Southern Natural Resources Consultant Report - September 2019

Forest Service

The Comment period has closed on the USFS request for comments on the proposed National Environmental Policy Act (NEPA) rule change to update the analysis and documentation of Categorical Exclusions. This is a small but important point within NEPA. NEPA requires agencies to disclose and analyze the potential impacts their management decisions will have on the natural environment. This has led to an overly cautious administrative process that subjects most management decisions to an Environmental Assessment or a more complex Environmental Impact Statement.

However, buried within NEPA is the ability of management actions to be classified as “routine in nature” and receive a Categorical Exclusion for the more time consuming and costly EA or EIS. The proposed management actions continue to require an analysis that describes the proposed action. The proposed rule change would provide for a wider variety of actions (or decisions) to receive a Categorical Exclusion (CatEx) and proceed in a timely fashion.

For the OHV community, this would translate to fewer delays in replacing culverts and repairing trail damage. However, it could also lead to closure of routes with limited opportunity to repair the trail damage. Within the proposed rule, there are good points for OHV as well as the potential to have the proposed rule used against OHV. The comments received will be reviewed and could potentially modify the proposed rule. A final release of the proposed rule is not expected before early 2020.

Sequoia and Sierra National Forests

The Sequoia and Sierra have released their draft Revised Forest Management Plans. The public is invited to comment on the proposed plans. The comment period closed Sept. 26, 2019.

I attended meetings held by Sequoia and Sierra NFs concerning the draft plans and am reviewing the contents of the plans for their impact on OHV recreation. Overall, these draft plans are better than the last round plans. However, there are some points of concern that I have with the draft plans.

For the Sequoia NF, there is a proposed corridor for the Pacific Crest Trail that would define a vehicle exclusion about a mile wide. While much of the PCT is within wilderness boundaries, the segments outside wilderness, especially within the Piute Mountains, could be a problem for OHV recreation. The chief concern is the fact that Sequoia NF has yet to complete their required travel management plan for the Piute Mountains. This is the only segment of National Forest within California (and possibly the entire National Forest System) to not have a valid travel management plan. Should criteria be set by the Forest Plan Revision that impacts existing trails, it would be easier to eliminate the trails from impact rather than mitigate the potential impacts received between the PCT and OHV Travel Management.

The Sequoia NF also has numerous proposed “wild and scenic river” designations. At first glance, there are some points of concern; specifically, the order of proposed designation of wild and scenic segments.

Wild and Scenic River legislation provides for three classes of designation: Wild, Scenic, and Recreation. Each classification has prescribed management actions. A Wild classification is the most stringent and prescribes that certain actions must be taken to maintain water quality and the natural wild state of the river segment. In general, this would not be a problem if the Wild segment were located within wilderness area boundaries where the natural wild state can be preserved with limited potential impact by other forest uses/designations.

However, several proposed designations of wild and scenic within the Sequoia NF have Wild segments proposed downstream from Scenic and Recreational designations. There are several designated OHV routes that could be impacted by the Wild designation that would not be impacted if the proposed designation were changed to Recreation.

Bureau of Land Management (BLM)

The Bureau of Land Management is hosting a public meeting from 10AM to noon on September 17 at their Barstow Field Office, 2601 Barstow Road, Barstow, CA.

The BLM will be presenting information concerning the management of the Dumont Dunes Off- Highway Vehicle (OHV) Recreation Area for the upcoming OHV season and seeking public comment on proposed implementation actions. Discussions will include dates for the five holidays, road maintenance and signs, and visitor center dates, hours and activities.

BLM is working to install route trail markers throughout the Mojave Desert region. This has been an on-going project for about ten years. With the long delayed WEMO travel management coming to a close, Barstow Field Office is getting route markers installed. The new markers north of Dumont Dunes towards the California-Nevada border have drawn criticism from local residents and the environment preservation community that want OHV recreation limited around the Death Valley National Park boundary. Route designation signs are being placed and everyone is encouraged to abide by the signs permitting activity.


There are several proposed legislation actions at the state and federal level that will impact OHV recreation. Political campaign season is rapidly approaching. The California legislature tends to resurrect proposed legislation from the “dead file” and use “urgency” to have it passed. The federal Congress will be winding down activities and shifting to campaign mode by the end of the year.

Overall, the state and federal budget process will have significant impact on OHV recreation. Money and politics will be on full display in coming months.

About the Author

John Stewart

John Stewart

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