Winter Travel Management

Eldorado National Forest

SUMMARY

The DEIS, released on June 22, 2018, describes four alternatives: 1) current management, 2) proposed action, 3) non-motorized alternative, and 4) motorized alternative. Alternative 3 was submitted by Snowlands Network and Winter Wildlands Alliance. Alternative 4 was submitted by snowmobile groups.

Alternative 1

The current management of Eldorado closes 25% of the forest to snowmobiles. Most of this (17%) is designated wilderness. The remainder is recommended wilderness, primitive or semi-primitive areas, downhill and nordic resorts, and various special non-motorized areas. There are 58 miles of groomed snowmobile trail forming the Silver Bear Trail System near Highway 88 west of Silver Lake.

Alternative 2

Alternative 2, the proposed action, is barely distinguishable from current management. The alternative closes an additional 23,000 acres (4%) to OSV use, but the area closed is generally below 4,500 ft in the western portion of the forest. Thus, the Proposed Action does nothing to minimize conflict between motorized and non-motorized recreation in the important areas near Carson Pass, Echo Summit, Anderson Ridge, Loon Lake, and Ludlow Hut, in violation of the 2015 Travel Rule.

Alternative 3

The alternative we submitted to the Forest Service and that became Alternative 3 identified 21,500 acres (3.5% of the total forest area) of important non-motorized areas (those mentioned above) and specified that they be designated closed to OSVs. We also identified 123,000 acres (20% of the forest) where we knew that snowmobile use was occurring and designated those as open. We did not designate as either open or closed the remaining 52% of the forest not already designated or currently closed.

We invited the forest service to adjust those boundaries as they saw fit while keeping the non-motorized areas closed in their analyzed alternative. Instead they chose to designate as closed the entire 52% of the forest we had not designated. The result is that Alternative 3 opens only 20% of the forest to snowmobiles.

That seems very little compared to Alternative 2, but most of the land designated closed in Alternative 3 is low elevation and gets very little use by either snowmobiles or skiers. In fact, the Foreest Service estimates that most of the snowmobile use on ENF occurs on only 10% of the forest on the Silver Bear Trail System located on Highway 88 near the Iron Mountain Sno-Park and Bear River Reservoir.

Our alternative retains all 58 miles of groomed snowmobile trail.

Altenative 4

Submitted by snowmobile groups, Alternative 4 opens even more land (5,200 acres or 1% of the forest) to OSV use than current management. The alternative would open areas that are currently closed: the Caples Creek recommended wilderness area and several semi-primitive or special interest areas. Since opening these currently closed areas to motorized use would involve an amendment to the Forest Plan, the forest service is not likely to adopt this alternative.

PROBLEMS

There are numerous, significant problems with Eldorado's Proposed Action that violate both the National Environmental Policy Act (NEPA) and the 2015 Travel Rule.

The DEIS does not consider a full range of alternatives

The four alternatives described in the DEIS close 25%, 29%, 80%, and 25% of the forest to snowmobiles. NEPA requires that the Forest Service "consider all reasonable alternatives." There are obviously reasonable alternatives for designating areas and routes for OSV use that would fall into the range between 29% and 80%. The fact that Eldorado has not analyzed any such alternative is a serious violation of the NEPA requirement.

The Proposed Action designates open areas that are larger than a ranger district

The DEIS divides the forest into four partitions using ranger district boundaries and designates a single OSV area within each partition that is "smaller than a ranger district." However, since the "open areas" are adjacent to each other and snowmobiles can freely travel across these arbitray boundary lines without even knowing they are doing so, in reality there is a single, large open area that constitutes 75% of the forest. This is violation of the Travel Rule, which states that open areas must be "discrete, specifically delineated spaces that are smaller ... than a ranger district."

The Proposed Action makes no attempt to minimize conflict with other uses

NEPA regulations require that the Forest Service, in designating areas and routes open to OSV use must "minimize conflicts among the various uses of National Forest System lands." The Proposed Action designates as open to OSV use areas that are important to non-motorized users such as Van Vleck Meadow, land south of Highway 50 at Echo Summit, areas north and south of Highway 88 at Carson Pass, Martin Meadow at Carson Spur, and Anderson Ridge just north of Highway 88. These are all popular locations for cross-country skiers and snowshoers, and have been for many years. By designating these areas for OSV use, Eldorado has completely ignored their responsibility to minimize conflicts between snowmobilers and non-motorized users.