**Statement of Nada Culver**

**Senior Counsel, The Wilderness Society**

**Senate Energy and Natural Resources Committee Hearing Regarding
Off-road Vehicle Management on Public Lands**

**June 5, 2008**

Chairman Bingaman, members of the Committee and members of the Senate,
my name is Nada Culver. I am Senior Counsel in the Public Lands Campaign
of The Wilderness Society. The Wilderness Society's mission is
to protect wilderness and inspire Americans to care for our wild places.
I work in the BLM Action Center, which tracks land use planning around
the West and is dedicated to helping the public effectively engage and
participate in the processes that determine how our public lands are
managed. I appreciate the opportunity to speak with you today about the
management of off-road vehicles on the public lands. This written
statement is submitted on behalf of The Wilderness Society and our
partners, who care deeply about the natural wonders and recreation
opportunities on our public lands.

Travel planning is the cornerstone for achieving workable management of
dirt bike, all-terrain vehicles and other off-road vehicles (ORVs) on
our public lands. Planning provides a framework for agencies like the
Bureau of Land Management and Forest Service to take a hard look at the
lands they manage, plan to manage uses of those lands, including by
ORVs, enforce uses based on plan, and then monitor the effects of plans
to determine if changes are needed to protect the resources, uses and
values of these lands.­

Recognizing the damage that ORVs can inflict on both natural resources,
such as water, wildlife and wilderness, and other users of the public
land, Presidents Nixon and Carter issued Executive Orders to guide their
management by federal agencies, including the Bureau of Land Management
(BLM) and Forest Service (FS). These Executive Orders (EO No. 11644
(1972)) as amended by Executive Order No. 11989 (1977)), which are also
incorporated into the BLM's regulations (43 C.F.R. § 8342.1), require
the agencies to ensure that areas and trails for off-road vehicle use
are located:

-   to minimize damage to soil, watershed, vegetation, air, or other
    resources of the public lands, and to prevent impairment of
    wilderness suitability;

-   to minimize harassment of wildlife or significant disruption of
    wildlife habitats, and especially for protection of endangered or
    threatened species and their habitats;

-   to minimize conflicts between off-road vehicle use and other
    existing or proposed recreational uses of the same or neighboring
    public lands; and

-   outside officially designated wilderness areas or primitive areas
    and in natural areas only if the agency determines that off-road
    vehicle use will not adversely affect their natural, aesthetic,
    scenic, or other values for which such areas are established.

These Executive Orders essentially put the burden of proof on the
agencies to make sure that natural resources, including sensitive and
lands specifically identified for their conservation values are not
harmed by ORV use, while other users can enjoy the scenery and
non-motorized recreation opportunities on public lands, and ORV use is
only permitted in areas or on routes where these criteria are met.

Although there are some BLM or FS planning efforts that are based on
these fundamental principles, the majority are not. My testimony today
will address our grave concerns with the ongoing damage to the public
lands and the need for action to correct these trends while there is
still time.

The key elements of sustainable plans to manage ORVs, as well as the key
failures in the travel planning that the BLM and FS are conducting (or
not conducting), can be described in three categories:

1.  Ecological -- The Executive Orders, as well as established
    management priorities for specific conservation areas or resources,
    such as wilderness study areas or wildlife habitat, dictate
    protection from ORVs.

2.  Fiscal -- The agencies must have sufficient resources to inventory
    resources and conditions on the public lands, create management
    plans, enforce decisions, and monitor plans to ensure they are
    adequately protecting other resources and users.

3.  Recreational-- Motorized vehicles prevent other users from
    experiencing the naturalness, solitude and scenery of the public
    lands. Sustainable plans provide for a variety of users to fully
    enjoy recreational opportunities on the public lands.

A review of the ways in which the current travel planning initiatives do
not address these important considerations highlights the actions needed
to fix them.

