United States 

Department of

Agriculture

Forest 

Service

January 2015

Record of Decision 

Oregon Dunes NRA Management Area 10 (C) 

Designated Routes Project

Central Coast Ranger District-Oregon Dunes National Recreation Area, 

Siuslaw National Forest 

Coos, Douglas and Lane Counties, Oregon
The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs 

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contact USDA's TARGET Center at (202) 720-2600 (voice and TDD). 

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employer.
Record of Decision

Oregon Dunes NRA Management Area 10 (C) Designated Routes Project

Central Coast Ranger District-Oregon Dunes National Recreation Area

Siuslaw National Forest

Lane, Douglas and Coos Counties, Oregon

Legal Location: Portions of T.18S., R.12W., Sections 3-5, 8-10, 16-17, 20-21, 28-29, 32-34; 

T.19S., R.12W., Sections 23-26, 35-36; T.23S., R.13W., Sections 23, 26, 34; T.24S., R.13W., 

Sections 3, 9-10, 15-16, 21-22, 27-29, 33-34. W. M. surveyed.

For information contact: 

Central Coast Ranger District-ODNRA

P.O. Box 400

Waldport, OR 97394

541-563-8464

The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and 

activities on the basis of race, color, national origin, gender, religion, age, disability, political 

beliefs, sexual orientation, or marital or family status. (Not all prohibited bases apply to all 

programs.) Persons with disabilities who require alternative means for communication of 

program information (Braille, large print, audiotape, etc.) should contact USDA's TARGET 

Center at (202) 720-2600 (voice and TDD). To file a complaint of discrimination, write USDA, 

Director, Office of Civil Rights, Room 326-W, Whitten Building, 14th and Independence 

Avenue, SW, Washington, DC 20250-9410 or call (202) 720-5964 (voice and TDD). USDA is 

an equal opportunity provider and employer.

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Record of Decision

1. Introduction

This Record of Decision (ROD) documents my decision to select an alternative from the Oregon 

Dunes NRA Management Area 10 (C) Designated Routes Project Environmental Impact 

Statement (FEIS). This ROD was developed according to requirements of the National 

Environmental Policy Act (NEPA), the Council of Environmental Quality’s implementing 

regulations (40 CFR 1500-1508), U. S. Department of Agriculture NEPA regulations (7 CFR 

part 1b), Forest Service NEPA regulations (36 CFR 220), and Forest Service policy in Forest 

Service Manual 1950 and Forest Service Handbook 1909.15.

This Record of Decision contains a brief summary of the environmental analysis completed for 

this project, as well as the rationale for selecting the alternative I will implement. It also contains 

certain findings required by pertinent laws and regulations, and information concerning 

responses to administrative objections filed in response to publication of the draft Record of 

Decision. The Oregon Dunes NRA Management Area 10 (C) Designated Routes Project FEIS is 

incorporated by reference in this decision document and is attached as a separate volume.

2. Background

Analysis Area and Scope

Congress designated the Oregon Dunes on the Siuslaw National Forest as a National Recreation 

Area (ODNRA) in 1972, and prescribed that it be managed for “...public outdoor recreation use 

and enjoyment,” and for “the conservation of scenic, scientific, historic, and other values 

contributing to public enjoyment.” The ODNRA is comprised of approximately 28,900 acres of 

forested areas, water and open sand areas between Florence and North Bend on the Oregon 

coast. This area of diverse and constantly changing landscapes is host to a wide array of outdoor 

recreational uses. 

One popular use of the area is OHV riding. The ODNRA provides a riding experience almost 

unique in the United States, and many families travel long distances to enjoy the open sand. 

OHV riding is a multi-generational, social experience that connects participants to each other and 

the out of doors. Many families consider the opportunity to ride on the ODNRA unique and 

irreplaceable. OHV riders are also an important source of economic activity for coastal 

communities from Florence to Coos Bay. Riders travel long distances to reach the ODNRA and 

often stay for several days in campgrounds or hotels, purchasing supplies from local stores.

Management of the ODNRA is guided by the 1994 Oregon Dunes National Recreation Area Plan 

(the Dunes Plan). The Dunes Plan was adopted, following extensive public involvement and the 

completion of an environmental impact statement, as an amendment to the Siuslaw National 

Forest Land and Resource Management Plan (1990). The 1994 Dunes Plan updated and 

replaced the earlier 1979 Dunes Plan. The 1994 Dune Plan was appealed by 10 separate 

individuals or groups. Each appeal was reviewed by the Regional Office Reviewing Officer 

Richard Ferraro, Deputy Regional Forester at the time. In each case he affirmed the Forest 

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Supervisor’s decision to amend the Siuslaw National Forest Plan with management direction for 

the ODNRA.

The Dunes Plan established separate management areas with differing resource emphases within 

the ODNRA. The Dunes Plan set the conditions for OHV use within each management area 

under Executive Order 11644 and 36 CFR Part 295. The 11 management areas, their primary 

emphases, and associated acres are as follows:

10 (A) – Non-Motorized Undeveloped – 7,830 acres (27%)

10 (B) – Off-Road Vehicle Open – 5,930 acres (21%)

10 (C) – ORV on Designated Routes – 4,455 acres (15%)

10 (D) – Developed Corridors – 1,050 acres (4%)

10 (E) – Snowy Plover Habitat – 1,010 acres (3%)

10 (F) – Plant, Fish and Wildlife Habitat – 3,120 acres (11%)

10 (G) – Wetlands Emphasis – 2,540 acres (9%)

10 (H) – Wildlife and Fish Viewing – 315 acres (1%)

10 (J) – Recommended Wild and Scenic River – 1,090 acres (4%)

10 (K) – Research Natural Area – 1,190 acres (4%)

10 (L) – Noise Control Buffer – 370 acres (1%)

The Dunes Plan provides for public OHV use in two management areas: 

• Management Area 10 (B) includes large areas of open sand and is managed primarily for 

recreational OHV use; 

• Management Area 10 (C) is largely vegetated, and restricts OHV use to “designated 

routes.”

The Dunes Plan provides that MA 10 (C) be managed to “protect vegetated habitats while 

providing controlled opportunities for Off Road Vehicles (ORV) touring and traveling on 

designated routes.” The Dunes Plan further states that the goal for this management area is “to 

minimize OHV impacts on vegetated areas while allowing controlled opportunities for riding and 

travel through the area on designated routes for access to the beach and other areas which are 

open for OHV use.” 

