[Awclist] Fwd: RRFW Posts Easy Comment Form for Proposed USFS Rules

[Thomas Robey]

Begin forwarded message:

> From: RRFW Riverwire <riverwire at rrfw.org>
> Date: January 19, 2008 10:55:13 PM MST
> To: trobey at cybermesa.com
> Subject: RRFW Posts Easy Comment Form for Proposed USFS Rules
> Reply-To: riverwire at rrfw.org
>
> RRFW Riverwire
>
> RRFW Posts Easy Comment Form for Proposed USFS Rules
>
> January 19, 2008
>
> The United States Forest Service (USFS) is taking public comment on  
> proposed new rule changes which heavily favor outfitter/guided  
> access to public lands. The comment deadline is February 19, 2008.
>
> The massive countrywide rulemaking changes will jeopardize do-it- 
> yourself access to all types of recreation on Forest Service lands.  
> This includes do-it-yourself (guide-free) hunters, fishermen, off- 
> road enthusiasts, hikers, backpackers, canoeists, jet-boaters,  
> paddlers, mountain-bikers, photographers, and river runners.
>
> Your comments are needed to protest the proposed changes. Now is the  
> time to stand up and protect your right to use these lands equally  
> with outfitters and their clients.
>
> RRFW has made it easy for you to weigh in with your comments. Please  
> visit our website at http://www.rrfw.org/ForestRec.php, copy and  
> paste bullet points into the left side from the suggestions on the  
> right, editing the content to personalize your views on the proposed  
> changes. We will submit your comments to the agency for you.
>
> The proposed changes and points you may wish to make are described  
> below as well as on our website at: http://www.rrfw.org/ 
> ForestRec.php, but please be sure to personalize your comments, as  
> public lands agencies tend to discount obvious form letters.
>
> Background:
>
> While defining the total limit on recreational use is necessary in  
> heavy-demand areas to protect the resource from too much visitation.  
> Land managers limit access to all recreational users through set- 
> aside blocks of "allocations" which often over-allocate access for  
> outfitter's clients. The proposal allows new commercial services to  
> decide the allocation they need. Over-allocating access to  
> outfitters and guides bars use to the do-it-yourself public. River  
> runners are all-too-familiar with the problems of being locked out  
> of areas for lack of available permits when trips are open to  
> customers of outfitters and guides.
>
> Only in a very few locations, after a huge effort on the part of do- 
> it-yourself recreationists' against the resistance of outfitter and  
> guide groups, have allocation-free permit systems been implemented.  
> These permit systems, called Common Pool or Freedom of Choice permit  
> systems, do not set aside any access allocations. Outfitters/guide  
> clients and the do-it-yourself public compete equally for permits.
>
> What's Proposed by the USFS:
>
> * Outfitters, guides and non-profit groups would be awarded an  
> allocation of public use for up to ten-year periods.
>
> * Outfitters and guides would be able to pay a small fee for sole  
> and exclusive access to prime camping, hunting, fishing and picnic  
> areas, including boat launch ramps.
>
> *The rule change would give preferred access to the outfitters at  
> the expense of the do-it-yourself public on all Forest Service- 
> managed lands.
>
> * This rulemaking would force allocating access in management areas  
> where access is presently allocation-free.
>
> * The new proposed rules do not protect wilderness areas from  
> commercialization.
>
> What You Can DO:
>
> The US Forest Service has established procedures to be used for  
> citizen comments. Be sure to cite the appropriate section listed,  
> and feel free to relate any anecdotal story from a National Forest  
> near you to illustrate the issue.
>
> Besides commenting to the USFS, tell your outdoor recreation friends  
> they need to comment too!
>
> Here's what you might want to say to the Forest Service in your own  
> words (with appropriate cites):
>
> In Cite 41.53d - Definitions: Allocation of Use:
>
> * Add a definition for Common Pool, since a new definition for  
> Allocation of Use is proposed. This definition should include  
> language allowing commercial use permits to be awarded without a  
> guaranteed amount of use, service days or quota, where all  
> outfitters, guides and non-profit organizations using public lands  
> should compete on an equal footing with the public for permits in a  
> common pool type of permit system.
>
> In Cite 41.53d - Definitions: Assigned Site:
>
> * Do away with the Assigned Site definition: there should be no  
> Assigned Sites specifically set aside for outfitter, guide or non- 
> profit use including campsites, launch ramps, trails, and prime  
> hunting and fishing locations. Assigned Sites diminish the  
> recreational value for the do-it-yourself recreational public with  
> the establishment of locations the do-it-yourself public may not use.
>
> In Cite 41.53d - Definitions: Needs Assessments:
>
> * The definition of Needs Assessment must include assessing the need  
> for commercial services in relation to existing public demand for do- 