1.  [Ecological Sustainability:]{.underline}

As set out above, the Executive Orders direct the BLM and FS to manage
ORV use by prioritizing protection of natural resources, such as
wilderness suitability, soil, water, and wildlife habitat, as well as
avoiding conflicts with other recreationists. These priorities are also
consistent with the statutes governing the agencies. The Federal Land
Policy and Management Act (FLPMA) directs the BLM to manage the public
lands "in a manner that will protect the quality of scientific, scenic,
historical, ecological, environmental, air and atmospheric, water
resource, and archeological values." 43 U.S.C. § 1701(a)(8). FLPMA
requires the BLM to accomplish this through management plans, which are
based on an inventory of the public lands and their resource and values,
\"including outdoor recreation and scenic values.\"  43 U.S.C. §
1711(a).  Similarly, the National Forest Management Act (NFMA) requires
that the Forest Service manage the Forests in an ecologically
sustainable manner that "protects soil and water resources, streams,
streambanks, shorelines, wetlands, fish, wildlife, and the diversity of
plant and animal communities." 36 CFR 219.27(a)(4) (implementing 16
U.S.C. § 1604).

Travel planning is an important aspect of achieving these management
goals. The regulations of both the BLM and FS that address management of
ORVs also incorporate the priorities established by the Executive
Orders. *See,* 43 C.F.R. § 8342.1; 36 C.F.R.§ 212.55(a). Unfortunately,
the agencies are proceeding with travel planning in a manner that will
not fulfill these mandates.

\(a\) *Maintaining oversized road and motorized trail systems* -- Both
agencies have stated their intent to move away from permitting unmanaged
cross-country use. However, the networks that they are designating or
simply leaving in place indefinitely are too large and, as a result,
will continue to damage natural resources.

BLM's *Land Use Planning Handbook*. H-1601, Appendix C, Section II.D
(Comprehensive Trails and Travel Management) states that the BLM should
"\[c\]omplete a defined travel management network (system of areas,
roads and/or trails) during the development of the land use plan, to the
extent practical." If designation is not possible, then the BLM is to
designate the network within five years. *See*, Instruction Memorandum
(IM) 2004-005. Individual state offices, such as Utah and Colorado, have
issued their own guidance to more strongly require designation of a
travel management network in resource management plans. *See*, IM
CO-2007-020. However, in many plans, the BLM is continuing to delay
designation and, instead, simply labeling multi-million acre planning
areas as "limited to existing" roads and trails. Instead of selecting
routes and avoiding ecological damage, the resulting travel networks do
not actively manage ORVs and do not prevent damage to natural resources
or the recreational experiences of other users of the public lands.

Although the FS is proceeding under a mandate to designate routes, the
process to date has not included consideration of how to minimize
impacts on other natural resources. Instead, the FS has provided
opportunities for interested parties to identify additional motorized
routes to be added to the travel network without similar opportunities
or consideration of the need to protect natural resources.

[BLM Examples:]{.underline}

-   Yuma, Arizona, Proposed Resource Management Plan (RMP): The proposed
    plan limits ORV travel to existing routes in "limited" areas based
    on the existing inventory of routes, deferring designation to a
    later process even though these initial routes have not been
    subjected to analysis of their compliance with applicable legal
    standards. The Proposed RMP also commits to an interim step of
    permitting interested parties to designate additional routes,
    without requiring rigorous assessment and evidence that these routes
    were in existence legally and proof of why they are needed. Proposed
    RMP, p. 2-98. The travel planning process set out in the Proposed
    RMP does not provide for an assessment of whether inventoried
    routes, as well as any additional routes proposed, were created
    legally or for interested parties to recommend routes for closure
    based on a full disclosure of the manner in which these routes
    impact other values in the planning area, which is likely more
    important in light of the substantial mileage and acreage already
    identified for use by ORVs.