Several routes in MA 10 (C) were identified and designated in the Dunes Plan itself. These 

include major access points to the open sand, many of which are signed and maintained. The 

Dunes Plan also called for the designation of additional routes within 3 years of Plan approval 

and the obliteration or naturalization of non-designated, largely user-developed, routes. In MA 

10 (C), then, the Forest Service was directed to:

• Designate those routes open to OHV use;

• Obliterate those routes not so designated; and

• Restrict OHV use to designated routes. 

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Staffing and budget constraints delayed this effort, as the Siuslaw National Forest focused on 

implementing other direction from the Dunes Plan, including restrictions on alcohol use, 

management of sand camping, development of additional access at Riley Ranch, and recovery of 

the threatened snowy plover. These efforts have largely been successful: restrictions on alcohol 

have limited wild parties and kept the Dunes open to family recreation; sand camping remains 

safe, predictable, and available; the Riley Ranch campground and access trail are open and 

popular; and the plover populations are beginning to recover. However, the delay in designating 

routes in Management Area 10 (C) presents the Forest Service, counties, OHV riders, and other 

interested parties with several management challenges.

The Dunes Plan restricts OHV use in Management Area 10 (C) to designated routes, but the only 

formally designated routes are the major access trails. An extensive network of unauthorized, 

user-developed routes continues to be used and additional routes have probably developed. 

None of these (except the Riley Ranch Trail) have been designated for OHV use, but 

undesignated routes have not been enforced as closed and allowed to re-vegetate either.

The ODNRA is an area characterized by the rapid spread of predominantly non-native, invasive 

plant species, especially European beachgrass (Ammophila arenaria). Some of the userdeveloped routes evolved because they were popular, regularly-used travel ways and rapid 

vegetation encroached on either side making what was once open sand a vegetated area, with a 

now “unauthorized” motorized trail through it. Other trails, as in the Fingers area, involved the 

gradual breakdown of upland forests as riders sought out challenging riding experiences and hill 

climbs.

Without a complete formal route system or adequate signing and closure orders for most of MA 

10 (C), use of undesignated routes and establishment of additional user-developed routes 

continues. Responsible riders cannot reliably tell where riding is appropriate. As a result, the 

majority of existing trails within MA 10 (C) today are not designated routes. This has, in turn, 

led to greater and unnecessary impacts to important plant communities within and adjacent to the 

MA 10 (C) areas. 

In 2005, the Forest Service published a final Travel Management Rule (36 CFR Part 212, 

Subpart B), requiring every national forest to designate those roads, trails, and areas open to 

motor vehicle use. Forest Service regulations (36 CFR 261.13) now prohibit use of motor 

vehicles that is not consistent with the designations. The Siuslaw National Forest completed the 

Siuslaw Travel Management Project in 2009, and has published a motor vehicle use map each 

year since 2010. On most of the 630,000 acre Siuslaw National Forest, travel management was 

relatively simple and non-controversial. Cross-country motor vehicle use in steep, wet, densely 

forested lands is difficult if not impossible. However, the agency recognized in 2009 that route 

designation in the Oregon Dunes National Recreation Area was not complete, and would be 

much more complex. Until route designation is completed, OHV use on many established routes 

in MA 10 (C) is technically prohibited but unenforced under 36 CFR 261.13, an undesirable and 

unsustainable situation. The 2009 Siuslaw Travel Management Project decision pointed towards 

the Designated Routes Project to complete designation on the Oregon Dunes National Recreation

Area.

This project redeems the Forest Service’s responsibility to implement the Dunes Plan, the Travel 

Management Rule, and Executive Order 11644 by designating routes within MA 10 (C), 

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providing OHV access and reasonable, enjoyable connections between valued riding areas while 

minimizing impacts to adjacent and intervening native plant communities and habitat.

This decision is limited in scope. While it does include a non-significant amendment to the 

Dunes Plan, it does not attempt to re-draw the overall balance of motorized and non-motorized 

allocations in the ODNRA. The Dunes Plan established that overall zoning following extensive 

participation by OHV riders, county governments, the environmental community, and others. 

The 1994 Dunes Plan was itself founded on the preceding 1979 Dunes Plan, which was 

developed with the help of the original Advisory Committee called for under the legislation 

establishing the ODNRA. 

OHV riding is a legitimate and appropriate use of the Oregon Dunes, consistent with the 

establishing legislation for the ODNRA. This decision does not close any area zoned in the 

Dunes Plan for open riding. Non-motorized recreation is also an appropriate use of the Oregon 

Dunes. This decision does not open to OHVs any area zoned in the Dunes Plan as nonmotorized. Rather, this decision addresses only Management Area 10 (C) – that portion of the 

ODNRA zoned for OHV use on designated routes only. 

Purpose and Need Summary

The Project is needed to bring on-the-ground practice in Management Area 10 (C) into alignment 

with the Dunes Plan, the Travel Management Rule, and Executive Order 11644 by designating 

an understandable, manageable, and environmentally sustainable system of OHV routes to 

provide for access and enjoyment for recreational visitors. This involves two major components:

1. As directed by the Dunes Plan, the Forest Service must complete the designation of 

appropriate routes within Management Area 10 (C) of the ODNRA. Those routes not 

designated for OHV use must be appropriately re-vegetated and closures must be 

enforced so that the purpose of the 10 (C) designation can be fulfilled, allowing OHV use 

on designated routes while minimizing impacts to surrounding resources.

2. The Project also re-zones portions of Management Area 10 (C) to Management Area 10 

(B), opening them to cross-country OHV use. A fundamental purpose of the 10 (C) 

designation in the Dunes Plan is to restrict cross-country OHV use to protect native 

vegetation. However, parts of Management Area 10 (C) are in fact dominated by 

invasive species such as European beach grass and Scots broom. In part, this reflects 

mapping errors that date back to the original aerial photo interpretation and vegetation 

typing done for the 1994 Dunes Plan. Some areas allocated as MA 10 (C) were better 

suited as MA 10 (B), better meeting the appearance, conditions and management 

objectives of that management area. Non-native, invasive species do not need protection 

from impacts by OHVs. Re-zoning these areas also promotes user understanding and 

acceptance of restrictions that are needed and may further objectives for restoring open 

sand.

