This year on June 28th 2018, Region 6 of the Forest Service posted the updated proposed Forest Plan for public comment. The comment period was for 60 days, ending August 27th. Then followed a written request as an interested party that was due Sept 17th.
The Forest Plan documents are online only (HERE) and have links to previous and supporting documentation as well as a so-called “interactive map”. NWTRA was eligible to produce a comment letter (2018 Forest Plan Objection Letter) and a written letter of recognition (2018 Interested Party). All Objection letters are located on the Forest Service site.
So to get you all back up to speed, it is time to review: The BMFPR is a “Forest Plan” that “…. guides land management decisions (project or site-specific level planning) for a period of about 15 years. The Forest Plan is strategic in nature and does not approve projects or actions on National Forest System (NFS) lands; for example it does not close specific roads, trails, or areas – further NEPA (National Environmental Protection Act) and public engagement is required on these types of site-specific level decisions”
What then is the BMFPR? From the Forest Service; “It is a document that guides land management decisions (project level planning) for a period of about 10 to 20 years. It is strategic in nature and does not approve projects. Similar to elements of a county zoning plan, which require approval prior to beginning a project, parts of the forest plan describe desired conditions, suitable uses, and design criteria for project planning. On lands guided by county zoning plans, unless outright allowed by the plan, projects proposed by individuals or companies cannot be initiated without demonstrating compliance and obtaining the proper permits. Example: a home builder wants to build on land zoned for residential use. The builder must submit a building plan to the building and planning departments. It will be reviewed for compliance with the land use plan, building codes, property setbacks, height restrictions, etc., after which construction can begin. Comparably, projects proposed for National Forest System lands must be analyzed for compliance with laws and regulations along with adherence to forest plan direction, with all analyses documented by following the NEPA process. Once the analysis and public review are complete, the responsible official decides whether or not to implement the proposal either as is or with modifications to it”
The Winom-Frazier and Desolation OHV Trail Complexes are currently operating under the 1990 Forest Plans . This plan has had amendments that have described certain actions from allowing specific timber harvests to restricting specific use. But these amendments still had to follow the strategic plan of the 1990 Forest Plan. As described in the BMFPR Winter 2009-10 Newsletter this Blue Mountain Forest Plan Revision has been in process since late 2003. Initial meetings for the Blue Mountain Forest Plan in 2010 with the Draft Environmental Impact Statement (DEIS) meetings in late March and early April 2014, then more changes behind the scenes, with a new alternative (not reviewed by the public) in June of 2018.
The concern the NWTRA has that all of the other aspects of this new Forest Plan can direct actions in its guidance or strategic nature to our motorized use. For Example TRAVEL MANAGEMENT. Umatilla National Forest(UNF) operates under a far different Travel Management Plan than Wallowa-Whitman and Malheur. UNF has designated routes and Motor Vehicle Use Maps (MVUM) the others do not. Adoption of a new Forest Plan like Alternative E-Modified 2018 WILL dictate a new Travel Management Plan in those forests to be like the restrictions in freedom of Umatilla NF. Specifically the NWTRA objected special management areas of Backcountry Motorized (3B) which will maintain or decrease all motorized access within those areas by there definition.
Remember, this process started in late 2003, for a 1990 plan, that by their rules should be updated every 10years, but they also say has a lifespan of 15years (Huh?). So the supporting documents are as old as the start of the process or older. The Forest Service conducted multiple studies on its own and utilized studies by others for all aspects of the plan. This includes the Off-Highway Use and Collaboration (CaseStudyReport on OHV 2005) study that reviewed OHV use then and in the future. A national study of OHV use was conducting showcasing a steady growth in OHV sales and use nationwide (National OHV use survey 2008). Also an Oregon State motorized use Motorized Trail Plan (Motorized)
In addition the Forest Service conducted the “Wilderness Need Evaluation” . Below are links to each forest having specific areas:
· Umatilla: · Wallowa-Whitman: · Malheur:Now as of September 2018, the Forest Service has the final draft of the Forest Plan (HERE). This is the only way to view the plan as there are no plans for physical printed copies. On this site is the Letter from the (retired the day after the letter) Regional Forester, James Pena~, his rational (draft record of decision) for picking the alternative he did, Alternative E Modified, each of the forests individual plans, the biological opinions from member agencies, maps (pdf) and an interactive map.
Read the Draft Record of Decision. Here you can see why the former Regional Forester Pena recommends 70,000 plus more acres of Wilderness across all 3 forests (in the face of local recommendation of zero) and why he does not recommend the Alternative E Modified-Departure. Then you can dive into each forests’ plan. For Winom-Frazier it is Umatilla’s and Wallowa-Whitman’s.
The Forest Service has removed any reference to “designated routes” from the Wallowa-Whitman or Malheur plans, letting the Travel Management plan (coming after this is approved) to take on that issue.
There is not much within each alternative to explain why, just the expectation of “Desired Condition”
The maps included are very vague with very limited reference details like section lines or secondary roads to give the viewer a reference. In addition, some major locations of items are wrong. This unfortunately is no change from 2014.
An Overview of the planning process for the BMFPR according to the Forest Service (FS) is described here.
Additional reading is the BMFPR DRAFT Executive Summary Need for Change (Forest Plan Overview). Here the FS discusses the reason why the update is needed. The interesting thing to note is the need of “The Current Forest Plans (1990) Do Not Fully Address Sustainability” section and its specific framework. This framework is utilized within the 2010 BMFPR. Also within this overview is the “Direction for Off-Highway Use is Not Adequate”. Here the key statement is “Motorized access was the single most urgent topic for the participants in the Community Collaborative Workshops”, indicating the Forest Service knows that we exist.
TO NOTE VERY CLEARLY: These current plans are just updates of the previous language on paper. There is NO REFERENCE to the changes in the forest since 2014, such as recent forest fires, so a number of the known conditions are woefully false. Which if the Forest Service is going to try to achieve their “Desired Condition” in these areas, the starting point is way off.
NWTRA Official Comments and Letters:
NWTRA Comments on Back Country Areas
2018 Forest Plan Objection Letter