-   Tri-County RMP revision and amendment in New Mexico: The process
    began in 2005 to update RMPs that were finalized in 1986 and 1994,
    governing close to 3 million acres of public land in three counties.
    Although the draft plan is still in progress, the BLM has confirmed
    that it will not be designating route systems for the vast majority
    of the planning area. Similarly, in Colorado, both the Little Snake
    and Uncompahgre RMP revisions currently in preparation have stated
    that designation of a travel network will not be included in either
    of these plans.

-   Moab, Monticello, Kanab, Price, Vernal, and Richfield RMPs: The BLM
    is preparing six plans covering 11 million acres of land including
    areas with wilderness character and potential wild and scenic
    rivers. Rather than protecting wild areas and cultural sites, the
    BLM is proposing to designate more than 15,000 miles of off-road
    vehicle routes -- essentially blanketing southern Utah's canyon
    country with roads and motorized routes, while declining to
    acknowledge the potentially irreparable harm to other resources.

-   California Desert Conservation Area (CDCA), travel plan for the
    Western Mojave (WEMO): This bioregion of the CDCA is the most
    heavily impacted by ORV use. The WEMO includes 4 units of designated
    critical habitat---Superior-Cronese (766,900 acres), Ord-Rodman
    (253,200 acres), Fremont-Kramer (518,000 acres), and Pinto Mountains
    (171,700 acres). WBO AR 14834. Although the WEMO plan also included
    designation of Desert Wildlife Management Areas ("DWMAs") to manage
    critical habitat, the DWMAs excluded thousands of acres of
    designated critical habitat. The BLM's 2003 WEMO Route Designation
    and the 2006 WEMO Plan amendment authorized an ORV route network
    including over 5,444 miles of open routes and over 30 miles of
    "limited" routes within desert tortoise habitat, of these, over
    2,230 miles of routes are in designated critical habitat.

[FS Examples:]{.underline}

-   Plumas National Forest travel plan (California): Currently, the
    agency manages approximately 4,150 miles of roads and 102 miles of
    motorized trails. Its latest proposal adds 375 miles of existing
    unauthorized routes to the current system of motorized trails. 

-   Cassia Division on the Minidoka District of Sawtooth National Forest
    travel plan (Idaho): The district finalized an unmanageable 802-mile
    route system where the large amount of short "in and out" routes
    will be impossible to enforce. Additionally, the Idaho Department of
    Fish and Game and Environmental Protection Agency commented to the
    agency regarding potential problems managing wildlife habitat and
    water quality, respectively, with the high density of routes.

\(b\) *Not fulfilling special management requirements* -- There are
certain areas where natural resources and values must be given special
consideration in travel planning, including heightened protection from
the impacts of off-road vehicles. Agencies have a duty to protect
cultural sites, rivers and streams, wildlife migration corridors, and
other sensitive lands and should consider designating these areas for
walking trails and other lower-impact uses only.

Management of wilderness study areas (WSAs), national monuments, wild
and scenic rivers, and cultural resources is governed by specific
priorities to protect their conservation values. *See, e.g.,* Interim
Management Policy (IMP) for Lands Under Wilderness Review (BLM Manual
H-8550-1) (requiring that WSAs are managed to protect their suitability
for wilderness designation); Antiquities Act of 1906, 16 U.S.C. §§ 431
-- 433 (requiring management to protect objects of interest); Wild and
Scenic Rivers Act, 16 U.S.C. § 1271 - 1287 (requiring management to
protect outstanding river values); National Historic Preservation Act,
16 U.S.C. §§ 470f, 470h (requiring federal agencies to consider effects
on historic properties and seek to avoid damage).

Inventoried roadless areas on FS lands are governed by the 2001 Roadless
Rule. The Rule acknowledges defines the characteristics of roadless
areas as:

> \(1\) High quality or undisturbed soil, water, and air;
>
> \(2\) Sources of public drinking water;
>
> \(3\) Diversity of plant and animal communities;
>
> \(4\) Habitat for threatened, endangered, proposed, candidate, and
> sensitive species and for those species dependent on large,
> undisturbed areas of land;
>
> \(5\) Primitive, semi-primitive non-motorized and semi-primitive
> motorized classes of dispersed recreation;
>
> \(6\) Reference landscapes;
>
> \(7\) Natural appearing landscapes with high scenic quality;
>
> \(8\) Traditional cultural properties and sacred sites; and
>
> \(9\) Other locally identified unique characteristics.

