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Natural resources report for November 2022

| Rose Winn, Cal4Wheel Natural Resources Consultant | Natural Resources Consultant Reports


The Forest Service is in the final stages of revising the forest plans for the Sierra and Sequoia National Forests and is currently working through the administrative review (objections) process for the draft Records of Decision and Revised Forest Plans. The revised drafts were released in 2019, however, revisions were altered since to account for changes across the forest terrain that resulted from multiple catastrophic fires in 2020 and 2021. Updates include designation of Wild & Scenic Rivers, efforts towards sustainable recreation, and an overhaul in structure of management of the Pacific Crest National Scenic Trail (PCT). Issues within the plan revisions that are of key concern to OHV enthusiasts include:

  • OHV trail closures in the Piute Mountains of Sequoia National Forest
  • Violation of federal law within the planning process and overhaul of PCT management
  • Bias of heavy input from the Pacific Crest Trail Association
  • Minimized public input from the OHV community throughout the planning process
  • Neglect to balance the Recreation Opportunity Spectrum
  • Disregard for the Forest Service’s contracted obligation to preserve multiple-use access to public lands, with explicit bias towards non-motorized recreation

Read Cal4Wheel’s objection letter via this link:

Objection Resolution meetings will be held on November 15 – 17 from 9:00am – 5:15pm daily. Objections from all parties involved can be viewed in the Public Reading Room. The Objection Resolution meetings are open to observation by the public. Attendees may join in-person or virtually:

 To Join In-Person:

Marriot Convention Center in Visalia
300 S Court St, Visalia, CA 93291

To Join Virtually:

Microsoft Teams meeting Tues and Wed – November 15 and 16

Click here to join the meeting
Or call in (audio only) +1 202-650-0123, 63597736#

Microsoft Teams meeting Thursday – November 17

Click here to join the meeting

Or call in (audio only) +1 202-650-0123, 947020815#

The topics slated for each day of the meeting agenda include:

  • November 15
    • Pacific Crest Trail Management Area
    • Recreation – Travel Management
    • Pack Goat Closure
    • Recommended Wilderness
    • Sustainable Recreation
    • Wild & Scenic Rivers
  • November 16
    • Timber and Fuels Management
    • Botany – At-Risk Plants
    • Riparian Conservation Areas
    • Wildlife – California Spotted Owl Habitat Management
    • Wildlife – WHMA and associated species (marten, goshawk, fisher); other at-risk species (willow flycatcher, great gray owl, and ESA species)
    • NHPA concerns with TRIB-FW-DC-02
  • November 18
    • Species of concern list – plant species
    • Species of concern list – Black Backed Woodpecker
    • Climate Change

For more information about the Sequoia & Sierra National Forest Land Management Plan Revisions, visit the project website.


On October 21, I submitted comments to the Bureau of Land Management (BLM) regarding their Environmental Assessment for an update to the Labyrinth Rim / Gemini Bridges Travel Management Plan (TMP). While my work as NRC for Cal4Wheel is naturally centered in California, this project is important for Cal4Wheel to be involved in as the Moab region is an iconic national destination for OHV enthusiasts across the US. This region is also frequently used as the testing-grounds for innovative product development across the OHV industry.

The Labyrinth Rim / Gemini Bridges area is located just outside of Moab, Utah. It boasts a network of over 1,100 miles of trails through stunning red rock canyons, arches, and exquisite desert landscapes. It is also the host site of the annual Easter Jeep Safari. BLM's proposed update could close over 400 miles of trails. Cal4Wheel objected to the proposed closures and advocated that BLM should consider increasing trail mileage rather than reducing it, given that BLM already closed over 700 miles of trails in this area in 2008. Prior to 2008, this region contained over 1,800 miles of OHV trails. If the BLM proceeds to close over 400 miles of trails with this proposed travel management update, OHV accessibility would be reduced to only 38% of the original OHV trail footprint. Additional trail closures would negatively impact user safety, potential resource damage, the local Moab economy, and the national OHV economy.

After analyzing the TMP Environmental Assessment, Cal4Wheel believes that the BLM has failed to resolve critical concerns and legal violations on the following Plan components:

  • NEPA analysis
  • Economic impact analysis
  • Omission of local resident and user insight
  • Cumulative impacts
  • Regulatory discrimination of disabled persons
  • Analysis of impacts to species of concern

Additionally, Cal4Wheel called on the BLM to abandon the current progression of the TMP update, return the full plan to its formative stages to conduct a valid evaluation of the issues noted above, and provide forums for relevant, robust public comment.

