct further proceedings to determine a proper remedy in an environmental case like this, the court's decision simply announces a new rule must be issued within 180 days.  The parties to the case, including snowmobile advocates Idaho State Snowmobile Association, American Council of Snowmobile Associations, and BlueRibbon Coalition, are still interpreting the court's ruling.  "This is either a tectonic shift or much ado about nothing," stated Sandra Mitchell.  "Forest Service rules and maps have for decades regulated not only areas of 'use and non-use' but details to the gnat's eyelash regarding winter use of specific roads and trails for motorized and non-motorized users.  If it does anything, this decision will create unnecessary controversy and further sap the planning budget of an agency already fearful of being raided in the name of fiscal reform," added Sandra. 
 
The decision is subject to appeal for sixty days.  A copy of the decision may be viewed HERE.

 
October 1, 2014 - CSA has been actively involved in administrative appeals prior to the Federal Court proceedings.  As this litigation was brought in Idaho, CSA has partnered with the ISSA to facilitate the defense of this matter. This partnership has resulted in several large donations being made by CSA to the Idaho legal defense fund and any resources necessary being available to our Idaho partners. 

CSA is also aware of similar litigation in California regarding winter travel management and notes the parallels between the WWA litigation and the litigation in Colorado regarding MVUM route designations. These are not isolated issues.

COMMENTS SUBMITTED

SAGE GROUSE-The Colorado Snowmobile Association has submitted comments on Sage Grouse habitat designation.  We have also attached a map of the area the designations affect.  We really encourage everyone to read the comments and familiarize yourself with the issue.  (See above for updates.)

WOLVERINE-In February of this year the US Fish and Wildlife Service announced their proposal to list the Wolverine as a threatened species under the Endangered Species Act.  In addition USFWS proposed two special rules designed to facilitate management and recovery of the species should it receive protection.  These rules are very important to Colorado and the efforts of CPW to re-introduce the Wolverine into the state.  Basically these two rules prohibit restrictions placed on activities occurring withing the high elevation habitat of the wolverine, including snowmobiling and backcountry skiing and land management activities like timber harvesting and infrastructure development. 

For the last 3 years members of COHVCO and CSA have participated in stakeholder meetings hosted by CPW to discuss the reintroduction.  These efforts have been targeted to ensure these basic protections of access that weren't in place when the Canadian lynx was released in the late 90's.  Because these proposed rules do offer these protections COHVCO, CSA and TPA have submitted Comments supporting the listing with the proposed rules.

October 1, 2014 - The US Fish and Wildlife Service recently determined there should be no changes in forest management as the result of a wolverine in the planning area.  This planning initiative addresses the management of millions of acres throughout the western United States and all areas above 10k feet in Colorado. The Organizations have been heavily involved in stakeholder discussions with the US Fish and Wildlife Service and Colorado Parks and Wildlife regarding best available science for the management of the Wolverine. As a result of these stakeholder meetings, best available science was clearly reflected in the recent USFWS listing decision as the decision clearly stated there should be no management changes on public lands as a result of the Wolverine. This is a major win as modeled habitat for the Wolverine in Colorado was any areas over 10,000 ft. and at one point closures to motorized access were seen as necessary in all these areas. This determination was a major step forward in protecting motorized access from misguided wolverine mangement standards.
 
While the USFWS has stopped the listing for reasons unrelated to science in the listing, the Organizations are looking at partnering with the Pacific Legal Foundation as part of the litigation that will surely result from the decision.


 

SOLICITATION
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