A Forest Plan amendment provides for designation of routes beyond the initial 3-year window 

envisioned in the Dunes Plan and re-zones portions of Management Area 10 (C) to Management 

Area 10 (B), opening them to cross-country OHV use.

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3. Decision

Based on my review of the alternatives and environmental impacts described in the Oregon 

Dunes NRA Management Area 10 (C) Designated Routes Project Final Environmental Impact 

Statement (FEIS), the comments on the DEIS submitted by other agencies and the public, the 

evaluation of objections submitted during the objection period, and other information available 

in the project record, I have selected Modified Alternative 4. The specific modifications to 

Alternative 4 are identified in this Record of Decision (ROD).

The following summarizes the analysis completed by the interdisciplinary team of the 

differences between Modified Alternative 4 and Alternative 4 as analyzed in the FEIS.

Modified Alternative 4 will:

• Designate an additional 2.3 miles of trails. This is the same as Alternative 4 in the FEIS.

• Reallocate 518 acres of Management Area 10 (C) to Management Area 10 (B), opening 

these lands to cross-country OHV use. This area contains 46 miles of user-developed 

routes. This is a modification of Alternative 4 in the FEIS because the reallocations of 

areas A3 and A16 have been changed, and an additional area has been added, A17. In the 

North Riding Area, reallocation A3 has been increased from 6 acres to 28 acres, 

containing 1.2 miles user-developed routes. I made this modification because it 

responded to the public’s concern about not having enough trail riding experiences in that 

area and it was close to sand camps sites 1, 2, and 3. Although A3 contains 78% native 

vegetation, OHV use should have a low impact on a majority of those acres because of 

difficult access and seasonal flooding. This area was historically open sand, and has been 

vegetated in response to stabilization of dunes by European beachgrass. Also in the north, 

I added 64 acres to A17 in order to respond to the public’s concern surrounding limited 

trail riding in that area. I feel it was appropriate to respond to this concern by adding 

acreage to A17 since that area does not have any native plant associations and it was 

historically open sand. In the Middle Riding Area, reallocation A16 has been reduced 

from 132 acres to 109 acres, containing 6.3 miles of user-developed routes. I felt that this 

reduction in acres was needed so I could respond to a public concern regarding user 

conflicts on the adjacent non-motorized beach.

This decision amends the Siuslaw National Forest Land and Resource Management Plan 

(Siuslaw Forest Plan; 1990) to:

• Provide for designation of 2.3 miles of trails beyond the 3-year window envisioned in the 

1994 Dunes Plan; and

• Reallocate 518 acres from Management 10 (C) – ORVs on Designated Routes Only, to 

Management Area 10 (B) – Open Riding 

I have determined that this project-level Forest Plan amendment is not significant under 

regulations implementing the National Forest Management Act because it is very limited in 

geographic scope and does not affect the overall mix of goods and services provided from the 

Siuslaw National Forest.

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4. Decision Rationale

I have selected Modified Alternative 4 because this alternative best balances public recreation 

access with environmental protection in Management Area 10 (C) while bringing on-the-ground 

management and the Dunes Plan into alignment. In particular, my decision is guided by the 

following principles:

• Areas in MA 10 (C) that are dominated by invasive species and unnatural vegetation, or 

that were historically open sand, should generally be open to cross-country riding;

• In areas in MA 10 (C) that are dominated by fragile native vegetation including upland 

forests, OHVs should remain on designated trails providing through access to riding 

areas;

• Designations should be easy for riders to understand and recognize on the ground, and 

therefore easier to enforce; and

• The decision should preserve the overall balance of motorized and non-motorized 

opportunities established in the Dunes Plan.

In making this decision, I have considered how well each alternative meets the purpose and need, 

and also how well each alternative responds to public comments and issues. 

Purpose and Need

The purpose of the Project is to bring on-the-ground practice in Management Area 10 (C) into 

alignment with the Dunes Plan, the Travel Management Rule, and Executive Order 11644 by 

designating an understandable, manageable, and environmentally sustainable system of OHV 

routes to provide for access and enjoyment for recreational visitors. This requires completion of 

route designation, enforcement of closures, and re-zoning those portions of MA 10 (C) better 

suited to open riding to MA 10 (B).

Designating additional routes to help create a more comprehensive, legal, and understandable 

system, along with enhanced route signing, rider education, unauthorized route closure, and 

strong enforcement will help meet the following management objectives: 

• Facilitate OHV rider access through various parts of MA 10 (C) that are currently 

difficult to understand and navigate on the ground;

• Provide a designated system of routes for OHV access, legally recognized in Forest 

Service planning documents, so that riders have assurance that riding remains legal; 

• Encourage user acceptance of and compliance with designated route requirements in MA 

10 (C) areas; 

• Protect areas of native, upland forest by discouraging use of unauthorized, userdeveloped routes and allowing them to be rehabilitated or to revert naturally to a more 

natural condition; and

• Simplify OHV management within MA 10 (C), allowing agency personnel to focus more 

on visitor education, resource restoration, compliance and enforcement of closures.

The selected alternative best meets the stated purpose and need for action by maintaining riding 

opportunities, limiting impacts to native vegetation, and providing access to all existing 

designated sand camps.

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How issues were considered and taken into account

Modified Alternative 4 was selected because it is the most responsive alternative to comments 

received on the DEIS. The individual comments and responses are found in Appendix A of the 

FEIS. The comments represent a wide variety of viewpoints on the preferred alternative. Some 

comments stated that the preferred alternative was too restrictive of motorized vehicle 

opportunities while other comments stated that the preferred alternative increased motorized 

vehicle opportunities too much. All of the comments were considered in the decision.

