Update on Subpart A - Focus Group Meets for R5 Program

Yesterday, The General (on behalf of BRC) participated in a Region 5 focus group hosted by the Center for Collaborative Policy. The meeting was related to the September rollout of the Forest Service’s Subpart A Travel Analysis Process (TAP).

The following groups (a lot of heavy hitters) were invited to attend the meeting in Sacramento. Here is the list; American Hiking Society, Backcountry Horsemen Association, Blue Ribbon Coalition, California State Parks OHV Division, California State Water Resources Control Board, California Association of 4-Wheel Drive Clubs, California Equestrian Trails and Lands Coalition, California Off-Road Vehicle Association, California Outdoor Heritage Alliance, Center for Sierra Nevada Conservation, Great Old Broads for Wilderness, International Mountain Bike Association, National Forest Recreation Association, Pacific Crest Trail Association, Recreation Outdoors Coalition, Regional Council of Rural Counties, The Wilderness Society, Trout Unlimited, and the Wildlands CPR/ Natural Trails & Water Coalition.

Six Steps of TAP
http://www.fs.fed.us/r3/cibola/travel-management/tm_magdalena/tap/appendix_i/appendix_i_summary.pdf

The FS said the main focus of TAP in Region 5 is to analyze level 1 and 2 roads. Remember that level 2 roads are the roughly graded roads that are open to green sticker vehicles. TAP will also look at level 3-5 roads and some trails although the agency spokesman said that system trails are not part of this process.

HQ has several initial concerns with this process. First, TAP (a non-NEPA process) is replacing the Roads Analysis Process (a NEPA process). Although the agency said TAP is not a decision document, it will in fact be used to influence or drive subsequent site-specific (road ripping/decommissioning, road closures, trail closures) and programmatic (Forest Plans) NEPA processes.

Historically, anti-OHV groups advocate for NEPA to be used on all planning efforts (with a special focus for OHV) because it allows them to gum up any trail project with appeals, lawsuits, and objections. However, when The General and CAL4WD articulated our concerns about TAP not being a NEPA process… the hard-core green groups sat in stone cold silence with Cheshire cat grins on their faces. That silence spoke volumes.

Secondly, the past history of Region 5 creating special and unique access restrictions (i.e. 3 mile limit on mixed-use roads, little or no designation of unauthorized routes, etc.) because of threats of lawsuits or the actual filing a lawsuits could mean that the game is rigged where the greens bury the agency with an avalanche of “environmental concerns” thereby creating controversy… thus closures. Many of us witnessed that paradigm in Subpart B of TMR in Region 5 and it could rear its ugly head in TAP.

Third, R5 has set a hard deadline of January 2012 for completion by all Forests in CA. HQ has concerns about arbitrary deadlines that preclude a quality product such as was evidenced in Subpart B.

The “trust factor” was also brought up for discussion by the spokesperson for Rural Counties.

The representative from the California Outdoor Heritage Alliance made the point that the historic use of the Forest (hunter camps, fishing access, OHV use, equestrian trails, etc.) is already well known by the Forest since much of that use has been going on for decades. And, the fact that the public is using the Forest should be a key foundation in TAP.

HQ believes that historic and current use should be just as important if not more so than the soon to be released data dump by enviro groups citing pending environmental disasters if most of the roads used by OHVs are not closed.

Be assured, HQ will continue to give input into TAP and will review it when rolled out in September. Will TAP be simply a continuation of a process that disenfranchises the public and local governments or will it be a new start? That question will have to be answered by Region 5.

Thanks for your service and thanks to the pro-access groups for being there!

PS – It was disappointing and embarrassing to see IMBA carrying the water for the anti-OHV groups at this meeting.