Articles tagged with: comment letters

Cal4Wheel Submits Objections to Eldorado National Forest Hazard Tree Mitigation Project

Cal4Wheel Submits Objections to Eldorado National Forest Hazard Tree Mitigation Project

On March 11, 2023, Cal4Wheel submitted Objections to a Roadside Hazard Tree Mitigation project for Eldorado National Forest (ENF). Previously in August 2022, Cal4Wheel submitted comments on the project’s Proposed Action for Scoping to urge the Forest Service to maximize the total acreage for hazard tree abatement in order to increase public safety, protect public access to motorized recreation opportunities and general outdoor recreation, and decrease future risk of wildfire. Of positive note, ENF included the full 2,461 miles from the original proposal within the draft final decision.

However, Cal4Wheel objected to other components of the draft final decision given that it fails to effectively fulfill the Purpose and Need for the project through unnecessary limitation on scope of implementation related to:

  1. Maintenance level 1 roads
  2. Catastrophic wildfire prevention
  3. OHV and outdoor recreation
  4. Social and economic impacts
  5. NEPA review

Additionally, Cal4Wheel offered the ongoing support of club membership as volunteers to support the success of both immediate hazard tree mitigation and post-project maintenance needs.

Read the Objection letter here

Cal4Wheel submits objections to Creek Fire Restoration Project draft decision

Cal4Wheel submits objections to Creek Fire Restoration Project draft decision

The Creek Fire Restoration project was presented for Scoping and public comment in early 2022. In 2020, the Creek Fire scorched 380,000 acres of Sierra National Forest, equating to 30% of the Sierra NF footprint in Fresno and Madera counties. The fire was exacerbated and quickly spread beyond the scale of normal firefighter response due to overly dense forest caused by decades of restrictions on logging, cattle grazing, prescribed burning, and vegetation management. Within the 380,000 acres that were burned, the fire consumed foothill, mountain, and alpine terrain - turning much of it into a moonscape of thick ash and blackened toothpick remnants of trees that previously featured beautiful forests, wildlife habitat, and outdoor recreation opportunities.

Cal4Wheel submitted comments during the Scoping and Analysis phases of this project in March and September 2022. The original project scope designated a 230,000 acre footprint, thus creating a restoration plan for 60% of the burn scar. Cal4Wheel advocated that Sierra NF should maximize restoration efforts by including a greater volume of acreage within the plan, and, maximize impact by simultaneously conducting projects to reduce future threat of fire by reducing vegetation density and restoring previously closed OHV routes to serve as fuel breaks throughout the terrain.

Unfortunately, Sierra NF caved to pressure from extreme environmentalists and released a revised plan that reduced the total acreage for restoration to a mere 31,976 acres - equating to just 13.8% of the original plan (230,000 acres) and only 8% of the burn scar (380,000 acres). Cal4Wheel submitted objections to the revised plan, citing negligence on the part of Sierra NF to fulfill their responsibility as contracted public land managers to effectively manage the forest for the benefit of the people by actively preserving a healthy landscape and wildlife habitat. Cal4Wheel additionally cited Forest Service infraction of NEPA violations including rigging the Purpose and Need of the project, detrimental social and economic impact, and discrimination of disabled persons due to restrictions of public access for OHV recreation. 

Read the full letter of objections via this link

Complaint submitted: Forest Service violations of NEPA process

Complaint submitted: Forest Service violations of NEPA process

Cal4Wheel submitted a complaint to request immediate resolution, and escalate a request for Congressional oversight, regarding the Forest Service’s implementation of NEPA (National Environmental Policy Act) process violations within the Sequoia and Sierra National Forest Land Management Plan Revisions objection resolution. The Forest Service (FS) has completed the final stages of revising the forest plans for the Sierra and Sequoia National Forests. Objection Resolution meetings were held on November 15-17, 2022, to discuss the draft Records of Decision and Revised Forest Plans with members of the public who had submitted comments and objections to the plan revisions. 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 Pacific Crest Trail 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:

The Objection Resolution meetings were attended by three groups within the OHV recreation community: Cal4Wheel, Stewards of the Sequoia, and CORVA. Multiple extreme environmentalist organizations were also in attendance, including: the Center for Biological Diversity, CalWild, Sierra Forest Legacy, the Pacific Crest Trail Association, and many more. Unfortunately, the FS disregarded the points of concern raised by Cal4Wheel and other OHV enthusiasts, while giving full attention and credence to the requests and suggestions raised by environmentalists. Additionally, the FS did not follow NEPA protocol within the objection resolution meetings.