Using the comments from the public and other agencies, as well as internal knowledge of the 

area and situation, the interdisciplinary EIS team identified a list of eight issues associated with 

this project: 

1. Maintenance of the OHV trail-riding experience

2. Noise impacts on nearby residents and non-motorized recreationists

3. OHV impacts on native vegetation 

4. Rider safety

5. OHV impacts on wildlife and their habitats

6. OHV impacts on wetlands 

7. Visitation and local economic effects 

8. Maintenance of motorized access to designated sand camps and motorized access from 

sand camps within MA 10 (C) to open riding areas in MA 10 (B)

Issue 1: Trail Riding Experience 

Changes to OHV route designation and enforcement of existing closures can affect the quantity 

and quality of OHV riding experiences. Many riders’ comments spoke specifically to the 

importance of trail riding opportunities, especially for families. Trails through vegetation are a 

specific feature of MA 10 (C) not found as often in the wide-open dunes of MA 10 (B). Trails 

offer a different experience than open sand. Some forested trails provide the opportunity for 

challenge and adventure, but many of the trails on gentler ground provide a more controlled 

environment for family riding. Some of the best trails riding experiences are not found on the 

wide connecting routes between riding areas or from the open sand to the beach, but rather in the 

meandering system of user-developed routes through various topography and terrain. This maze 

of small routes developed over many years as vegetation gradually encroached into areas that 

were once open sand and as visitors pioneered new routes through vegetated areas in the absence 

of clearly signed designated routes and effective closure efforts by the Forest Service. As these 

mazes of trails cannot be effectively tracked and maintained as individual trails, an effective way 

to continue providing this recreation opportunity is to reallocate trail maze areas as MA 10 (B) 

(open riding) and rely on continued use to keep the routes open and available for the trail riding 

experience.

The selected alternative maintains family trail riding opportunities by re-zoning 518 acres of 

gentler ground including 46 miles of user-created trail for open riding.

Issue 2: Noise 

The sound of OHV riding can affect the lives of nearby residents and the quality of nonmotorized recreationists’ experiences. Buffers near homes and popular non-motorized 

campgrounds and an overall limit on vehicle sound emissions are built into the design of the 

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Dunes Plan. We received comments on noise from local residents, and the issue of noise was 

incorporated into the design of each alternative. Therefore, there is no measureable difference 

among any of the alternatives with regard to the possible impact of noise on nearby residents and 

non-motorized recreationists. No designated routes or reallocations to open riding are in areas 

that will increase sound from OHVs into residential areas or areas of quiet recreation. In fact, 

areas of unauthorized user-developed routes along the eastern boundary of the ODNRA from 

which sound funnels down into nearby communities would be enforced as closed, therefore 

reducing the impact of sound in all alternatives.

The selected alternative retains all sound buffers and sound restrictions in the Dunes Plan.

Issue 3: Native Vegetation

Route designation and re-zoning from 10 (C) to 10 (B) may affect native vegetation. This issue 

was raised by environmental organizations, ecologists, scientists and others, and applies to those 

portions of MA 10 (C) which are dominated by native vegetation rather than by invasive species. 

The issue is complicated by the fact that patterns of vegetation have been heavily altered by 

humans over time -- both directly (plantations of beach grass, Scots broom, and shore pine) and 

indirectly (vegetation developing on areas affected by dune stabilization). Some areas now 

dominated by native vegetation, such as wetlands in the deflation plain and shore pine 

plantations, were once open sand. Other areas, such as tree islands and the Fingers in the Middle 

Riding Area, have been forested for many decades.

The selected alternative protects native forests by focusing OHV use on those parts of MA 10 

(C) that were historically open sand. Only 2 acres of native forest known as Banshee Hill are rezoned for riding on long-established trails. 

Issue 4: Rider Safety

This issue was raised primarily by riders concerned that closure of user-developed, unauthorized 

routes may affect rider safety by concentrating riders into smaller areas and fewer routes. 

Over 40 years of management of the ODNRA indicates that there are multiple factors that 

determine the "safety" of the OHV riding setting and experience. Rider density can be one of 

those but others include: rider behavior, speed, ability, topography, visibility, familiarity with the 

area/terrain, protective gear, and familiarity with the machine. Past history at the Dunes seems to 

indicate that even in popular, more congested areas of the ODNRA, vehicle on vehicle accidents 

are rare. Most rider injuries occur in lower density areas and are due to people operating 

machines beyond their skill/competency level, rather than from crashing into one another.

By its nature, OHV riding can be a high risk outdoor recreation activity. Given the numerous 

rider safety variables over which the Forest Service has no control and the inability to accurately 

predict future rider density, the Forest has proposed only alternatives that it believes provide for 

rider safety. The Forest has not proposed any alternatives believed to be potentially dangerous to 

OHV riders, taking into consideration the inherently dangerous aspects of the activity. 

Most riding on the Oregon Dunes takes place in MA 10 (B), the area zoned for open riding. The 

selected alternative re-zones the most popular areas and trails within MA 10 (C) for open riding 

as well. By avoiding any closure of popular, heavily used riding areas, the selected alternative 

would not result in any measurable increase in rider concentration, and would not affect rider 

safety.

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Issue 5: Wildlife and Habitat

The issue of wildlife habitat was incorporated into the design of each alternative. All action 

alternatives seasonally close the Siltcoos Breach beach access to motorized vehicles from 

September 16 through March 14 to protect snowy plover wintering habitat. All alternatives 

protect natural wetlands and natural upland forests, and the wildlife associated with them. 

Formal consultation on Threatened, Endangered and Proposed Species with the U.S. Fish and 

Wildlife Service was initiated through a biological assessment. The Fish and Wildlife Service’s 

Biological Opinion concluded that the project may affect individual birds, but is not likely to 

jeopardize the continued existence of the snowy plover, and provided an incidental take 

statement and reasonable and prudent measures to prevent jeopardy. Completion of route 

designation and restriction of OHV riding to designated routes will improve protection of snowy 

plover habitat. The Forest Service has adopted the reasonable and prudent measures in this 

ROD.

Issue 6: Wetlands

Natural Wetlands: The issue of natural wetlands was incorporated into the design of each action 

alternative. Natural wetlands are protected by project design criteria in all alternatives.

Unnatural Wetlands: Unnatural wetlands have developed behind foredunes due to the 

introduction and establishment of European beach grass. These wetlands continue to increase in 

size eastward as the local foredune increases in height. Current OHV use in and in the vicinity 

of these wetlands is not inhibiting the eastward expansion of deflation plains. In many cases, 

large areas of historically open sand are now inundated and crowded with vegetation, with only a 

few narrow trails remaining. The interdisciplinary team used historic photos to distinguish 

natural wetlands and natural vegetation from those created due to stabilization of dunes by 

invasive beach grass. The selected alternative protects natural wetlands, and allows OHV use to 

continue in unnatural wetlands that were formerly open sand by re-zoning them as MA 10 (B).

