After reviewing the Travel Management Draft Environmental Impacts Statement (TMDIES) TuCARE offers the following comments in order to assist in making the appropriate decision that will benefit local stakeholders and at the same time provide for the long term health and vitality of forest resources.
Over the past decade there has been a dramatic decline in the federal timber sale program. Coinciding with the reduction of sale offerings there has been a drop off in road maintenance. Historically, road maintenance has been funded through the timber sale program. Road projects were developed and completed as part of sale contracts. The lack of maintenance has resulted in a number of problems with the transportation system. Some of the problems include, increased sediment inputs into streams from roads, culvert failures, restricted access, loss of surface material, road prism failures and general decline in the road drainage system.
Part 212 – Travel Management, subpart A 212.2(c) requires the forest service to develop, fund and maintain an annual “program of work for the transportation system”. The proposed alternatives will have a direct impact on local revenue to the community which should be considered. However the TMDEIS doe not have a comprehensive discussion on this subject.
The maintenance work generated from the various alternatives has the potential to impact local contractors. Due to the current economic downturn, it is important to know which alternatives will provide the greatest opportunity for local contractors. Which alternative will provide the best revenue stream for the community? TuCARE would like to request the forest service include a one-year program of work and a five-year forecast of work for each alternative.
Wildfire frequency and Fire suppression:
Increasing fire frequency in recent years has become the focal point in many land management decisions. It is a widely held belief that wildfire potential will continue to play a major role in future land management decisions across the region. Furthermore, the current decline in infrastructure has the potential to exacerbate this situation by delaying critical forest treatments. The changes being considered in the proposed alternatives have the potential to impact fire frequency and suppression, yet the TMDEIS does not discuss the matter.
This leaves a number of questions unanswered. Such as, which alternatives increase the probability of ignition from recreation sources? Will changes in road classification lead to slower response times, resulting in larger fires and higher suppression costs?
TuCARE would like to request the forest service conduct further analysis to determine the potential wildfire risks associated with the various alternatives.
Hunting and Fishing Recreation:
One of the greatest attributes of our National Forest System is access for hunting wild game. All across America there is a family heritage of hunting and fishing on our nation’s public lands. Local and valley residents have been traveling to the Stanislaus National Forest for many years to access hunting and fishing opportunities offered on the forest. Most trips to the forest take place early in trout season or late fall during deer season. Restrictions imposed by the wet weather closure provision and the expanded winter closure period will discourage sportsman and could lead to a decline in visitor days from this user group and subsequent loss of revenue to the community.
TuCARE requests the forest service drop the wet weather closure from the proposed alternatives. In lieu of the wet weather closure and the extended winter closure period we would like to see impacts mitigated through road maintenance projects such as surface replacement, road reconstruction, road drainage improvement.
Wet Weather closure:
As written all native surface roads, regardless of elevation, will be subject to closure for a 72-hour period after 1 inch of rainfall beyond September. This unfairly singles out hunters by limiting access during peak deer hunting conditions. A number of other hunting seasons will be shortened and/or interrupted. For example, spring turkey season runs from the last Saturday in March extending for 37 consecutive days. April is commonly a wet period. The wet weather closure will make it next to impossible to plan a trip during turkey season. Access during bear, quail, small game and fishing seasons are all impacted by this provision.
Expanded Winter Closure Periods:
As written all roads between 3,000 and 5,000 feet will be closed from November 30th to April 1st. Above 5,000 feet roads will be closed from November 30th to May 15th. The closure period for roads above 5,000 feet is completely unacceptable. The last weekend of April is the opening of trout season. Under this plan there would be no access for fishing, camping, or fish planting until the middle of May. The expanded winter closures will also have considerable impacts to hunting seasons similar to those mentioned above. Below are the dates and duration for the hunting seasons listed in the fish and game regulations. We have also taken time to provide the figures 1 and 2 showing the impacts to the various seasons.
California Department of Fish and Game Regulations:
- 361.Archery Season:
361. (a)(4)(A)(2), The archery season in Zones D-3, D-4, and D-5 shall open on the third Saturday in August and extend for 23 days.
361. (a)(4)(B)(2), The archery season in zones D-6 through D-10 shall open on the third Saturday in August and extend for 23 days.
361. Deer Season:
361. (4)(3)(B), The season for zones for D-3 through D-5 shall open on the fourth Saturday in September and extend for 37 consecutive days.
361. (4)(5)(B), The season in Zone D-6 shall open on the third Saturday in September and extend for 44 consecutive days.
361. (c) Special Hunts
360. (c)(13) G-37 (Anderson Flat Buck Hunt).
360. (c)(13)(B) The season for additional hunt G-37 (Anderson Flat Buck Hunt) shall open on the fourth Saturday in November and extend for nine consecutive days.
360. (C) (37) J-15 (Anderson Flat Apprentice Buck Hunt).
360. (C) (37) (B) The season for additional hunt J-15 (Anderson Flat Apprentice Buck Hunt) shall open on the fourth Saturday in November and extend for nine consecutive days.
360(b), the bear season shall open on the opening day of the general deer season as described in subsections 360(a) and (b) and extend until the last Sunday in December in the areas described in subsections 365(a)(1), (2), (3) (4) and (5) above.
Parking allowed off National Forest Transportation System Roads:
The preferred alternative and alternatives 3, 4, & 5 currently have a provision limiting parking off NFTS roads to one car length. This provision does not appear to be justified in the analysis and is overly restrictive. The Travel Management Rule states 212.51 Designation of roads, trails, and areas.
(b) Motor vehicle use for dispersed camping or big game retrieval. “In designating routes, the responsible official may include in the designation the limited use of motor vehicles within a specified distance of certain designated routes, and if appropriate within specified time periods, solely for the purposes of dispersed camping or retrieval of a downed big game animal by an individual who has legally taken that animal.”
TuCARE would like to propose parking up 150′ from the traveled surface of a system road for the retrieval of big game and access to dispersed camping.
TuCARE is committed to the “Wise Use” of our natural resources. It is our intention to provide comments that will reflect wise use and reasonable solutions to problems shared by us all.