> it-yourself recreational access. In areas where there is presently a  
> backlog, waiting list or overcapacity of demand for do-it-yourself  
> public recreation, no new outfitter or guide services should be  
> considered outside of a Common Pool in applicable land management  
> plan Needs Assessments.
>
> In Cite 41.53d - Definitions: Priority Use:
>
> * Calling outfitters and guides Priority Users is insulting to the  
> do-it-yourself recreational public, and commercial services should  
> be called just what they are: Commercial Use. Commercial Users  
> should not be awarded 10 year permits, 5 years is long enough, and  
> permits should not rollover after expiration.
>
> In Cite 41.53d - Definitions: Quotas:
>
> * Ask that the USFS require all quotas for Priority Users or  
> Temporary Users such as group size and pack-stock numbers be the  
> same for quotas applied to the do-it-yourself recreational user. As  
> an example, a Priority User should not be awarded a maximum group  
> size of 32 while the do-it-yourself group size maximum is 16.
>
> In Cite 41.53e - Needs Assessment, Resource Capacity Analysis, and  
> Allocation of Use:
>
> * Identifying how many people in a resource area is too many needs  
> to be established BEFORE "reliable information suggests that  
> resource capacity has been reached." Resource Capacity Analysis must  
> also inventory the type of permit system presently in place if one  
> exists.
>
> Cite 41.53g (3)a - Issuance of New Outfitting and Guiding Permits:
>
> * Before evaluating any need for new or increased commercial  
> services, the agency must consider present do-it-yourself  
> recreational demand. If there is greater demand for do-it-yourself  
> recreational permits then available supply, consideration must be  
> given to increasing the do-it-yourself public sector's allocation  
> before awarding new commercial service allocations. In areas where  
> no competitive interest exists, a commercial permit may be awarded,  
> but no allocation of any type should be included with that permit,  
> and a Common Pool management plan should be instituted for the  
> distribution of permits.
>
> Cite 41.53h (1) - Applications for Outfitting and Guiding Permits:
>
> * While it is appropriate for the agency to request identification  
> of the commercial services to be performed, requesting a commercial  
> enterprise to define the service days or quotas they require,  
> without considering the do-it-yourself recreational public's needs,  
> is unacceptable.
>
> Cite 41.53j (7) - Issuance of Temporary Use Permits:
>
> * If the USFS decides to have a unilateral Temporary Use Common  
> Pool, the allocation available for distribution in the Temporary Use  
> Common Pool must come from the present outfitter and guide Priority  
> Use permit allocations, not the do-it-yourself allocation.
>
> Cite 41.53l (2) a -Allocation of Use for a Priority Use Permit:
>
> * Adjust commercial allocations yearly instead of once every 5  
> years. A Priority (commercial) User with unused service days or  
> quotas during the recreational season adversely impacts do-it- 
> yourself access and regional small livery and recreational supply  
> businesses that cater to and survive on the local spending of the do- 
> it-yourself public.
>
> General comments:
>
> * Tell the USFS to consider whether authorizing Priority Use would  
> impede the Forest Service's ability to meet the recreational and  
> other goals of the Wilderness Act.
>
> * Recognize in this proposed rulemaking that Allocation-free Common  
> Pool areas like the Boundary Waters Canoe Area not only presently  
> exist, but they must be preserved allocation free.
>
> How To Comment:
>
> Go to the RRFW webpage for comment submission at:
> http://www.rrfw.org/ForestRec.php,
>
> Or, comments may be submitted by mail to:
>
> U.S. Forest Service, Attn:
> Carolyn Holbrook, Recreation and Heritage Resources Staff (2720)
> 1400 Independence Avenue, SW., MailStop 1125,
> Washington, DC 20250-1125.
>
> Or, you can submit electronic comments, start by clicking here:
>
> Proposed Directives for Forest Service Outfitting and Guiding  
> Special Use Permits and Insurance Requirements for Forest Service  
> Special Use Permits
>
> Click on the "Add a comment" yellow balloon to open a "Submitter  
> Information Form." Note that it will be easier if you have already  
> typed your comments in a separate document. You may then either copy  
> and paste it into the form or attach your document through the  
> "Browse" feature.
>
> If the link above is broken, use these instructions:
>
> Start by clicking here: http://www.regulations.gov
>
> Under "Search", type in the document ID which is FS-2007-0008-0001  
> and hit go.
>
> You should see a page with "Proposed Directives for Forest Service  
> Outfitting and Guiding Special Use Permits and Insurance  
> Requirements for Forest Service Special Use Permits", then click the  
> hotlink called, "Send a comment or Submission"to get to the  
> "Submitter Information Form." You may type your comments or attach  
> them via a separate document.
>
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