In the southeast corner of Washington and extending into the northeast corner of Oregon is a national forest that has been off the radar for oversight of responsible management of ATV/ORV use. This is the Umatilla National Forest (UNF), encompassing important headwaters of the Walla Walla River, long reaches of the Tucannon and Wenaha Rivers, Crooked Creek, Rock Creek and Butte Creek, and the Wenaha-Tucannon and North Fork Umatilla River Wilderness areas. Under the severely compromised application of NEPA to forest projects and practices during the Bush era, and due to the remoteness of this national forest from large, urban areas that tend to have a higher population of environmentally-sensitive recreationists, the ATVs, ORVs, dirt motorcycles, and 4-wheel drive trucks have run rampant with little or no monitoring and enforcement.
Throughout the summer of 2009, I hiked on the forest from trailheads into the Wenaha-Tucannon and North Fork Umatilla River Wilderness areas. I found extensive self-pioneered cross-country trails from ATVs/ORVs, vandalized “closed area” signs, and evidence of motorized incursions into designated Wilderness. I wrote several times identifying these areas and trailheads to the district rangers, the forest supervisor, and the Regional forester. I got no responses from the district rangers and placating answers from the other recipients.
Now the Forest Service is proposing to make a continuous motorized loop trail between the two forks of the Walla Walla River, linking the two trails at Deduct Pond. The Forest Service is categorically excluding the “Deduct Pond Trail Link” project from further NEPA analysis by artificially limiting the scope of the project area to the specific trail link area. Thus the Forest Service has segmented their analysis such that the impacts of the entire motorized loop system that will be newly established by this project can be overlooked. Currently, only motorcycles are permitted on the S. Fork trail, but “quads” or four-wheelers, are used on parts of the N. Fork trail. The current proposal will open up the north and south fork trail system to four-wheelers.
The comments submitted July 23, 2009, by the Hells Canyon Preservation Council accurately summarize the resource concerns. I also submitted comments with 7 pages of pictures showing the erosion and sediment delivery to the S. Fork Walla Walla River from the heavy motorcycle use. The pictures were taken from the popular Harris Park trailhead east of Milton-Freewater through Bureau of Land Management (BLM) lands to the US Forest Service (USFS) boundary. The BLM land is designated an area of critical environmental concern (ACEC). The South and North Forks of the Walla Walla River were proposed Jan. 13, 2010, as Critical Habitat for Bull Trout by the US Fish and Wildlife Service (USFWS) in a revision of the 2005 designation. The Walla Walla River (Hydrologic Unit No. 17070102) and adjacent riparian areas (see 50 CFR 424.12(b)) have been designated as Critical Habitat by the National Marine Fisheries Service (NMFS) for mid-Columbia River steelhead (Federal Register / Vol. 65, No. 32 / Wednesday, February 16, 2000 / Rules and Regulations).
My concerns are:
1) The S. Fork trail is immediately adjacent to the river and in many places there is no riparian vegetation. The soil is eroding due to motorized vehicles resulting in numerous areas where sediment laden water collects and drains directly into the river.
2) The North and South Fork Walla Walla River trails are open to hiking, horseback riding, mountain biking, backpacking, and are used to access hunting, fishing, camping areas, and designated old-growth timber areas and receive heavy horse traffic during hunting season. Connecting the trails to from a giant loop is very likely to encourage “races” and “time events” as on a BMX loop track. Faster speeds and heavier traffic will result in more trail damage and sediment delivery to the river, more damage to the riparian zone, and decreased public safety.
3) Monitoring and enforcement of off-road vehicles are inadequate to prevent and stop abuse that is occurring adjacent to even well-traveled forest service roads. So what can be expected from this new loop project that is more remote and therefore less likely to be monitored?
I am left wondering how federal agencies tasked with managing public resources responsibly and protecting endangered species can allow heavy motorized use in riparian areas and in a way that ensures erosion and delivery of sediments to waters identified as critical habitat for listed fish species. How is it that federal lands which are supposed to bear the burden of recovery efforts for listed species are treated in such a cavalier manner while commercial timber lands and farmers have been required to observe riparian protections, set-backs and specific placement, design and maintenance of roads, and numerous water quality protection measures? What is it about ORVs/ATVs/OHVs/motorcycles and their use as “recreation” that legitimizes their abuse of riparian zones and degradation of public lands and waters?
I also wonder why taxpayers would want to continue to support fish habitat recovery efforts and projects that have cost thousands if not tens of thousands of dollars in the Walla Walla River watershed to date only to have those efforts and dollars spent negated by ATVs/OHVs/ motorcycles driving along waterways and off-road on our public lands?
The cost of the required permit for driving ATVs/OHVs on the National Forest’s are trivial compared to the true costs of monitoring and enforcement and resource restoration that their abusive use necessitates. It costs $10 and is good for 2 years. This is not a fee collected by the federal agencies that goes towards the necessary costs of monitoring and enforcement. How much, if any, of the Oregon permit fees go to federal monitoring and enforcement efforts on national forest lands?
In summary, I contend that the designation of the proposed link between the S. Fork and N. Fork Walla Walla River trails as “Categorical Exclusion” is extremely inappropriate. I contend that there are definitely cumulative, and interrelated and interdependent effects and potential negative future impacts that must be evaluated by all the agencies responsible. I contend that continuing to piece-meal projects in isolation, such as this trail link, as separate and unrelated to the larger use and effects of this trail system is also extremely inappropriate. It is myopic to consider projects and their impacts only within the boundaries of one agency’s authority.