Issue 7: Visitation and Local Economic Effects

Recreation and tourism is the leading economic sector for most of the Oregon coast, and 

especially for the communities around the Oregon Dunes. Many local businesses, including 

hotels, restaurants, outfitters-guides, and commercial campgrounds serve visitors directly. Even 

businesses not directly involved in service delivery are dependent on income and economic 

activity from visitors to the coast. Visitors come from across the world and for a variety of 

activities, renting beach houses, staying in hotels, driving Highway 101, hiking, sandboarding, 

taking pictures, playing on the beaches, and riding OHVs. Both motorized and non-motorized 

areas of the Oregon Dunes are popular with visitors.

As a group, OHV riders are important contributors to the economy. The sport is social and 

family-based and involves equipment that is expensive to purchase and to maintain. The Oregon 

Dunes is one of the country’s premier destination OHV riding areas, and attracts enthusiasts 

from around the world. Counties, communities, riders and the Forest Service are united in 

wanting to preserve this opportunity. 

Comments from county and local governments, community members and riders expressed 

concern that closure of non-designated, user-developed, unauthorized routes could reduce 

visitation and thereby adversely affect local economies.

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Many factors affect annual visitation to the Oregon Dunes, including weather, fuel costs, other 

available destinations, and the state of the broader economy. All the variables that affect a 

person’s decision to visit the Oregon Dunes interact with each other, making it very difficult to 

predict the effects of marginal changes in local policy on an individual decision to visit.

The scope of this decision is very limited, and none of the alternatives considered here changes 

the overall balance of motorized and non-motorized uses established in the Dunes Plan. Areas 

zoned for open riding will remain open. Areas zoned non-motorized will remain non-motorized. 

This decision affects only that part of the Dunes zoned for riding on designated trails (MA 10 

(C). 

Parts of MA 10 (C) are popular with riders, dominated by non-native or introduced vegetation, 

and support a network of well-used, well-established trails. The selected alternative re-zones 

these areas for open riding. Other parts of the MA 10 (C) are dominated by natural upland 

forest, and support few trails. These areas would remain open only on designated routes. While 

some users’ experiences may be affected at the margins as we bring the Dunes Plan and usage on 

the ground into alignment, we do not expect any change in overall visitation to the Dunes as a 

result of implementation of the selected alternative, or any effect on the local economy.

Past experience supports this conclusion. In the past 20+ years, three important decisions have 

affected OHV use at the ODNRA: the 1994 Oregon Dunes Plan; the 2003 alcohol ban in OHV 

riding areas; and the 2005 designated-site sand camping decision. During scoping and public 

comment for each of these decisions, some predicted a decline in visitation if the decision was 

enacted. That did not occur. Despite enactment of all three decisions, OHV use has remained 

steady and there were no significant adverse economic effects in local communities. 

Issue 8: Access to Sand Camps

Seven designated sand camps are connected to open riding areas only through user-created 

routes. Through a combination of formal route designation, re-zoning of areas to open riding, 

and relocation of sand camps to more favorable sites, the selected alternative ensures continued 

access to sand camps and availability of sand camping experiences. 

Public Input Beyond the Scope of this Proposal

Many comments addressed issues ranging far beyond the narrow scope of this proposal but 

worthy of brief note here.

Revision of the Dunes Plan

As a component of the Siuslaw National Forest Land and Resource Management Plan (Forest 

Plan), the Dunes Plan establishes the overall management direction for the Oregon Dunes NRA, 

including the balance of motorized and non-motorized recreation opportunities. The Dunes Plan 

was first approved in 1979, and was revised in 1994. 

Many comments from OHV riders and others suggest re-zoning all of MA 10 (C), including 

native upland forests, for open riding. Others suggest establishing new riding opportunities, 

connecting the southern riding area and the middle riding area with a designated trail or 

otherwise opening up large non-motorized portions of the Dunes to OHV use. Meanwhile, 

comments from non-motorized visitors and others suggest closing all or major parts of the Dunes 

to OHV use. These comments mirror those the Siuslaw has received in each revision of the 

13
Dunes Plan. The balance between motorized and non-motorized recreation opportunities on the 

Oregon Dunes has been at issue since before the Oregon Dunes NRA was established, and at 

some level the partisans on all sides remain unsatisfied with the result.

I am sensitive to the passion and dedication that people bring to the fundamental questions 

around how the Oregon Dunes should be managed and for whom, and there’s a time and a place 

to wrestle with them. But this is not that time. Forest Plan revisions are expensive and time 

consuming, the next Forest Plan revision is not scheduled for several years, and the continuing 

debate over how much of the Dunes should be zoned for OHV use has not raised any 

fundamentally new questions. The route designation decision documented in this ROD 

implements the Dunes Plan and includes a non-significant amendment to bring the intent of the 

Dunes Plan into alignment with use on the ground. Revision of the Dunes Plan in its entirety is 

beyond the scope of this ROD.

Control of Invasive Species and Restoration of Open Sand 

The greatest threat to both the ecology of the Oregon Dunes and to their continued public 

enjoyment is the spread of invasive species. Beginning late in the 19th century, communities and 

government agencies, including the Forest Service, planted European beachgrass in dunes along 

the Pacific coast to protect harbors, highways, and communities from blowing sand. It did its job 

too well. European beachgrass continues to stabilize sand and to change the processes that 

created and maintain the Oregon Dunes. Foredunes trap sand and prevent its inland movement, 

allowing winds to scour out the deflation plain. Beachgrass-stabilized dunes are quickly 

dominated by shrubs and trees in this temperate rainforest. 

The Dunes Plan calls for vegetation treatment to restore dune geomorphological processes in 

localized areas, with an emphasis on snowy plover habitat and globally significant plant 

communities (Dunes Plan, III-13 to III-18). Manual, mechanical, and chemical treatments and 

prescribed fire have been successful in controlling invasive species at specific sites – especially 

around snowy plover habitats. In 2013, the Siuslaw National Forest mechanically removed 

invasive vegetation from 44 acres near Bull Run with the help of a D7 bulldozer, the local fire 

crew, and enthusiastic OHV riders. Additional treatments are carried out every year – but the 

scope of the challenge, the limits of available resources and control techniques, and the hardiness 

of beachgrass mean that this will be an ongoing effort.

