Friday, September 16, 2011

Sept. 19 Field Hearing - FS TMR Constructed on Foundation of Sand?

By now, many HQ followers are aware of the House Subcommittee on National Parks, Forests, and Public land’s field hearing being held in Sacramento on September 19, 2011.

BRC Alert with Info on Sept. 19 Hearing

For several years, HQ has blogged about how the 2005 Travel Management Rule was being misused on number Forests as a planning tool to effect landscape level closures of historic roads and trails to non-street legal (and in many cases street legal) OHVs.

HQ is not the only venue that feels TMR has gone astray. The Chico Enterprise-Record just published an editorial that concurs with our observation.

Chico Enterprise-Record Editorial (Sept. 16)

Wisdom tells us that you should not build a house on a foundation of sand. HQ believes many of the fatal flaws now clearly evident in TMR have their origin in the 2003 California Route Inventory and Designation Process (RID). Proponents of RID (as in get rid of OHVs on public lands) said users did not have to worry about landscape level closures of historic (and legal) OHV routes. In addition, RID/TMR in Region 5 also included the additional “thumb in the eye” of creating a new federal directive that effectively prohibited (except on rare road segments less then 3 miles in length) non-street legal “Green-sticker” OHVs from using level 3 non-paved logging roads. What makes the R5 ruling even more offensive is the California Vehicle Code expressly states that Green-sticker OHVs are allowed on non-paved logging roads.

CVC 38001

Back in 2003 when RID was codified, several FS staffers told HQ offline that supporters of RID would rue the day. BRC strongly protested RID because it was basically an underground regulation created without a formal public process as required by NEPA. Based on the expected tone and direction of the September 19 field hearing it looks like those RID/TMR “planning chickens are coming home to roost.”

Can TMR be salvaged in CA and elsewhere? HQ believes it can, but the agency must work hard to address the user’s legitimate concerns and restore public trust. The FS should also start their long heralded post Subpart B project level trail planning.

Sand should never be used as a foundation nor should it be used as a place where you stick your head. Instead, good planning and management should be based on solid rock and you (the FS) should man-up and admit that mistakes were made in RID/TMR.

See you at the September 19 hearing.

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