36 C.F.R. § 294.11. The recognized ecological values of inventoried
roadless areas are the reason that new road construction and road
re-construction are prohibited by the Roadless Rule. These values also
merit special consideration for protection when planning for management
of ORVs. Instead, Forests in the Southwest are proposing travel
management plans that will actively open and degrade inventoried
roadless areas.

The BLM manages the National Landscape Conservation System (Conservation
System), which is comprised of lands created by both presidential and
congressional directive, is managed based on a mission of stewardship
to: "conserve, protect, and restore these nationally significant
landscapes that have outstanding cultural, ecological, and scientific
values for the benefit of current and future generations." Wilderness,
wilderness study areas, national monuments, national conservation areas,
and wild and scenic rivers are all included in the Conservation System.
Failure to manage ORVs in these areas, where not only the Executive
Orders but also additional authorities direct the BLM and FS to
prioritize conservation and/or highlight their ecological values, is
especially indicative of the problems in the agencies' travel planning
processes.

[Examples:]{.underline}

-   Utah RMPs: These six plans govern more than 5 million acres of
    proposed Wilderness, including 1.8 million acres of WSAs. The plans
    propose to designate motorized vehicle routes throughout the WSAs
    and 92% of lands outside WSAs that the BLM has recognized as having
    wilderness characteristics.

-   Grand Canyon-Parashant National Monument and Vermillion Cliffs
    National Monument RMPs, Arizona: The proposed plan for each of these
    monuments designates two-tracks and barely noticeable routes for
    vehicle use even though the Monument Proclamations prohibit "all
    motorized and mechanized vehicle use off-road." In this case, the
    BLM is expanding the definition of a road to accommodate more
    off-road vehicle use in the monuments rather than protecting the
    natural and cultural resources for which these national monuments
    were created.

-   Steens Mountain Cooperative Management Area Comprehensive Travel
    Plan, Oregon: The BLM's travel plan designates so-called "obscure
    routes" in Wilderness Study Areas as available for motorized
    vehicles, even though nobody, not even the BLM, can find these
    routes on the ground. Off-roaders will be sent out to search for
    them, inevitably damaging wilderness qualities. In addition, the
    Steens Act prohibits use of motorized vehicles "off road," which is
    also bound to occur in light of this designation. The Interior Board
    of Land Appeals has recently stayed the implementation of this plan
    because of the blatant disregard for protection of wilderness
    qualities in sending motorized vehicles out to search for obscure
    routes in areas that the BLM is supposed to be protecting for their
    wilderness suitability.

-   Upper Missouri River Breaks National Monument RMP, Montana: Despite
    a detailed analysis and substantial scientific literature
    documenting the risks to sensitive wildlife highlighted in the
    Monument Proclamation from the high road density in the Monument,
    and numerous recommendations to reduce the road network from
    biologists and the State of Montana, the BLM has chosen to
    *increase* the miles of road for motorized use between the draft and
    proposed plans. The designated road network is likely to damage
    wildlife habitat, as well as the remote character and cultural
    resources that led to the designation of the Monument.

-   Western Oregon RMP Revisions -- This revision addresses more than
    2.5 million acres of public lands in six RMPs for the Eugene,
    Roseburg, Medford, and Coos Bay Districts and the Klamath Falls
    Resource Area of the Lakeview District. In addressing travel
    management for designated conservation areas, including areas of
    critical environmental concern (ACECs), WSAs and wild and scenic
    rivers, the Draft RMPs propose less protection in all management
    alternatives -- reducing or even eliminating closures to ORVs for
    these areas, which include the Elk Creek ACEC in the Salem District,
    the Camas Swale ACEC/Research Natural Area A in the Roseburg
    District, and the Rogue Wild and Scenic River Corridor and the Soda
    Mountain WSA in the Medford District.