Many comments from OHV riders pointed to invasive beachgrass – not OHVs – as the chief 

threat to the dunes, and argued that we should redouble efforts to control beachgrass rather than

close the dunes to OHV use. In large part, we agree. We do not propose to close any open riding 

areas, but instead to open 518 acres dominated by invasive species by re-zoning them from 

Management Area 10 (C) to Management Area 10 (B). Meanwhile, we are working on two 

levels to address the invasive species problem itself. Specific, on-the-ground projects like Bull 

Run are implemented each year while we simultaneously develop an overall strategy for dunes 

restoration in cooperation with riders and environmental groups. However, these efforts are 

addressed in separate environmental analysis, beyond the scope of this ROD.

Designation of OHV routes (this decision) and control of invasive species (as in the Bull Run 

treatment decision) are distinct projects, each implementing the overall direction of the Dunes 

Plan. We need not choose one or the other. 

14
Environmental Effects

This decision considers the balance of environmental effects presented in detail in Chapter 3 of 

the FEIS. All of the alternatives are consistent with all applicable laws including the Endangered 

Species Act, the National Forest Management Act, the Clean Water Act and the Act designating 

the Oregon Dunes NRA.

5. Public Involvement

Chapter 1 of the FEIS describes in detail the public outreach and involvement associated with 

this project. Comments on the DEIS made by individuals and organizations are individually 

addressed in Appendix A of the FEIS. The perspective and individual points in these comments 

were considered by the interdisciplinary team. For specific information on how comments were 

addressed, refer to Appendix A.

In 2009, the Siuslaw National Forest hired an independent contractor to assemble and facilitate a 

working group with a wide variety of interests to discuss the challenges and opportunities 

associated with OHV use in that portion of the Oregon Dunes NRA zoned for riding on 

designated routes (Management Area 10 (C)). The working group held public meetings and field 

trips throughout the Dunes, and in 2010 provided a report including a range of different ideas 

and recommendations regarding trails and riding areas, posted on the Forest website. The Forest 

Service considered the working group’s report in developing an initial proposed action for public 

consideration. 

Scoping

The Forest published a Notice of Intent to prepare an EIS on June 24, 2011. A scoping letter was 

mailed to approximately 150 individuals, groups and agencies. Over 800 scoping comment 

letters were received, as well as petitions containing nearly 6,500 signatures and comments. 

Responses expressed a wide variety of opinions about the proposed action and information to be 

disclosed in the draft EIS. These comments were used to identify issues, alternatives to the 

proposed action, and the extent of environmental analysis necessary for making an informed 

decision. Information obtained from the scoping process is contained in the Project Record.

Using the comments from the public and other agencies, the interdisciplinary EIS team identified 

eight issues associated with this project: 

• Maintenance of the OHV trail-riding experience

• Noise impacts on nearby residents and non-motorized recreationists

• OHV impacts on native vegetation 

• Rider safety

• OHV impacts on wildlife and their habitats

• OHV impacts on wetlands 

• Visitation and local economic effects 

• Maintenance of motorized access to designated sand camps and motorized access from 

sand camps within MA 10 (C) to open riding areas in MA 10 (B)

15
Comments on the DEIS

The Forest published a Notice of Availability of the Draft EIS in the Federal Register on October 

24, 2012. The Draft EIS was posted to the Forest website. The Forest sent about 700 letters and 

emails announcing the Notice of Availability of the Draft EIS with a web link to the project on 

the Forest Service website. The Draft EIS was placed in public libraries and was available at the 

Forest Service offices in Reedsport, Waldport and Corvallis. At the request of the public the 

initial 45-day comment period was extended an additional 45 days to January 22, 2013.The 

Forest hosted a public meeting in Florence on November 17, 2012. Another public meeting was 

held in Eugene in January, 2013. Other meetings with interested members of the public took 

place in Corvallis in December, 2012 and in Roseburg in January, 2013. In addition the Forest 

met with the Coos, Douglas, and Lane County Commissioners. The Forest received 

approximately 1300 comments on the Draft EIS during the extended comment period. 

Comments and agency responses are included in the FEIS, Appendix A.

Public comments were used to extend and improve the environmental analysis in the EIS to 

ensure that all environmental impacts were considered and disclosed. Comments were also used 

to modify Alternative 4 by adjusting areas proposed for re-zoning as open riding. Many 

comments were mutually exclusive, and beyond the scope of the proposal (re-zone all of the 

Dunes for open riding; re-zone all of the Dunes as closed). I believe that Modified Alternative 4 

strikes a reasonable balance, consistent with the Forest Plan, by re-zoning lands dominated by 

non-native vegetation for open riding while protecting fragile upland forests from trail 

development.

Consultation with Tribes

The Forest Service consulted on a government-to-government basis with the Confederated 

Tribes of Coos, Lower Umpqua and Siuslaw Indians, and a Tribal representative was included in 

the original working group to ensure that Tribal interests were incorporated into the initial 

project design. The Confederated Tribes of the Coos, Lower Umpqua, and Siuslaw Indians sent 

a comment during the comment period in support of the project.

The Siuslaw National Forest also discussed the Designated Routes project during regular 

consultation meetings with the Confederated Tribes of the Siletz and the Confederates Tribes of 

the Grand Ronde. Each of these Tribes deferred to the Coos, Lower Umpqua, and Siuslaw for 

input on this project.

6. Alternatives Considered

Six alternatives were developed and analyzed in detail in the FEIS. Two additional alternatives 

were considered but dropped from detailed consideration. For a more detailed description of 

Alternatives see pages 63-164 of the FEIS.

Alternative 1

Under Alternative 1, the No Action alternative, current management plans would continue to 

guide management of the project area. No additional routes would be designated and no 

management areas would be reallocated to accomplish the identified project goals. 

16
This alternative represents the most radical change in OHV opportunities of all the alternatives. 

User-developed routes within areas of MA 10 (C) not designated in the 2009 Travel 

Management Decision were, by definition, closed to motorized use when the initial Siuslaw 

National Forest Motor Vehicle Use Map was published on December 31, 2009. However, those 

routes and areas have not yet been physically closed nor stringently enforced on the ground. 

