NV BHA wholeheartedly supports no off-route motorized travel, as directed by the DC office.

NV BHA does not support off-route game retrieval in either the Proposed Alternative or Alternative 4. (See further comments below)

The FEIS does a better job than the draft of displaying negative effects of significantly increasing the FTS. However, there has been very little change from the draft in the miles of FTS additions which reflect response to those stated effects. The effects displayed make it evident that a decision for “the greatest good, for the greatest number, over the long term” will require considerable closure of unauthorized routes. By adding over 1000 miles of unauthorized routes to the system, the Proposed Alternative clearly does not address the effects displayed in the document. Except for the No Action alternative, any of the other alternatives would be a more appropriate response than the proposed one.

This is an EIS intended to analyze the impacts of each individual route to be added to the FTS. The EIS does describe and compare impacts between alternatives, but it does not display any effects of individual routes in any useful detail or track the decision logic for individual routes. For example: We need to know how many, and which roads impact specific habitats for elk, deer, T&E species, and species of special concern. Your thresholds for unacceptable potential impact causing rejection or acceptance of a potential route do not appear to be discussed or displayed.

Averaging and lumping overall effects at the alternative level obscures the likelihood there are proposed individual or groups of route additions that have unacceptable erosion, wildlife disturbance, disruption of the limited opportunity for SPNM experience, etc. The FEIS describes in detail completely unacceptable road conditions at Pratt Creek, Badger Creek, Jack Creek and Pole Creek as examples. These are the only roads discussed in any detail. Even then, without road numbers we cannot determine whether these roads were or were not dropped from the preferred proposal. The apparent absence of all this basic, essential information lends an arbitrary tone to the FEIS. We are left wondering if the only reason for many additions is to placate a noisy crowd.

NV BHA understands a document which discusses every individual proposed route in detail will be excessively cumbersome. However, far more discussion of impacts to specific individual or small clusters of routes proposed is essential. Proposed FTS additions in IRAs especially deserve a special effort to confirm they do or do not cause unacceptable impact to any resource.

Recreation

The FEIS does a good job of making it clear that motor-focused recreationists are very much in the minority, comprising only 16% of NF recreation users (p. 72).We cannot see that this fact has affected the decision process in any way.

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Tables on pages 80 and 86 show that there is no quantifiable difference in degree of change to non-motor users between any of the alternatives. Analysis found in other areas of the FEIS shows significant differences in degree of change between alternatives, especially to the ROS. Since non-motor-focused recreationists outnumber ORVers by at least 6 to 1, the fact is that far more people are negatively affected by the Proposed Alternative than any other alternative.

The response to our DEIS comments repeatedly states that our comments re: recreation user conflicts are invalid because “there are no documented records of user conflicts”. We find this surprising since we hear frequently from hunters and other recreationists of disturbance by ORVs, often in the Bruno and Elk Mountain areas. If you doubt this, you might start by querying NDOW folks.

You must recognize it is most difficult for people who disagree with the extreme anti-government attitude in Elko County to speak up on public land issues, especially on the issue of motor “access”. We know people who will not stand up and be heard at public meetings, others are even reluctant to go on record. Still others dispare there is any hope reason can ever prevail in Elko County so do not try. We hear from all of these people. It is too bad we did not start documenting these complaints sometime back.

Also, experience from other National Forests tells us that non-motorized users most often just fade away without comment and seek quiet opportunities elsewhere. It is likely areas of existing frequent motor use have already lost users preferring a non-motorized experience.

We are concerned that these apparent misreadings of the realities of motorized/ non-motorized recreation experience relationships has colored much of your decision process.

Game Retrieval Option

NV BHA opposes any off-route motorized big game retrieval (MBGR).

FS personnel told us exception will only be allowed to retrieve elk. The document says it will be allowed for deer also. This must be clarified.

Your discussion of the ½ mile allowance for MBGR is misleading. On the ground reality is that rarely will travel direct to and from the kill site be possible. In fact direct travel is likely to be on the fall line and expose the tracks to excessive erosion. Round about travel to the kill site will be necessary in many instances, leaving long, often new, tracks with all the likely resource impacts.

Skill level, knowledge, and land ethic motivation of the operator are all subjective criteria and route choice variations will produce widely variable resource impacts. Serious and unnecessary abuse would not seem to be an punishable offense.

Experience in other states shows that when off-road vehicle use for game retrieval is not possible or prohibited, local ranch-based , horse retrieval business will develop. We put the question to two Elko County ranchers, one of which is already providing some game retrieval service: Is a retrieval service business apt to develop if the FS prohibits game retrieval off designated routes? Both sources say yes, horse retrieval service will likely develop if MBGR is prohibited.

The FEIS makes the mistaken assumption that refusing MBGR will have a negative effect on the economy. The opposite will likely be true. MBGR will remove the opportunity for local retrieval business to develop. Pre-empting this job-creating economic activity by permitting MBGR clearly needs to be displayed in the FEIS as a cost of allowing machine retrieval.

There is more demand for big game hunting permits than can be issued. No other NF District in the state will allow MBGR. It is most unlikely MBGR regulations can affect numbers of hunters one way or the other.

Consistency statewide of no motor retrieval will eliminate hunter confusion and the enforcement difficulty sure to result if MBGR is allowed on Ranger Districts in Elko County.

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The FEIS states that 99.5% (p.50) of SPNM hunting opportunities will disappear if MBGR is permitted.

The FEIS admits that off-route retrieval will likely create lasting tracks and may cause significant erosion. It is also made clear that such impacts are prohibited by CFR.

