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Arizona Elk Society letter to Coconino National Forest appealing the Travel Management Plan

Appeal Deciding Officer

Southwestern Region
USDA Forest Service
333 Broadway Blvd. SE
Albuquerque, NM 87102

Dear Appeal Deciding Officer:

The Arizona Elk Society, P. O. Box 190, Peoria, Arizona 85380, is filing for an administrative review/appeal pursuant to 36 CFR 215 of the September 28, 2011 decision by Ms. Kristin Bail, Acting Coconino National Forest Supervisor, approving the Travel Management Project for the Coconino National Forest. The publication date of this decision was November 3, 2011. This appeal was approved by a unanimous vote of the Arizona Elk Society’s Executive Board at its regularly scheduled Board meeting on December 12, 2012.

We are asking for a review/appeal on four issues related to the Final Environmental Impact Statement (FEIS) and the related Record of Decision (ROD). Specifically, our concerns rest in the following four issues:

  1. Reasonableness of Motorized Big Game Retrieval (MBGR) restrictions.
  2. Reasonableness of extreme restrictions on areas where OHVs/UTVs have access to forest trails.
  3. Reasonableness of excessive closure of roadways.
  4. Unnecessary restriction on dispersed camping.

We will provide specific information on each of these issues, but first want to provide an overall context for our appeal on these issues. We believe that National Forest system was created for the use and enjoyment of these lands for past, current, and future generations so long as excessive resource damage in not incurred. Further, restriction to allowable uses of these lands should embrace a wide array of users and not discriminate (fair treatment) against any segment of our Society as directed in Executive Order 12898. As stated in the FEIS (Page 260) fair treatment means that no group of people, including racial, ethnic, or socioeconomic groups, should bear a disproportionate share of the negative environmental consequences resulting from industrial, municipal, and commercial operations or the execution of federal, state, local, or tribal programs and policies. We believe that hunters comprise a group of people as prescribed in this Executive Order.

Further, as stated in several places in the FEIS, areas where the American public can recreate is contrasting for several reasons. Stand converting fires such as the Wallow and Schultz fires have resulted in less area for the public to use and enjoy our national forests. Restrictions on private lands also have resulted in reduced outdoor areas for legal and lawful public recreation. Simply, as the FEIS points out, for many reasons, places where legitimate use of publicly held lands can occur are being reduced. Therefore, it is the position of the Arizona Elk Society’s Executive Board, that restrictions in lawful use of National Forest lands should be the result of clear and present resource impacts or to abate user conflicts and not solely for administrative convenience.

It is also important to note that many of the resource impacts described in the FEIS and the ROD constitute actions that are already illegal under existing rule or law and that adding another layer of regulation will simply not solve the problem.