Cal4Wheel raised concerns regarding FS violation of NEPA process during the objection resolution meetings, noting multiple elements of protocol that dictate how objection resolution must be administered. However, FS staff deemed those concerns irrelevant and proceeded to continue the meeting structure in violation of NEPA process. This disenfranchised Objectors of their fair opportunity to fully engage in the objection resolution process, nullified the validity of the Final Environmental Impact Statement (FEIS) and Final Record of Decision (ROD), and ultimately places the FS at risk of litigation. The complaint that Cal4Wheel submitted serves to document NEPA process violations within the objection resolution proceedings and outcomes, and to proactively seek resolution. Cal4Wheel has additionally reached out to members of the US Congress who represent districts that overlap with the Sierra and Sequoia National Forests, and members of the Congressional House Committee on Natural Resources, to request Congressional oversight of the FS and urge the FS to resolve all issues cited within the complaint prior to issuing a Final Record of Decision.

  • Read Cal4Wheel’s letter of complaint via this link
  • For more information about the National Forest planning process, visit this link
  • For more information about the Sequoia & Sierra National Forest Land Management Plan Revisions, visit the project website.

Cal4Wheel opposes expansion of critical habitat for Sierra Fisher

Cal4Wheel opposes expansion of critical habitat for Sierra Fisher

Cal4Wheel submitted comments to oppose the proposed expansion of critical habitat for the Sierra Fisher. The US Fish & Wildlife Service (FWS) released a revised version of the 2021 critical habitat proposal for the southern Sierra Fisher. The revision proposes designation of approximately 595,495 acres of critical habitat in portions of Fresno, Kern, Madera, Mariposa, Tulare and Tuolumne counties in California, which is an increase of 41,041 acres from the initial proposal.

Cal4Wheel's comments urged the FWS to objectively weigh all points of impact from this proposed listing – not only impact on Fishers, but also, impact on:

  • Other species of flora and fauna that reside in the same habitat as Fishers
  • General health and resilience of public lands where Fishers reside
  • Real and impending increased risk of catastrophic wildfire if additional restrictions on human activity are imposed on Fisher habitat as a result of approving this proposed rule
  • Social and economic welfare of humans who reside, conduct commerce, and recreate within the range of habitat occupied by Fishers
  • The accurate, factual impact of various human activities on the health of Fisher habitat and conservation of this species, including but not excluded to OHV recreation
  • The imperative for FWS to use the most current, accurate, best available science to clearly demonstrate the need and justification for this proposed designation of critical habitat

Read the full comment letter via this link

Photo courtesy US Fish & Wildlife Service

Cal4Wheel opposes listing of three species of salamanders as endangered or threatened

Slender Salamanader

Cal4Wheel submitted comments to oppose the listing of three species of Salamander as "Endangered" or "Threatened." After reviewing the proposal for listing, Cal4Wheel cited evidence of: 

  • Negative impacts to other species, OHV recreation, local economies, and balanced forest management 
  • Missing data within the analysis of need to provide protected status to each Salamander species

 Review the full comment letter via this link

Red Rock Canyon comments submitted

Red Rock Canyon comments submitted

Red Rock Canyon State Park recently released a Preliminary General Plan & Draft Environmental Impact Report for public review and comment. This Plan was crafted following four years of prior scoping, analysis, and public comment. 