OHV riders have continued to ride on many miles of user-developed routes in MA 10 (C), 

pending completion of this decision to designate additional routes. Once this effort is complete, 

those routes and areas not designated in the 2009 Travel Management decision or in this, the MA 

10 (C) Designated Routes decision, will be formally closed and strictly enforced under 

provisions of the 2005 Travel Management Rule (36 CFR Part 212).

Alternative 2

This alternative designates an additional nine OHV routes, totaling approximately 3.4 miles. All 

nine proposed routes exist on the ground as historic, user-developed routes and thus would 

involve no construction or new ground-disturbing activity except mechanically widening a 0.1 

mile existing route. Any user-developed routes not designated in this alternative would be 

enforced as closed to motorized use and obliterated or allowed to naturally revert. 

This alternative would also modify Management Area boundaries, reallocating approximately 

234 acres containing about 30 miles of user-developed routes from MA 10 (C) to MA 10 (B) in 

order to continue to provide OHV trail riding opportunities and to manage 10 (C) areas that

physically resemble adjacent 10 (B) areas in a manner consistent with MA 10 (B) management 

objectives. The reallocation includes an area commonly known as Banshee Hill in the Umpqua 

Dunes riding area. Approximately 102 miles of unauthorized user-developed routes would be 

closed and obliterated or allowed to revert naturally.

Alternative 3

This alternative designates eleven routes totaling approximately 3.6 miles as open to motorized 

vehicles. All proposed routes exist on the ground as historic, user-developed routes and thus 

would involve no construction or new ground-disturbing activity. Any user-developed routes not 

designated would be enforced as closed to motorized use and obliterated or allowed to naturally 

revert. Approximately 131 miles of unauthorized user-developed routes would be enforced as 

closed and eventually naturalized. 

This alternative is based on scoping comments that recommended an alternative limited to route 

designation only with no reallocations from MA 10 (C) to MA 10 (B).

Alternative 4

This alternative designates eight routes totaling about 2.3 miles. All proposed routes exist on the 

ground as historic, user-developed routes and thus would involve no construction or new grounddisturbing activity except mechanically widening a 0.1 mile existing route. The alternative would 

also modify Management Area (MA) boundaries, reallocating approximately 455 acres 

containing about 49 miles of user-developed routes. The reallocation from MA 10 (C) to MA 10 

(B) would provide OHV trail riding opportunities. Areas that were zoned MA 10 (C) but more 

closely resemble MA 10 (B), would be managed to meet MA 10 (B) objectives. Approximately 

84 miles of user-developed routes would be enforced as closed and obliterated or eventually 

naturalized under this action.

17
Modified Alternative 4

This alternative has the same proposed designated routes as Alternative 4. It differs from 

Alternative 4 in three proposed reallocations. The A16 reallocation in the Middle Riding Area 

would be reduced in acres from 132 acres to 109 acres. The western boundary of the A16 

reallocation was moved further inland to reduce user conflicts on the non-motorized beach and to 

lessen opportunities for motorized vehicles to enter the non-motorized beach. Another change is 

to A3 in the North Riding Area. This reallocation was increased from 6 acres to 28 acres in 

order to open a popular area for trail riding, particularly among families with children. A new 

reallocation, A17 (64 acres), was added in the North Riding Area. A17 is an area of historically 

open sand with no native plan associations.

Alternative 5

This alternative includes the proposed designation of ten additional routes for a total of 2.9 

additional miles. All proposed routes exist on the ground as historic, user-developed routes and 

thus would involve no construction or new ground-disturbing activity except mechanically 

widening a 0.1 mile existing route. Alternative 5 also includes 12 areas that would be reallocated 

from MA 10 (C) to MA 10 (B). In total, about 966 acres, the most of all the alternatives, are 

proposed for reallocation. Within those acres, about 70 miles of user-developed routes would 

remain available to OHV riding. Approximately 62 miles of user-developed routes would be 

closed and obliterated or eventually naturalized under this action.

7. The Environmentally Preferable Alternative

Modified Alternative 4 is the environmentally preferable alternative. It is the alternative that 

best achieves the purposes of Section 101 of the NEPA to “create and maintain conditions in 

which man and nature can exist in productive harmony.” By focusing OHV use on open sand 

and lands dominated by invasive species, areas wherein OHVs would have a low impact on 

vegetation, protecting fragile upland forests from trail development, and designating an 

understandable and enforceable system of trails for motor vehicle use, Modified Alternative 4 

causes the least damage to the biological and physical environment. 

8. Findings Required by Other Laws, Regulations, and Orders

National Forest Management Act

Implementation of this project requires a forest plan amendment to the Siuslaw National Forest 

Land and Resource Management Plan (Siuslaw Forest Plan). There are two components to this 

amendment. This decision would amend the Siuslaw National Forest Land and Resource 

Management Plan (Siuslaw Forest Plan; 1990) to:

• Provide for designation of 2.3 miles of trails beyond the 3-year window envisioned in the 

1994 Dunes Plan; and

• Reallocate 518 acres from Management 10 (C) – ORVs on Designated Routes Only, to 

Management Area 10 (B) – Open Riding 

18
Both components of this amendment make changes to the 1994 Dunes Plan, which was itself an 

amendment to the Siuslaw Forest Plan.

The 2012 planning rule provides for transition period for forest plan amendments initiated prior 

to May 9, 2012 (36 CFR 219.17 (3)). During the transition period, amendments may be made in 

conformance with the provisions of the prior planning regulation. This decision includes a forest 

plan amendment to the Siuslaw Forest Plan following the 1982 planning rule procedures. The 

Forest Service Land Management Planning Manual (Forest Service Manual 1926.51) lists four 

criteria for evaluating the significance of changes to forest plans: 

1. Actions that do not significantly alter the multiple-use goals and objectives for long-term 

land and resource management.

The two components of this amendment will not change any Forest Land and Resource 

Management goals or objectives.

2. Adjustments of management area boundaries or management prescriptions resulting from 

further on-site analysis when the adjustments do not cause significant changes in the 

multiple-use goals and objectives for long-term land and resource management. 

The component of the amendment that allows the designation of trails beyond the 3-year 

window envisioned in the 1994 Dunes Plan does not adjust management area boundaries 

or management prescriptions.

