ORV BMPs cause quite a stir
Created by Bethanie Walder on March 15, 2012
Late last week we found out that the Forest Service document entitled: “A Comprehensive Framework for Off-Highway Vehicle Trail Management” had been pulled from the agency website. It’s not 100% clear, but it appears to have been pulled in response to concerns raised by off-road vehicle organizations regarding the language and information within the document.
The Comprehensive Framework was jointly produced by the Forest Service, National Park Service and the Federal Highway Administration, and was finalized in July, 2011. Within the past few weeks, however, off-road vehicle organizations have objected to the report based on claims that it uses “derogatory and inflammatory” language about off-road vehicle users and because it contains Best Management Practices adapted from Wildlands CPR and Wild Utah Project’s 2008 “Best Management Practices for Off-Road Vehicle Use on Forestlands.”
We haven’t reviewed the entire Comprehensive Framework and we were not involved in its development. From our review of the document, it’s basically a “sustainable trails” guide that mostly addresses trail design and construction, including recommendations and citations to guides and reports published by off-road vehicle organizations. The Forest Service asked for our permission to reprint portions of our BMPs, and we said yes. Our scientifically-based BMPs, included as Appendix D, address where to locate off-road vehicle trails to reduce ecological impacts and to be in compliance with the off-road vehicle regulatory framework. BMPs provide an important complement to a document that focuses on how to design trails and what types of features to include from a recreation perspective, but that does not address the foundational ecological impacts of where those trails are sited.
Nonetheless, seven organizations sent a letter to Secretary of Agriculture Tom Vilsack opposing the Comprehensive Framework. The letter was also copied to the Chief of the Forest Service, the Director of the National Park Service and the Administrator of the Federal Highway Administration. A portion of the letter focuses on their concerns about Wildlands CPR, arguing that it was wrong for the Forest Service to use our information in the Comprehensive Framework. They seem to have a double-standard where including information from some stakeholders is appropriate but including information from other stakeholders is not.
While we don’t find it necessary to reprint or refute the misinformation in their letter, we did find it necessary to send our own letter to the people outlined above clarifying that our BMPs are science-based and appropriate for inclusion in the Comprehensive Framework. The full ORV BMPs report we published was fully cited based on the best available science. It also includes a brief reference to the legal framework guiding off-road vehicle management. The BMPs, therefore, are drawn frmo both the regulatory framework and the best science. Their letter includes the following comments: "Will our areas of concern be addressed or will there be a disclaimer? Our groups believe a disclaimer is insufficient because the material sourced from Wildlands CPR is not supported with scientifically based data and should not be included in the Report." This claim is patently false, as explained above. In addition, a shortened and updated version of our BMPs was just published in the peer-reviewed Journal of Conservation Planning. Unfortunately, as of early March, it appears that the three agencies involved have removed the Comprehensive Framework from their websites. (Click here for a copy of our letter to Secretary Vilsack, which includes a more detailed explanation of our concerns.)
But the opposition letter was only one part of their attack. They also went to their Congressional supporters, as evidenced by last week’s Senate Energy and Natural Resources Committee oversight hearing on the Forest Service budget. At the hearing, Senator Barasso (R-WY) questioned Forest Service Chief Tom Tidwell regarding the inclusion of our BMPs in the Comprehensive Framework:
"But who wrote this 'Best Management Practices?' Well you actually published them in the appendix and it's the Wildlands CPR. To have something written by this organization with their background and their goals, to me, it really undermines the credibility of the Forest Service. I want to know when the Forest Service first adopted and published Best Management Practices supported by the groups who oppose motorized access." (This quote was transcribed by listening to the hearing webcast, apologies for any immaterial errors that may have occurred.)
Chief Tidwell didn’t directly respond to the Wildlands CPR part of the question, but did point out how important BMPs are for management. Here’s part of his answer:
"Well our Best Management Practices are what we have found to be the right things to be able to address the issues especially like with erosion and runoff, drainage on trails. So those are our Best Management Practices. We would of course expect everyone to be supportive of those because they’ve proven to be very effective to address the issues." (Again, transcribed from the webcase, apologies for any immaterial errors.)
We sincerely hope Chief Tidwell stands by that sentiment, and that we see the Comprehensive Framework, including the appendix with our BMPs, back online very, very soon. We’ll keep you posted as we learn more.
P. S. We have received several comments related to this on different pages of our website. We are not going to post any additional comments at this point, as this blog post and the letter to Secretary Vilsack outline our position on this issue.
Tri Cities Peak Putters
Land Use Coordinator
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