-   Apache-Sitgreaves National Forest, Arizona: This Forest is proposing
    to open roads in inventoried roadless areas that are currently
    identified as closed (maintenance level 1) in the transportation
    inventory. Instead of protecting the ecological values of these
    roadless areas, the Forest is actively increasing their use --
    arguably violating the Roadless Rule's prohibition on road
    reconstruction and certainly promoting damage of acknowledged
    natural resources.

2\. [Fiscal Sustainability:]{.underline}

The BLM and Forest Service are designating road and trail systems that
are fiscally unrealistic based on available and projected funding for
construction, maintenance, monitoring, and enforcement. Roads and trails
are expensive to construct and maintain whether they are asphalt,
gravel, or dirt. There are substantial costs to construct and maintain
culverts, bridges and other structures to prevent erosion and ensure
visitor safety. The Taxpayers for Common Sense estimates the Forest
Service, in particular, currently has a \$10 billion road maintenance
backlog (<http://www.taxpayer.net/forest/roadless/index.htm>).

Even where minimal construction or maintenance is required (as is the
case for some routes on BLM lands), more routes require more enforcement
to ensure compliance with travel plans and also require more monitoring
to ensure that they are not causing unacceptable damage to natural
resources.

The FS regulations specifically require that, as part of designating
routes and areas for motor vehicle use, the agency consider "the
availability of resources for that maintenance and administration." 36
C.F.R. § 212.55(a). Unfortunately, the agencies rarely, if ever, include
an assessment of funding and resources required to implement proposed
travel plans. As a result, travel planning decisions are not based on
the practical realities associated with the designations. In many of the
following examples, the agencies acknowledge that a lack of funding is
foreseeable, yet do not adjust their travel plans, effectively
abandoning their obligation to protect the public lands.

[*Examples*:]{.underline}

-   The Cibola National Forest, New Mexico, includes the Sandia
    Mountains, a popular place to visit just east of Albuquerque. The
    travel analysis prepared included the following statement: *"But
    based on road maintenance funding received over the previous five
    years the Cibola N.F. can afford to fully maintain only about 31% of
    the existing system."*

-   The Apache-Sitgreaves National Forest, Arizona reached a similar
    conclusion. Their assessment concluded that the Forest can only
    afford 33% of its road system.

-   The Lincoln National Forest, New Mexico, presented a more
    distressing picture of road maintenance funding, stating that the
    forest receives about \$500,000 for road maintenance and
    construction, but needs about \$5.7 million to maintain its
    2337-mile road system. The Forest reported that, "The Forest budget
    can only support 9% of the road system."

-   The Black Hills National Forest, South Dakota, actually references
    its obligation to designate a minimum road system that is:

> *needed for safe and efficient travel and for administration,
> utilization, and protection of NFS land ... strikes a balance between
> the benefits of public access to NFS lands and the costs of
> road-associated effects on ecosystem values, taking into account
> public safety, affordability, and management efficiency*.
>
> The Forest's analysis concluded that "annual road maintenance funding
> is approximately 25 percent of what is needed based on \[its known
> road system according to its database\]." Nonetheless, the report
> recommends maintaining all roads, such that, despite only having ¼ of
> the necessary funding to maintain the existing road network, most
> routes will remain open for public and private use. Not surprisingly,
> the Forest also concludes that, "without new resources, the long term
> condition of NFS roads is expected to deteriorate."

-   The Upper Missouri River Breaks National Monument RMP, Montana,
    received repeated comments, including those of the federal district
    court in the *Montana Wilderness Association v. Fry* case, that
    emphasized the need for the BLM to assess the costs of its
    management approach. However, the plan does not analyze and compare
    the costs of mitigating the potential damage to the Monument objects
    from management decisions, such as keeping a high density of roads
    open in the vast acreage of the Monument, or take into account
    whether sufficient funding will be available to cover those costs.
    It seems unlikely that the BLM will be able to meet its obligations
    to protect the Monument from the foreseeable damage from ORVs.