Thus, the FEIS clearly demonstrates that the benefits of allowing MBGR to a few cannot outweigh the costs to many.

IRAs

We must continue to oppose designating unauthorized routes within IRAs on the FTS.
To do so is tantamount to constructing a new road which is clearly prohibited by the 2001 rule.

In addition, roads within IRAs, already in the FTS, must not be gradually upgraded to a higher standard (IE. making a 4x4 trail into a route travel-able by 2x4 pickups, etc.). The FEIS should make it very clear that only erosion control maintenance will be performed within the boundaries of IRAs. I think you will find ORV recreationists enthusiastic in their support of such a directive.

The FEIS describes the reasons for routes and spurs for camping around the periphery of IRAs, enabling access to the IRAs for quiet recreation (p. 60). NV BHA can support these types of short spurs and routes within .1 of a mile of the border , provided it is demonstrated they do not invade significant wildlife habit, are not subject to unacceptable erosion, etc. This type of route can provide opportunity for the large majority of recreation users on the Forest.

However, the charts in the FEIS do not distinguish between miles of routes penetrating the IRA's from the routes/spurs on the periphery of IRAs. Our endorsement of the concept on p. 60 is qualified: we oppose routes and/or spurs being added to the FTS penetrating deeper than .1mile into an IRA.

NV BHA supports retaining all areas inventoried as roadless, whether or not they qualify as having roadless or Wilderness characteristics . They all provide quality habitat and quality hunting opportunity away from the disturbance of motor vehicles.

Your reply to our comments to the DEIS strongly states that using the term “renegade routes” is misleading and inappropriate. It is a poorly kept secret that there are individuals and groups who deliberately create new routes to pre-empt future Wilderness classification or other restriction of motor access. This has been occurring almost since passage of the Wilderness Act. It is likely that a significant number of the routes in IRAs are indeed these “renegade routes”.

You no doubt avoided legitimizing some such routes when you did not add any routes created after 2001 in IRAs. It is also likely many unauthorized routes created before 2001 also qualify as “renegade”. It would be excellent policy to exclude all routes created after the 1986 plan.

NV BHA hopes it has not escaped your attention that most national sportsmen organizations, such as the 100,000 + member Rocky Mountain Elk Foundation have gone on record opposing HR.1581 which would eliminate protection for Roadless areas. In addition, the national outdoor tourism industry has echoed that opposition. Clearly, the value of Roadless areas needs to be accurately delineated in your Economic analysis.

Wildlife

We are told density analysis for elk and deer habitats were not done because “ there was not a clear delineation of occupied habitat for either elk or mule deer.” It is basic: when managing wildlife on public lands, you will never have all the data desired to make perfect decisions. You clearly know enough about elk ranges to do road density analysis which would show the wisdom of designating more or fewer roads open to use. For instance: The Bruno and Elk Mountain areas support significant elk herds and are certainly geographically well enough defined for helpful, herd area specific, road density analysis. NDOW informs us that current hunter motor use in the Bruno area quickly drives elk into hard to approach areas of heavy cover, thus frustrating harvest.

The Wildlife section states that elk herds are thriving, thus there is no need to worry. This is true as far as it goes. However, it denies your responsibility to do what can be done through this plan to assure that suitable elk habitat will be available in the near future for growing populations. Another way to put this is that adding unauthorized routes to the FTS will predictably inhibit big game use of some habitats. It will also damage future quality hunting opportunity. You are required to manage for predictable future impacts.

Elk are a very valuable resource and the demands in Nevada for elk hunting opportunity far exceeds supply. The Forest Service has responsibility and authority over most activities that can enhance or inhibit big game populations appropriate to land capacities.

EO 13433 “Directs agencies to facilitate expansion and enhancement of hunting opportunities and the management of game species and their habitats.” Decisions which just preserve the status quo do not meet this directive. You have great opportunity and strong direction to facilitate expansion and enhance big game habitat through this plan. In addition to limiting availability of future game habitat your proposed alternative will reduce SPNM to nil.

Transportation management is probably one of the most important management activities that can enhance both population levels and quality of the hunting or non-consumptive use of these resources.
The response to our DEIS comments denies both the responsibility and opportunity to factor herd management needs into the decision process.

Monitoring

We are concerned that there is no plan to monitor wildlife. Wildlife is arguably the most valuable resource you manage, save for minerals. Transportation systems can and do have profound effects on wildlife. Most all are negative. You do have opportunity in the future to drop routes which are producing unacceptable effects to wildlife. Yet there is no monitoring planned to determine the effects of this system on wildlife.

Recreation is also a very important resource. Yet the plan says monitoring is optional and the proposed monitoring will not produce data necessary for site-specific transportation management. Our understanding is that the National Visitor Use Survey is not site-specific, so this survey will not give you information as to whether specific portions of the transportation plan are creating unacceptable conflicts.

Nevada Back Country Hunters and Anglers supports the Visitor Map Alternative without MBGR. It provides reasonable access. We see no need for more motorized access than a system which provides motorized access to wihin one mile of 90% of all lands covered by this plan. – (p. v) The FEIS explains the need for transportation planning and stopping the proliferation of unauthorized routes. We do not see any attempt in the FEIS to justify an increase in the FTS.

We do understand the exceptional pressures you are under in Elko County. However we urge you to remember that your obligations to effect good land stewrdship rest with the whole of America. Federal lands remain federal lands largely because of repeated demonstration that local mind sets rerely reflect anything producing the “maximum long term net public benefit “ mandated in NFMA. Hang tough and let us know if there is any way we can help.

Randy McNatt

Chairman NV BHA