Contact: Dan Schroeder, Ogden Sierra Club Conservation Chair, 801-393-4603 or 801-626-6048
The Ogden Group of the Sierra Club, joined by three other conservation organizations, filed an appeal on Friday of the Forest Service's recent decision to open dozens of additional roads and trails in the Ogden Ranger District to motorized travel.
The Forest Service decision was made public at the end of March. If implemented, this decision would make motorized recreation the dominant use throughout approximately three-quarters of the Ogden Ranger District, at the expense of wildlife habitat, watersheds, quiet recreation, and other forest resources. Many currently nonmotorized trails would be opened to motorized travel, while several new ATV trails would be constructed.
The conservationists' appeal is based on the failure of the Forest Service to comply with several laws and regulations including the National Environmental Policy Act (NEPA) and an Executive Order (EO 11644) on off-road vehicle management signed by President Nixon in 1972.
NEPA requires agencies to fully disclose the environmental impacts of significant federal actions. The Ogden Ranger District, however, has failed to disclose many of the impacts of its decision. For example, its analysis assumes that starting on the day the decision is implemented, all motorists will stay on legally designated routes--even in remote areas where law enforcement is impractical and there are no physical barriers to off-route travel. Many of the affected routes cross between Forest Service land and adjacent state-owned or private lands, yet the Forest Service has not disclosed or analyzed the impacts of its decision on these adjacent lands. The Forest Service's analysis of impacts on nonmotorized users is especially superficial, based on inaccurate statistics that hide the reality of where there are outstanding opportunities for quiet recreation.
Many of the routes affected by this decision are intended to connect to the Shoshone Trail, a vast network of looping ATV routes that promoters hope will soon stretch from Brigham City to Bear Lake. The Forest Service and other agencies designated "Phase 1" of the Shoshone Trail in 2004, without public notice or NEPA analysis. The present decision would be a major step toward expanding this mega-trail system, whether or not the "Shoshone" name is ever applied to the additional trails. Further expansion is likely to occur in the upcoming Logan Ranger District travel plan revision, and in efforts by Box Elder and Cache counties to force private landowners to open their lands to ATV travel. However, federal regulations prohibit subdividing a large project into several smaller pieces for the purpose of NEPA analysis. By failing to disclose or analyze the full impact of this extended ATV trail system on wildlife and other resources, the Forest Service is in violation of NEPA.
Executive Order 11644 requires that areas and trails open to off-road vehicles on federal land be designated so as to minimize harassment of wildlife, damage to soils and vegetation, and conflicts with other uses of the land. Yet the present decision would result in severe and unnecessary impacts to these resources in several specific locations--most notably Box Elder Creek, Public Grove, and the Mollen's Hollow roadless area. Among the wildlife species seriously impacted are elk, sage grouse, sharp-tail grouse, and Canada lynx. Unfortunately, the Forest Service made no attempt to minimize these impacts as required. Instead, the Forest Service merely says that it has "considered" these impacts in its decision, and that impacts will be lessened by better management after the decision is implemented. The language of the Executive Order is clear in implying that mere consideration of impacts is not adequate, nor is postponement of attempts to minimize impacts until after routes are designated.
The Sierra Club and its allies believe it is possible to accommodate much of the demand for motorized recreation opportunities without serious harm to other forest resources. Over a year ago, conservation organizations suggested an alternative plan that would accomplish this. Unfortunately, the Forest Service rejected this compromise and even added more new motorized trails to the plan before announcing its decision. Setting aside its mandate to promote multiple uses, the Forest Service has acquiesced to the demands of a single user group that represents less than five percent of all Forest users.
Besides the Ogden Group of the Sierra Club, the appellants include three Salt Lake City-based organizations: the Wild Utah Project; Western Wildlife Conservancy; and the Citizens' Committee to Save Our Canyons.
To download the full text of the appeal (pdf, 220k, 44 pages), click here.
The photos below illustrate a few of the site-specific issues that were not adequately addressed by the Forest Service in its decision to open dozens of additional routes to motorized travel.
Photo 1. Pete's Hollow trail (26022), UTM 419628E, 4590245N, facing north, 26 May 2003. Between the creek crossing at the bottom of this slope and the cabin site on the ridge--a distance of about half a mileÑmost of the trail is comparable in steepness to this location, with a typical slope of 30%. The high brush on either side creates numerous blind corners. Many portions of the route, like this, are already deeply eroded below the original ground level. This route is unsafe and inappropriate for motorized travel.
Photo 2. Dock Flat complex (26010), Box Elder Creek trail segment, UTM 420405E, 4588789N, facing south, 25 September 2004. This trail has been closed to motorized use since 1988, but the closure was never implemented on the ground until late 2003. After that, quiet users returned to this area. This use would be largely displaced by the decision to open this trail to ATV's and motorcycles. Under the present decision, all nonmotorized trails in this area would be either opened to motorized use or obliterated.
Photo 3. Public Hollow Loop (20092), UTM 428362E, 4584506N, facing west, 4 September 2004. This is one of many points along this route where travel during wet conditions has created deep mud holes and severe route widening and braiding. Along much of the route the rutted and compacted area is more than 100 feet wide. A spring seasonal closure is not adequate to prevent this resource damage, because wet conditions can occur at any time of year.
Photo 4. User-created trail branching off Public Grove 4x4 route (20220), UTM 426286E, 4586145N, facing northwest, 14 May 2003. The Public Grove 4x4 route crosses the green meadow in the middle distance; Devil's Gate Valley lies beyond. This photo shows how in the open terrain there are no natural barriers to prevent off-route travel. Effective law enforcement here is virtually impossible, due to the remoteness of the area; gating the two (currently closed) routes that lead into the area, however, would be easy. This particular user-created route climbs directly to the location of a historic sage grouse lek. (Sage grouse are now quite rare in this area, though there have been occasional sightings in recent years.) This area is also high-value summer range for elk, whose habitat would be fragmented by motorized travel along route 20220. Since this photo was taken, the user-created route has been widened and lengthened by additional motorized use, despite the fact that this entire area has been legally (though not physically) closed to motorized travel since 1988.
Photo 5. Public Grove 4x4 route (20220) at Section 24 boundary, UTM 425554E, 4585740N, facing west, 17 November 2004. Illegal travel on this closed route has already resulted in severe route widening, braiding, and soil compaction, here and in numerous similar locations. The problem is exacerbated by the impermeable clay soils and by the open terrain which encourages off-route travel. This photo also shows that a spring season closure is not adequate to protect the area during wet conditions, since these conditions also occur frequently during the fall.
Photo 6. Davenport Hollow (20196), UTM 457360E, 4596416N, facing southwest, 4 July 2003. This photo shows the segment of route 20196 that has been closed to motorized use since 1988 but would be opened by the present decision. In recent years it has become a favorite destination for nonmotorized uses of the forest including hiking and wildflower viewing. Because almost every other ridge top in the Monte Cristo Range is traversed by a highway, road, or motorized trail, this route offers a unique opportunity for quiet recreation that would be lost if the current decision is implemented.
Photo 7. Sink Hole Loop (26012), UTM 426524E, 4589936N, facing northwest, 22 May 2005. This photo shows that the Sink Hole Loop route (originally created for, and still used as, a livestock driveway), is very narrow, built into a steep side-slope. Recreational use of this narrow, precarious route by pickups and SUV's is unsafe and could ultimately cause slides that would necessitate costly repairs. Furthermore, the route's only recreational purpose is to lead travelers onto private property that lies beyond, where the route descends an extremely steep, eroded slope that is also unsafe and causing resource damage.