Talking Points
Post date: Oct 10, 2018 10:18:55 PM
OK, here they are. Some basic talking points for writing you comments to the Bitterroot National Forest over mountain bike access to Wilderness Study Areas. These might get refined over time. If anyone want access to any of the Travel Plan Documents. let us know and we will work on posting them.
The Forest Service is publishing a corrected legal notice which restarts the 45-day objection period, giving the public additional time to object. If individuals or entities have already submitted objections, they do not need to resubmit them; they will be considered with all others received.
Following the Reviewing Official’s response, the Bitterroot Forest Supervisor will either modify the FEIS and Final ROD accordingly, or reaffirm the decision to close the additional trails to mountain bikes.
As directed by the court, the only issue to be considered during the objection response period is the closure of the Sapphire and Blue Joint WSAs to mountain biking. No other aspects of the Travel Plan will be subject to the objection process.
The new deadline to submit objections is November 19, 2018.
Objections mailed or hand delivered must be submitted to the Reviewing Official by one of the following methods; mail: Objection Reviewing Official, USDA Forest Service, 26 Fort Missoula Road, Missoula, MT 59804. Fax: (406) 329-3411, or email: appeals-northern-regional-office@fs.fed.us. Hand delivered objections must be delivered between 8am-4:30pm weekdays, excluding holidays.
Objections should include: 1) Objectors name, address, phone number, and organization represented, if any; 2) title of project on which the objections are being submitted along with the name of the national forest; 3) A description of those aspects of the proposed project addressed by the objection, including specific issues related to the proposed project; if applicable, how the objector believes the environmental analysis or decision specifically violates law, regulation, or policy; suggested remedies that would resolve the objection; and 4) objectors signature.
Please put “Bitterroot Travel Plan Objection” in the subject line for emailed objections. An automated response will confirm that your electronic objection has been received. All objections are open to public inspection and will be posted to the Forest Service website.
Key Points
The Montana Wilderness Study Act did not exclude “non-conforming” uses. Congress was clear that uses such as bikes were acceptable.
The multiple court cases over managing WSAs including the McAllister decision encouraged the FS to manage these uses and to consider alternatives other than wholesale area closures.
An analysis of national trends in mountain bike use extrapolate to the Bitterroot should not be considered adequate to establish that mountain biking has increased enough to impact wilderness character.
There was motorized use in both WSAs in 1977. That use has since been discontinued Replacing motorized use with quiet human powered mountain bike use should be considered a net increase in wildness character.
The minimal amount of hard data available does not support the assertion that mountain biking in the WSAs is commonplace. The Wilderness Institute volunteer evaluations of the Blue Joint and Sapphires encountered one group of two mountain bikers during their entire course of their studies.
There is no evidence of user conflict. The comments received regarding user conflict related to popular front country trails not remote backcountry trails.
The study of user conflict referenced in the EIS indicates that the vast majority of hikers (68%) have no problem sharing trails with bikes.
The misrepresentation of 660 miles of coincident routes (aka roads) as trails obscures the magnitude of the trail loss. Rather than the claimed 1,211 miles of trail there are at best 525 miles of single track outside of Designated Wilderness and Recommended Wilderness.
( The 525 miles subtracts the 68 miles of closed recommended wilderness trails from the claimed 593 miles of non=wilderness trail. I’m unclear where they get 593 miles. The trail inventory lists different numbers. I found 1009.7 miles total trail, with 601.3 in wilderness, or inversely 408.4 [340 miles if we subtract the RW miles] miles outside designated wilderness. This accords closer to when we have counted separately)
Trails in WSA account from 20 - 32% of total trail miles. By any measure this was a significant change from all the alternatives in the draft EIS. A change of this significance should have triggered a supplemental EIS. (The claim only additional 62,4 mile, but for some reason exclude sections of 313 that are in the Sapphire WSA and we believe Hole in the Wall should be considered in the WSA, not in the Anaconda-Pinter Wilderness. The maps show it outside. The boundaries were from the pre GPS/GIS mapping era, so boundary trails are sort of in no person land.)
Other Forests dealing with similar issues such as Colville National Forest have decided that the presence of bikes does not inherently degrade wilderness character and rather than ban bike they will physically monitor use and reassess access as needed.
Remedy: Trail closure should only be a last resort. They need a flexible adaptive plan that responds to future. We agree use has probably increased since 1977, but the magnitude of the growth should influence how it is managed. It matters whether there 10 mountain bikers a year or 1000, and whether our use intersects with other users. It might be that most other use is during hunting season, and date restrictions might be adequate, or there might be specific trails that have the greatest chance for interactions and only those trails need to be addressed.
Suggestion: Do not use the word mechanized as a synonym for mountain bike. It is a pejorative that wilderness groups have convinced the FS to use. It is used to make bikes sounds scary and anti-nature.