Read the full comment letter via this link:


Sierra National Forest recently launched the Motorized Recreation Plan Update project, with a commitment to the motorized recreation community to examine routes, not previously analyzed and decided, for potential addition to the FS System of roads, OHV areas, and motorized trails. The purpose and intent of the plan was to re-evaluate over 550 miles of OHV routes that were closed in 2008 to consider re-designating them as active routes in the MRP. The actual outcome of this project is a major disappointment, as the FS opted to add only 30 miles of routes back to the MRP, of which only 10 miles are for full size OHV.

On September 29, I submitted Objections on the MRP update. Cal4Wheel asserted that the limited addition of mileage is insufficient and does not serve to fulfill the purpose and need for the project - which is to enhance motorized recreation in SNF, provide a linked system of routes that accesses more diverse riding opportunity, create looped routes, and increase access to dispersed camping and recreation.

After analyzing the MRP Environmental Assessment, Cal4Wheel believes that the Forest Service failed to resolve significant concerns and legal violations on the following Plan components:

  1. NEPA analysis
  2. Alignment with existing Plans and Policies
  3. Negative cumulative impacts
  4. Negative economic impacts
  5. Analysis of impacts to endangered and threatened species

Additionally, Cal4Wheel called on the Forest Service to fulfill their contracted responsibility to balance the Recreation Opportunity Spectrum by analyzing all un-inventoried, non-system, and user-created OHV routes for consideration of addition to the MRP. Read the full objection letter via this link:

For more information on the MRP project visit the project website:


California State Parks has revised the General Plan for Red Rock Canyon State Park to address changing conditions, analyze the latest information and data, and incorporate lands that were added to Red Rock Canyon State Park since the Park’s 1982 General Plan was approved. While the current General Plan only covers the original 8,180 acres, the Revised General Plan will include the entire area of approximately 25,000 acres currently under park ownership and management. The General Plan presents the long-term management framework for natural and cultural resource stewardship, interpretation, facilities, operations, and visitor experience. It is the primary management document for a park within the State Park System, establishing its vision, purpose, and management direction for the future.

CA State Parks drafted an Environmental Impact Report (EIR) to meet the requirements of the California Environmental Quality Act (CEQA). Cal4Wheel’s concerns with the Draft EIR include:

  • Nightmare Gulch will be permanently closed to all but hiking and horseback riding due to alleged concerns over public safety and preservation of archeological sites
  • Part of Last Chance Canyon will be closed
  • Only street legal vehicles will be allowed, with the exception of a few connector routes
  • No Side by Sides (SxS) will be allowed in the park

Public comments on the EIR will accepted through December 2, 2022. Cal4Wheel will be submitting comments; and encourages members to get engaged by also submitting individual comments. For more information about the Red Rock Canyon State Park General Plan Update, visit the project website:


The US Fish & Wildlife Service (FWS) has proposed listing the relictual slender salamander as endangered and the Kern Canyon slender salamander as threatened. FWS is also proposing to designate 2,685 acres of critical habitat for the relictual slender salamander and 2,051 acres of critical habitat for the Kern Canyon slender salamander. This is of interest to Cal4Wheel, as 92% of the proposed critical habitat falls within Sequoia National Forest and lands managed by the Bureau of Land Management.

FWS is seeking public comment on the proposal to list and designate critical habitat for the relictual and Kern Canyon slender salamanders. All related documents are available for public review (available for viewing here). FWS will receive public comments through December 19, 2022. The proposal, information on how to submit comments, GIS shapefiles and legal boundaries can be accessed on by searching under docket number FWS-R8-ES-2022-0081.


The US Fish & Wildlife Service (FWS) has released a revised version of the 2021 critical habitat proposal for the southern Sierra Nevada distinct population segment (DPS) of fisher. The revision proposes to designate approximately 595,495 acres of critical habitat in portions of Fresno, Kern, Madera, Mariposa, Tulare and Tuolumne counties in California, an increase of 41,041 acres from the initial proposal. The revision identifies areas essential to the conservation of the species, which is currently listed as endangered under the Endangered Species Act. 

More than 90 percent of the revised proposed critical habitat falls on federal lands managed by the U.S. Forest Service (USFS), National Park Service (NPS) and Bureau of Land Management. During the public comment period, the USFS, NPS and a species expert from a research institute recommended additional areas for inclusion as critical habitat, mostly consisting of public lands. After reviewing the information, FWS agreed that those areas serve as important reproductive habitat for the fisher. FWS states that the revised proposal is not expected to restrict recreational access on public lands, however, historical trends demonstrate that designation of critical habitat frequently results in restrictions and closures of public access to public lands, including recreational access.

The revised proposed critical habitat rule was published in the Federal Register on November 7, opening a 45-day public comment period. The proposal, legal boundaries, GIS shapefiles and information on how to submit comments can be found on by searching under docket number FWS-R8-ES-2021-0060.

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