3\. [Recreation sustainability]{.underline}:

The Executive Orders require the BLM and FS to ensure that conflicts
with other recreationists, not using ORVs, are avoided. The BLM's Land
Use Planning Handbook also specifically directs the agency to consider
designation of special recreation management areas to provide a
primitive recreation experience. H-1601-1, Appendix C, Section II.C. The
majority of Americans who visit National Forests and BLM lands do so to
experience wild lands and natural scenery, view wildlife, hike, hunt, or
fish. The Outdoor Industry Association studied "active outdoor
recreation," which was defined as only non-motorized activities:
bicycling, camping, fishing, hunting, paddling, snow sports, wildlife
viewing, trail-running, hiking, and climbing. The report found that
active outdoor recreation contributes an estimated \$730 billion to the
US economy (Outdoor Industry Association,
<http://www.outdoorindustry.org/research.new.php?action=detail&research_id=26>
). According to the U.S. Fish & Wildlife Service, in 2006 Americans
spent \$76.7 billion on wildlife-related recreation. (USFWS 2006,
*[National Survey of Hunting, Fishing and Wildlife-associated
Recreation]{.underline}* -
<http://www.census.gov/prod/2008pubs/fhw06-nat.pdf> ). Contending with
dust, pollution and noise from off-road vehicles disrupts these
experiences.

Unfortunately, the travel planning efforts to date do not provide
sufficient opportunities and areas for quiet, non-motorized recreation
experiences.

[Examples:]{.underline}

-   Utah RMPs: Despite the acknowledged opportunities for primitive
    recreation and solitude in the nearly 3 million acres with
    wilderness characteristics outside existing WSAs, the RMPs do not
    include protection for these experiences, either through designation
    of special recreation management areas or management prescriptions.
    The Draft Monticello RMP would designate more than 500,000 acres as
    special recreation management areas, but only eight percent of this
    acreage (43,507 acres) is proposed for backcountry use -- ORV use is
    identified as a primary activity in all other special recreation
    management areas. Although the Draft Moab RMP identifies about 25%
    of their special recreation management areas as having a
    non-motorized focus, none of them incorporate areas that are
    actually exclusively non-motorized. These RMPs also do not take the
    opportunity to close motorized ways in the 1.8 million acres of
    WSAs, which would not only improve wilderness values but also
    heighten the quiet recreation experience.

```{=html}
<!-- -->
```
-   Bangs Canyon Travel Management Plan, Colorado -- The BLM agreed with
    Colorado citizens that large portions of this area had wilderness
    characteristics. However, the travel management plan designated a
    motorized trail through this area.

-   Western Oregon RMP Revisions: The recreation section of these RMPs
    focuses on proposals to designate new ORV emphasis areas, but fails
    to even consider comparable designations for traditional,
    non-motorized recreational uses, such as hunting, angling, hiking,
    horseback riding, or bird watching. For example, for the 865,800
    acres managed by the Medford District, the RMP proposes 13 ORV
    Emphasis Areas, comprising 100,751 acres. While there are 3 proposed
    special recreation management areas, only one, for the Pacific Crest
    National Scenic Trail, and a portion of another, the Rogue National
    Wild and Scenic River where it is managed for its "wild" values, is
    really focused on providing primitive recreation opportunities --
    for a total of less than 15,000 acres.

-   Apache-Sitgreaves National Forest: The proposed management for the
    inventoried roadless areas in this Forest would open roads currently
    designated as closed, removing opportunities for primitive
    recreation, such as enjoyment of wildlife, that will no longer be
    available with increased motorized use.

