Time to Take Action on
Proposed Snowmobiling Ban
Draft SEIS in the Huron-Manistee National Forests Proposes to Ban Snowmobiling
The Huron-Manistee National Forests has released a Draft Supplemental Environmental Impact Statement (SEIS) for public review and comment. The SEIS proposes to ban snowmobiling and gun hunting within 13 Semi-Primitive Non-Motorized Areas (SPNM) on these forests as the result of a legal decision by the U.S. Court of Appeals. Your participation in this process is critical!
Now that the SEIS has been released, we need you to send letters to the Forest Service in support of Proposed Action Alternative 3 of the SEIS. The areas in question should be defined as Semi-Primitive Motorized areas, and kept open to snowmobiling and firearm hunting.
Tell them that you are opposed to Proposed Action Alternative 2, which would essentially shut off trails both north to south and east to west across the Northern Lower Peninsula.
Snowmobilers in Cadillac would no longer be able to get Traverse City Baldwin or Reed City. Riders would also have trouble getting from Ogemaw Hills to Houghton Lake.
A Little Background
As a result of a U.S. Court of Appeals decision, comments were taken by the Forest Service on two proposed alternatives related to snowmobile-use and firearm use in semi-primitive non-motorized management areas and firearm use in or near primitive areas.
1. No action- This alternative would maintain the direction in the 2006 Forest Plan.
2. Notice of Intent - Amend the Plan to follow the 6th Circuit Court ruling. This alternative would ban gun hunting on all areas and snowmobile use within and adjacent to selected SPNM areas.
The Forest Service received more than 9,000 letters on this issue. We were told that 2,500 were form letters from members of the Fund for Animals. These letters came from all over the world, and were in favor of closing our public lands to snowmobiling and fire arms hunting.
Send Your Own Personal Letter
Your MSA Board knows that this issue and process can be difficult to understand. That is why we are providing the following information for you to include within your own personal letters. Please realize that the Forest Service tends to throw out form letters, so your personal letter will carry the most weight in this process. You need to write to the Forest Service and tell them that you support Proposed Action Alternative 3 of the SEIS. The areas in question should be defined as Semi-Primitive Motorized areas, and thereby keep all existing areas open to snowmobiling and firearm hunting.
Also, tell the Forest Service that you are opposed to Proposed Action Alternative 2. It would be wrong to ban snowmobile use and firearm hunting in existing SPNM areas on these forests.
More Information You Can Include
The Proposed Action ignores the SEIS analysis which shows that less than 27 percent of existing SPNM areas are located beyond a 1/2 mile from open public roads; therefore these areas clearly fail to meet “remoteness” conditions expected to be found in true SPNM areas.
The Forest Service made a serious mistake when it classified the 13 parcels of lands in question as SPNM in 2006 based purely upon ill conceived wishes for unrealistic future “desired conditions.” Proper forest management should, instead, be based upon a realistic interpretation of existing and future conditions, i.e. facts and proper application of agency standards, rather than merely hoping a sow’s ear may eventually become a silk purse for SPNM advocates.
If Alternative 2 is selected, the 2006 SPNM classification error will only be proliferated and likely lead to additional litigation, while choosing Alternative 3 can properly correct this mistake.
All snowmobile trails which would be closed by the Proposed Action are located on open public roads and should therefore remain open for winter snowmobile trail use.
The SEIS improperly minimizes the cumulative effects of Alternative 2. While the Proposed Action will close “only 14.3 miles” of the 525 miles of snowmobile trail in this area, this closure will effectively eliminate important small links within the overall trail network and consequently eliminate connectivity for significantly larger portions of the trail system.
While the Proposed Action would eliminate snowmobile trails across the SPNM areas, it would not close summer ORV trails across the same parcels of land. This defies logic and further demonstrates the flawed reasoning and motivations behind choosing Alternative 2 as the Proposed Action.
The SEIS clearly proves there is no duplication of efforts in providing snowmobiling or firearm hunting opportunities in Michigan; therefore all existing opportunities are important and should be continued.