Cal4Wheel reviewed the Plan and believes that SP has failed to resolve critical concerns that were raised, along with suggestions for remedy, during prior public comment opportunities. Additionally, some components of the Plan may place California State Parks at risk of executing a range of legal violations. In this comment letter, these issues are described in detail, with offer of recommendations to remedy each of the following:

  1. Misalignment with SB 155
  2. Equity of access for disabled visitors
  3. Violation of the California Desert Protection Act, and California Public Resource Codes (PRC) Sections §5002.2 and 5019.53
  4. Misuse of “Zones” to severely restrict public access
  5. Elimination of motorized access within Birds of Prey Natural Preserve

Review the full comment letter via this link

Cal4Wheel submits comments on BLM's Environmental Assessment for Moab area trails

Cal4Wheel submits comments on BLM's Environmental Assessment for Moab area trails

Cal4Wheel 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). The Labyrinth Rim / Gemini Bridges area is located just outside of Moab, Utah. It is a national destination for OHV enthusiasts as it boasts a network of over 1,100 miles of trails through stunning red rock canyons, arches, and exquisite desert landscapes. This area 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. 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:

Creek Fire restoration project comments submitted

Burned area south of Shaver Lake courtesy of Inciweb

Cal4Wheel has submitted comments dated September 21, 2022 regarding the draft environmental assessment for the Creek Fire restoration project in the Sierra National Forest. Read the comment letter at this link

Of positive note, Sierra National Forest (SNF) responded in favor to several suggestions that Cal4Wheel shared during the Scoping phase of this project. An important revision that was added to the analysis is: existing recreational roads will not be decommissioned as part of the CFR project.

Within comments for the Environmental Analysis, Cal4Wheel advocated for restoration of historical OHV routes that have been previously closed in order to:

  • Enhance the local recreation economy
  • Eliminate bias in public land access against persons with disabilities
  • Capitalize on the unique and important opportunity for SNF to be a trendsetter in building new roads and trails as part of burn scar restoration, where new roads and trails may be designed to optimally traverse the landscape in a manner that idealistically balances the needs and interests of public access, wildlife, and forest ecology

Additionally, Cal4Wheel offered the ongoing support of club membership as volunteers to support the success of both immediate forest restoration and post-project maintenance needs.


Cal4Wheel comments on Williams Hill Recreation Area plan

Cal4Wheel comments on Williams Hill Recreation Area plan

Cal4Wheel has submitted comments to the Bureau of Land Management (BLM) regarding the Williams Hill Recreation Area's draft plan and environmental assessment. Cal4Wheel supports proposed alternative B, which will design an OHV trail network and other recreational improvements in the recreation area.

Read Cal4Wheel's comments here.

Cal4Wheel submits comments on proposed rule for Foothill Yellow Legged Frog

Cal4Wheel submits comments on proposed rule for Foothill Yellow Legged Frog

Cal4Wheel's Natural Resource Consultant, Rose Winn, submitted a comment to the US Fish & Wildlife Service (FWS) to oppose a proposal to list four population segments of the Foothill Yellow Legged Frog (FYLF) as "threatened" or "endangered." If the listing is approved, there is risk of OHV access closures throughout FYLF habitat, which includes millions of acres of public land in the Sierra Nevada Mountain range and the coastal region of California. While FWS claims to use the best available scientific and commercial data available to determine the final decision, there is evidence that the proposal and impending decision have been heavily influenced by environmental special interest groups like the Center for Biological Diversity. 

Read the full comment here for more details. Cal4Wheel is proud to advocate for preservation of OHV access in California's public lands to ensure that everyone may continue to enjoy OHV recreation throughout the state.

For more information about this proposed listing of the FYLF, check out the proposal announcement in the Federal Register, or the full proposed rule docket with accompanying documents and roster of public comments.

17 organizations write to oppose Oceano SVRA's draft Public Works Plan

17 organizations write to oppose Oceano SVRA's draft Public Works Plan

The undersigned businesses, associations, and enthusiast groups are opposed to several provisions in the proposed Oceano Dunes State Vehicular Recreation Area (ODSVRA) Public Works Plan (PWP) that was released on December 30, 2020. If implemented as drafted, the proposed PWP would fundamentally change the operation of ODSVRA which has been open to off-highway vehicle (OHV) use for many decades.

Friends of Oceano write letter in opposition to Oceano SVRA foredunes closure

Letter asks State Parks to delay closure

Friends of Oceano write letter in opposition to Oceano SVRA foredunes closure

The California Coastal Commission has issued an emergency permit requiring California State Parks to immediately close 48 acres of camping area ahead of the Christmas and New Year's holidays, resulting in a 50% loss of camping spaces on the dunes.

In response, the Friends of Oceano Dunes have written a letter addressed to State Parks asking them to delay the closure.

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