My name is Dan Heinz. I was deeply involved in development of the White Pine County Lands bill. I have been a regular participant in the County CRM committee since its inception 15 or so years ago representing conservation viewpoints from Western Nevada.

Today I am representing Backcountry Hunters and Anglers. This is a relatively new organization with members in 43 states, including Nevada, with several in White Pine County.

Backcountry Hunters & Anglers is a national organization of outdoor enthusiasts who prize the tradition, challenge and solitude of America’s backcountry. BHA is a 501c3 non-profit charity that works to conserve big, natural habitat and healthy rivers and streams. We work so our kids and grandkids are free to enjoy the high-quality hunting and fishing we cherish.

All of our members tell a familiar story — working hard and playing by the rules, only to have illegal or inappropriate riders on ORVs shatter their experience, scare away the wildlife and damage the habitat. It’s happening all across the country, over and over again. (I use the nomenclature adapted by the New Mexico State Senate: OHV refers to full sized 4x4 vehicles. ORV refers to ATVs, Dirt Bikes etc.)

BHA is not advocating reduction of existing designated motor access. We do not oppose responsible use of a planned transportation system. We have been supporters of the Steptoe Valley collaborative transportation planning effort from the start.
The White Pine County Bill designated a lot of Wilderness in the County. It is well to remember this was the direct result of disturbance by an invasion of ORVs. This turned a strongly anti-wilderness county to one favoring Wilderness.

The Silver State Trail does not add any motorized opportunity. It is intended to attract more, likely a lot more, ORV use to existing routes. The stated intent has been to designate a backcountry ORV trail all the way through to Idaho with a branch through to western Nevada. BHA must oppose efforts to increase ORV use when efforts to manage this problematic activity are just getting started.

ORV-focused recreation use is very much in the minority. Detailed FS surveys over many years on the Humboldt-Toiyabe show that only around 10% of users come here primarily to use an ORV . The BLM website once showed ORV use on BLM lands to be only 9% of all recreation use. Yet ORVs use a very disproportionate share of resources, and require significant management expense.

We feel White Pine County must not attract more ORV recreation than you and the agencies have the resources to administer. Law enforcement, route maintenance, signing, search and rescue must all be financed.

It is unavoidable: Acceptable resource impacts from current ORV use will increase to unacceptable levels as traffic increases.

The EA failed to recognize in any way that attracting increased use to the trail will inevitably result in many users branching off into adjoining routes. This will increase adverse impacts to sensitive resources. The obvious answer is to close ORV access to sensitive areas along the full length of the trail. Thus, the net effect of a SS trail would be to decrease backcountry touring opportunity for ORV users.

Analysis of the inevitable disturbance to other values, uses and resources along these spur and loop routes must be a consideration included in determining whether there can be a Silver State trail or not.
Closing such a trail once use is established and solicited nationally would be very difficult indeed.

The EA does determine that the trail will increase use and adversely affect existing “wildlife, natural or cultural resources, or traditional uses” near the trail. The White Pine County Bill states a trail may be designated ONLY if SST route DOES NOT cause significant negative impact to any of these values. (caps mine)

The route passes within ¼ mile of at least 26 springs. 3.14 miles of the selected alternative pass within 100 ft or closer to wetland/riparian zones.

People who use a vehicle to access a specific site for camping, loafing, birdwatching, letting the kids splash in the creek, hunting, etc. are the vast majority of public land recreationists. These are the people most often impacted by ORV-focused recreationists. Most people visit our public lands to experience quiet and solitude. The noise and dust of ORVs is incomparable with destination recreation.

The EA does state that increased use from the SS Trail will likely displace these users near the trail.

The Preferred Alternative C displays the highest impacts of the alternatives considered and considerable impacts are acknowledged.

Quotes from the EA:

Wildlife
4.6.4 Alternative C

“Additionally, routes associated with Alternative C were not selected to avoid areas of crucial habitat for wildlife species. Routes associated with Alternative C travel through 53.46 miles of mule deer crucial summer range and 15.51 miles of elk crucial summer habitat”.
“Routes associated with Alternative C were not prioritized to avoid areas of important resources for wildlife. As a result, the risk of impacts to migratory bird species under Alternative C would be greater than those described under Alternatives A and B.”

Wetland/Riparian
4.5.4 Alternative C
“The risk of impacts to wetland/riparian zones associated with Alternative C would occur over a greater area than under Alternatives A or B.”
“Increased OHV use within the project area would result in an increased risk of direct, long-term impacts”
Cultural Resources
4.2.4 Alternative C
“Alternative C would result in a greater risk of disrupting sites and intruding on the historic settings of heritage areas in the County.”
Rangeland and Livestock grazing
4.10.4 Alternative C
“Impacts from Alternative C would be similar to those described under Alternative A. However, impacts would be more intense because of the greater overall length of Alternative B (354 miles) and the additional east-west leg. Additionally, Alternative C crosses through 32 allotments.”

Dispersed recreation opportunities p53
“Increased OHV use would result in individual big-game animals avoiding areas near the alternative route. This would indirectly result in displacing hunters to different routes and different areas of the game management units to avoid increased OHV use and for more quality hunting opportunities”
Developed Recreation p 52
“In the long term, as more individuals become aware of the SST, it is assumed that use would become progressively greater. Increases in motorized recreation at these sites over time would result in greater user conflicts and displacement of non-motorized recreation uses to other nearby developed recreation sites. “

NDOW tells us BLM did avoid many sensitive areas, but added “ The fact remains that the route passes within 1/4 mile of at least 26 springs or other surface water features and still runs through some areas of sensitivity where it comes over the Egans, over the Schell Creek Range north of Schellbourne and the Becky Peak portion where it runs through higher elevation areas that are relatively dense with water sources.”
True, it is a subjective judgement whether the negative impact limitations to wildlife, natural, traditional uses or cultural resources exceeds WP Co. Bill legislated limitations. The EA documented many inevitable negative impacts. Reasonable judgement would say proposal impacts are, at best, very near, if not over, the unacceptable level.
The EA did fail to assess the inevitable negative impacts caused by increased use off of SST These impacts are almost certain to push impacts well over the unacceptable threshold.
Backcountry Hunters urges the White Pine County Commission to request the BLM to withdraw the decision notice and revisit analysis, paying particular attention to the predictable future increases in impacts.

Sincerely

Randy McNatt, Chairman by