Michigan has the largest number of registered snowmobiles in the U.S. yet, on a per capita basis, the fewest miles of snowmobile trails. All existing trails on these forests are critical to meeting the high demand for snowmobile trails in Michigan. We need more opportunities, not less.
National Forests are to be enjoyed for multiple recreation uses; be very cautious about excluding public use based upon subjective positions or bias of a few toward other legitimate recreation use.
After the Comment Process
The Draft SEIS will be published in the Federal Register within the next few weeks. Comments will be taken on it through mid-December.
Once the comment process is complete, the Forest Service will take all comments, both in favor of the ban and against the ban, and consider them in their decision. The Forest Service will then come up with their recommendation. They will take that recommendation back before the issuing judge for his approval. We are working hard to make sure that this recommendation keeps these areas open to snowmobiling and firearms hunting. We also realize that once this recommendation is made and the judge makes his decision, lawsuits will more than likely be filed. Remember it was a lawsuit that started this entire process -- Meister v. USDA Forest Service Court Case.
To Find Out More
Visit the MSA Web site at
www.msasnow.org to obtain updates, comment information, and links to this process. We will do our best to keep you informed regarding this critical issue. Rest assured those who want us out of our National Forests are doing everything they can to take away our right to recreate on our public lands.
You need to comment on this issue to help fight the proposed closures to snowmobiling and hunting with guns on the Huron-Manistee National Forests!
You Can Provide Comments By:
Mail: Huron-Manistee National Forest, Attn: Ken Arbogast, 1755 S. Mitchell St., Cadillac, MI 49601
Fax: (231) 775-5551
E-mail:
comments-eastern-huron-manistee@fs.fed.usThis e-mail address is being protected from spambots. You need JavaScript enabled to view it ; the subject line should state: Forest Plan SEIS
March 2011
Many of you are wondering where we are at on the Huron-Manistee National Forest Plan and the Supplemental Environmental Impact Statement (SEIS) that is currently underway at the National Forest Service level. MSA officers have also had several questions in regards to permanent trails, and the use of the Permanent Snowmobile Trails Easement subaccount setup when snowmobile registrations were increased.
Supplemental Environmental Impact Statement
On Sept. 29, 2010, the U.S Court of Appeals for the Sixth Circuit in the case of Meister vs. U.S. Department of Agriculture, ruled that there were deficiencies in the original Environmental Impact Statement (EIS) prepared for the Huron-Manistee Land and Resource Management Plan Revision of 2006. At issue was snowmobiling and hunting “in or near” semi primitive forest areas.
In response to this court decision, on Dec. 28, 2010, the Huron-Manistee National Forests published a Notice of Intent (NOI) to prepare a SEIS. This SEIS is to assess the environmental impacts of a Land and Resource Management Plan (Plan) alternative that would ban firearm hunting and snowmobile use on National Forest lands within and near semi primitive, non motorized management areas.
The Forest Service sought comments on two alternatives – no action or close these areas to hunting and snowmobiling. We have asked you to send your comments, and many of you did. Those out there wishing to keep us out of our National Forests have also sent many comments.
We need to be patient. This is going to be a long process. Comments on the two alternatives were closed on Feb. 11, 2011.
MSA’s complete response can be found on a Web site,
www.masnow.org. We will try to keep you informed, but remember we are looking at a 15-month process.
Even the Department of Natural Resources agrees with MSA that “no action” should be taken in regards to hunting and snowmobiling in the Huron-Manistee National Forest. In a letter to the Forest Service, Rodney A. Stokes, DNR Director-designate wrote, “In terms of the two alternatives the Service listed in the SEIS Notice of Intent, the No Action Alternative maintains the integrity of the approved forest plan which we supported relative to Mr. Meister’s appeal in 2006, and we continue to support today.”
The Forest Service will now take all of your comments and come up with action alternatives that will require more comments before any decisions are made. Comments will be sought on those new alternatives sometime in June 2012. I fully expect to be giving another update on this issue in the March 2012 Michigan Snowmobile News. The process takes time, but we have to stay on top of it.