[Legal challenges]{.underline}: The glaring inconsistencies of the
travel plans issued to date with the mandates of the Executive Orders,
other applicable laws, and agency guidance, as well as responsible
management of our public lands, has led to formal legal challenges. The
travel plan for the Steens Mountain Cooperative Management Area has been
appealed twice: first because the BLM failed to complete a comprehensive
travel management plan altogether and then again because the plan tried
to designate "obscure routes" that plainly violated the agency's
obligation to protect the values identified in the Steens Act. The
travel plans for the California Desert Conservation Area have also been
subject to a number of challenges: the BLM has been directed by courts
to close portions of the Algodones Dunes to ORVs to protect threatened
and endangered plans and a current lawsuit challenges plans for other
bioregions, including the WEMO, based on designations made without any
reference to or use of the regulatory requirements, as well as ongoing
failures to protect critical habitat. Unless firm and comprehensive
corrections are implemented in the travel planning underway, there are
likely to be more such challenges.

[Status]{.underline}: The FS is in the process of creating travel plans
system-wide, with 108 currently underway. Of these, the majority are in
the earliest stages of scoping or have not yet released a draft
environmental document. The BLM is not subject to a specific rule
requiring completion of travel plans, but is in the process of revising
all of its governing land use plans, which inevitably addresses travel
management decisions, and estimates 50 of these are currently in
revision. (*See*, BLM Land Use Planning webpage:
<http://www.blm.gov/wo/st/en/prog/planning.1.html> ). The agency does
not track completion of all travel planning efforts, especially where
those plans are included in RMPs, although it highlights completion of
nine. (*See,* BLM webpage showing completed travel plans:
<http://www.blm.gov/wo/st/en/prog/Recreation/recreation_national/travel_management/travel_mgt_planning.html>
). The Wilderness Society performed its own informal survey in 2006,
which indicated that approximately 80 comprehensive travel management
plans have been completed or are close to completion. However, other
than plans for units of the Conservation System, most of these travel
plans are for small portions of different planning areas, such as
individual areas of critical environmental concern or special recreation
management areas. As a result, while many travel management plans have
been completed, many more are still needed to address the vast acreage
managed by the BLM.

Based on the agencies' respective commitments to completing travel
planning and the magnitude of acreage at issue, it is critical that
these efforts be conducted correctly. Because the agencies have not
completed plans for most of the lands they manage, there is still an
opportunity for them to comply with direction to manage ORVs in a
sustainable manner. The agencies should be directed to ensure that:

-   Travel plans must prioritize protection of the ecological values of
    our public lands, including wildlife habitat, wilderness values,
    soil, and water, as well as historic and cultural resources. Use of
    ORVs cannot compromise these irreplaceable resources. Units of the
    BLM's Conservation System, cultural resources and other places with
    recognized conservation values should receive special consideration
    for management that will fulfill the purposes for which they have
    been identified.

-   Travel networks should be defined by the agencies' available budgets
    for construction, maintenance, monitoring and enforcement.

-   Natural quiet and beauty of the public lands are without question
    what most people seek when visiting public lands. Interior Secretary
    Kempthorne and Forest Service Chiefs have acknowledged impacts to
    visitor experiences from motorized off-road vehicle use. The
    agencies cannot overlook the importance of providing visitor
    experiences that are not compromised by destroyed scenic views and
    noisy interruption, which scares away wildlife.

The Wilderness Society and our partners appreciate the interest of the
Committee in addressing the management of ORVs on public lands.
Responsible management of ORVs is crucial to the health of our public
lands and on our opportunities to enjoy them. We hope that the BLM and
FS will embrace their responsibilities as stewards of these lands and
use travel planning as a way to protect them. Thank you.

This testimony is submitted on behalf of The Wilderness Society and the
following: Colorado Mountain Club, Center for Biological Diversity,
American Hiking Society, Wild Connections, Central Colorado Wilderness
Coalition, Idaho Conservation League, San Juan Citizens Alliance,
Wildlands CPR, High Country Citizens' Alliance, Wilderness Workshop and
Winter Wildlands Alliance.