May 16, 2018

Delivered via email to: objections-pacificsouthwest-regional-office@fs.fed.us

Objection Reviewing Officer
USDA Forest Service, Pacific Southwest Region
1323 Club Drive
Vallejo, CA  94592

RE:  Objections to Lassen NF OSV – New Information

Dear Objection Reviewing Officer:

Please accept these objections to the Draft Record of Decision for the Lassen National Forest Over Snow Vehicle Use Designation, as well as the associated Revised Final Environmental Impact Statement.  The Responsible Official is Acting Forest Supervisor Ted McArthur.

These objections are submitted on behalf of ________ (State Association/Club/Myself and my family) who enjoy snowmobiling and plan in the future to continue to enjoy over snow vehicle access to the Lassen National Forest.

The OSV Subpart C of the Travel Management Rule affects all National Forest Systems lands where snowfall is adequate for OSV use to be allowed.  These objections are submitted in accordance with 36CFR218, Subparts A and B.  These comments and objections are being submitted based on new information, Minimum Snow Depth.

Objection:  Minimum Snow Depth

The U.S. Forest Service should not  impose snow depth prescriptions.  The final OSV Rule does not set or suggest using minimum snow depths.  

Snowfall depth language was considered by the agency and intentionally left out of Subpart C.  See 80 Fed.Reg. 4507 (Jan. 28, 2015).  The Final Rule included roads, trails and areas for OSV use “shall be designated…where snowfall is adequate for that use to occur, and, if appropriate, shall be designated by class of vehicle and time of year….”

The guidelines for adequate snow in the RFEIS cannot be determined by snow depth measurements.  There are many common sense reasons to avoid a snow depth prescription.  Weather conditions vary greatly and consequently,  snow conditions vary greatly and are constantly changing.  

Snow depth is not an effective or necessary means to protect against resource damage.  Today’s snowmobiles are expensive and sophisticated and the owners know they are designed to travel over snow, not dirt and rocks.  Grooming equipment and operators are also sophisticated in the techniques to enhance the trail conditions.  Resource damage is best addressed through officer discretion in the field by applying existing regulations, rather than an inflexible snow depth requirement.  

There is not regulatory basis or compelling practical need to create such requirements.  The Forest, in cooperation with partners and engaged users can work together to address challenges in a site-specific manner.  

Thank you for taking these comments and objections into consideration.

Sincerely,

Cc:  Randy Moore, Regional Forester
        Congressmen