Jim Sanders,
Forest Supervisor
Norm Wagoner,
Forest Supervisor Forest Plan Revision
Chippewa National Forest
200 Ash Avenue NW
Cass Lake, MN 56633-8929

August 7, 2003

Dear Mr. Sanders and Mr. Wagoner:

Minnesotans for Responsible Recreation (MRR) are writing to you in reference to your current Forest Plan Revision process, and would like to commend you on taking some steps to control recreational motor vehicles (RMVs) on the Superior and Chippewa National Forests. MRR, however, believes that you are not going nearly far enough to control this present and growing threat of recreational motor vehicle use on our national forests. MRR would recommend that you adopt Alternative D which emphasizes more semi-primitive non-motorized forms of recreation. Since a vast majority of Minnesotans and Americans in general participate in non-motorized forms of recreation, this makes the most sense (see published Recreation Use in Minnesota study, and 2001 Outdoor Recreation in America study, American Recreation Coalition, 2001, http://www.funoutdoors.com/research.html). While MRR sincerely appreciates the fact that in all alternatives except Alternative A, year-round RMV and all-terrain vehicle (ATV) cross-country travel would be eliminated on the Superior and Chippewa National Forests, we are disturbed by the fact that the preferred alternative, Alternative E, allows ATV cross-country travel for big game retrieval and furbearer trapping access. Alternative E essentially allows year round cross-country travel for ATVs since anyone could argue they are traveling cross-country on their ATV for the purpose of trapping access any time of the year. This is simply unacceptable and a way to appear that a big step is being taken (eliminating RMV and ATV cross-country travel) while permitting a gaping loophole which will allow motorized cross-country travel to continue on the forest. Allowing ATV cross-country travel to continue for trapping and big game retrieval will also make your job as managers much more difficult. Law enforcement officers will have a difficult time monitoring illegal cross-country travel and enforcing the new forest guidelines. Motorized users will argue they are checking their traps or scouting for trapping locations, and law enforcement officers will find it nearly impossible to legally argue their case against these users. New cross-country trails that are developed will not be able to be closed or monitored for illegal use since they may have been developed by motorized users during the big game retrieval process or during trapping activities. You must disallow cross-country travel at all times in all places on the Superior and Chippewa National Forest. The preferred alternative (E) must be amended to disallow cross-country ATV travel or a new alternative must be chosen. This is one area where you cannot go half-way in your meaning or enforcement of motorized cross-country travel. To do anything less than a forestwide closure of ATV cross-country travel year-round would be a nightmare for forest management. In addition, the State of Minnesota will soon be phasing out cross-country travel and instituting a designated trails only policy for RMVs on all State managed lands. As a matter of consistency, the Superior and Chippewa National Forests should also have a policy which forbids motorized cross-country travel year-round and in all areas and requires that all RMVs and ATVs travel only on trails designated for motorized use. All other trails not clearly marked and signed for RMV or ATV travel should be off-limits to motorized travel. MRR would also like to address several items in the forest plan that do not adequately consider the negative impacts of RMV and ATV use on the forest in general:

*The preferred alternative provides the largest number of miles of new designated RMV trails. MRR believes that no new trail miles be targeted until each individual project is addressed and the environmental impacts of that project are carefully considered. Setting a target implies that it must be met, and it is possible that thorough environmental review of these trails may not make meeting such a target likely.

*Designating a maximum of 100 miles of new snowmobile trails in the preferred alternative when the negative impact of these trails on threatened species like the Lynx may be significant is a mistake. This provision should be taken out of the preferred alternative. MRR believes that the over 18,000 miles of snowmobile trails already present in the State should be more than enough to provide access to nearly every nook and cranny of the State for snowmobile use.

*The Forest Service must recognize and address the effect of RMV use on wildlife habitat, particularly the impacts from RMV and ATV routes making safe and secure areas for species much smaller, increasing the ease for poachers to access game species, and the fragmentation of habitats from RMV and ATV designated and user created informal routes. Nowhere in the forest plan is the significant negative impact of RMV use on wildlife addressed.

When addressing Scenic Quality in the plan, the Forest Service does not address the very dramatic and significant negative effects of RMVs and ATVs on the forests’ scenic qualities. Eroded hillsides, torn up wetlands, mudholes and braided and rutted trails are all significant detractors to scenic quality on the forests.

When addressing the regions social and economic impacts, the Forest Service fails to look at the potential negative impact of RMV and ATV use on the regions social and economic sustainability in the spring, summer and fall seasons, particularly along Minnesota North Shore. The increase in noise and pollution from these machines may likely drive away traditional visitors to this region who seek quiet places to picnic, fish and hike free from the noise and fumes of these machines. People traditionally come to here in the spring, summer and fall to smell the fresh pine needles and hear the call of the Loon across a lake, not smell exhaust fumes and hear the noise of a revving engine. For many, the traditional reason for getting away from the city to the Northwoods will be lost in the cacophony of engines and exhaust, hurting local economies that relied on the fisherman, hiker and sightseer. While MRR is encouraged by the strides in the right direction the Forest Service is making by restricting motorized recreation use to trails that are signed and open for a specific motorized use only, we are concerned that a large loophole (allowing cross-country use during big game retrieval and trapping) may scuttle the good intentions and make management of motorized recreation use much more difficult. We look forward to hearing back from you regarding your forest plan and sincerely hope you consider these recommendations when making a final decision on which alternative forest plan you choose.

Sincerely,

Jeff Brown,
Executive Director
Minnesotans for Responsible Recreation