The component of the amendment that adjusts management area boundaries from 

Management Area 10(C) to Management Area 10(B) does not cause significant changes 

in the multiple-use goals and objectives for long-term land and resource management of 

the Siuslaw National Forest. Alternative 4 Modified reallocates 518 acres from 

Management Area 10(C) to Management Area 10(B). These management area boundary 

changes are extremely limited in scope (518 acres out of 630,000, or less than one-tenth 

of 1%) relative to the entire Siuslaw National Forest (and 1.7% of the ODNRA), retain 

the overall balance of lands allocated to motorized and non-motorized uses, and are 

consistent with the intent of the management area descriptions (lands requiring protection 

from cross-country riding remain MA 10 (C), while lands dominated by non-native 

vegetation are re-zoned as MA 10 (B). Effects from these boundary adjustments are 

discussed in detail in Chapter 3 Environmental Consequences by resource.

3. Minor changes in standards and guidelines. 

The Dunes Plan recognized that OHV trails in MA 10 (C) must be designated, but 

included a guideline anticipating that designation would be completed within 3 years (by 

1997). One component of this amendment recognizes that work is being completed much 

later than suggested. This amendment is specific to only this project.

The effects of the component of the amendment that adjusts management area boundaries 

from Management Area 10 (C) to Management Area 10 (B), which results in changing 

the standards and guidelines for 518 acres, is discussed in detail in Chapter 3 

Environmental Consequences by resource.

4. Opportunities for additional projects or activities that will contribute to achievement of the 

management prescription. 

No additional management practices are included in either component of this forest plan 

amendment. This amendment does not apply to any other designations of OHV routes in 

19
the project area or on the Oregon Dunes National Recreation Area. This amendment does 

not eliminate any future opportunities to achieve the management prescription.

Overall Finding: On the basis of the information and analysis contained in the FEIS and all 

other information available as summarized above, it is my determination that the two 

components of this Forest Plan amendment (re-allocation of 518 acres from MA 10 (C) to MA 

10 (B); and designation of OHV routes in MA 10 (C) beyond the initial 3 year window) are not 

significant amendments of the Forest Plan under provisions of the National Forest Management 

Act.

In all other respects, the project is fully consistent with the goals, objectives, standards, and 

guidelines of the Siuslaw National Forest Land and Resource Management Plan, as amended.

This decision complies with the Northwest Forest Plan as amended by the 2001 Record of 

Decision and Standards and Guidelines for Amendments to the Survey and Manage, Protection 

Buffer, and other Mitigation Measures Standards and Guidelines. It considers suitable habitat 

for survey and manage species and applies appropriate mitigations providing for a reasonable 

assurance of species’ persistence.

Inventoried Roadless Areas

Management Area 10 (C) lies within two Inventoried Roadless Areas, Woahink (5,060 acres) 

and Tenmile (7,798 acres). Maps displaying the Inventoried Roadless Areas boundaries in 

relation to Management 10 (C) are attached. A Wilderness Suitability Report, Oregon Dunes 

National Recreation Area (ODNRA), was completed on September 30, 1976. An analysis of all 

lands within the ODNRA determined that no portion of the Act meets the requirements for 

wilderness as stated in The Wilderness Act, P.L. 88-577. The Forest Service proposed that the 

Secretary of Agriculture convey to the President the recommendation that no lands within the 

ODNRA be designated as wilderness and added to the Wilderness Preservation System (USFS, 

1976).

The Final Environmental Statement on Wilderness Suitability, Oregon Dunes National 

Recreation Area, was completed on January 10, 1977. It found that no area was suitable for 

wilderness (USFS, 1977).

The designation of motorized trails in an inventoried roadless area is allowed. The 2001 

Roadless Rule does not apply to this project because the Rule only prohibits the construction and 

reconstruction of roads and the harvest of timber. The designation of a motorized trail is not 

prohibited in the Rule. On January 12, 2001, the Federal Register published the Roadless Area 

Conservation Rule, 36 CFR Part 294. It states: “A trail is established for travel by foot, stock, or 

trail vehicle, and can be over, or under, 50 inches wide. Nothing in this paragraph as proposed 

was intended to prohibit the authorized construction, reconstruction, or maintenance of 

motorized or nonmotorized trails that are classified and managed as trails pursuant to existing 

statutory and regulatory authority and agency direction (FSM 2350). Nor was anything in this 

paragraph intended to condone or authorize the use of user-developed or unauthorized roads or 

trails. These decisions are made subject to existing agency regulations and policy and that intent 

has been retained in the final rule.” (FR page 3251).

Although no construction of designated routes is proposed, the designation of motorized trails 

was tested in court (Umpqua Watershed v. USFS, 2010) with the Riley Ranch Access project 

(USFS, 2009) and was found consistent with Roadless Area Conservation Rule.

20
Furthermore, the Forest Plan recognized that both the Woahink and the Tenmile Inventoried 

Roadless Areas have long provided for extensive use for off-road motorized vehicles. Thus, this 

project aligns with that Forest Plan’s intent for these Inventoried Roadless Areas.

Endangered Species Act

The Siuslaw National Forest concluded in a Biological Assessment for the Designated Routes 

Project that designation of OHV routes and re-allocation of lands for open riding has the 

potential to adversely affect the threatened western snowy plover (Charadrius nivosus ssp. 

nivosus). The Forest conducted formal consultation with the US Fish and Wildlife Service. The 

Fish and Wildlife Service’s Biological Opinion concluded that the project may affect individual 

birds, but is not likely to jeopardize the continued existence of the species, and provided an 

incidental take statement and reasonable and prudent measures to prevent jeopardy. Completion 

of route designation and restriction of OHV riding to designated routes will improve protection 

of snowy plover habitat. The Forest Service has adopted the reasonable and prudent measures in 

this ROD.

As determined in the Biological Evaluation, implementation of Modified Alternative 4 will have 

no effect on any listed fish species or their designated critical habitats. Consultation with 

National Marine Fisheries Service (NMFS) was therefore, not necessary.

The Biological Assessment concluded that the proposed action will have No Effect on any other 

species listed as Threatened or Endangered. 

The Project File includes the Biological Assessment, Biological Opinion, and letters of 

concurrence. Also refer to pages 108-115 of the FEIS for further discussion of impacts to snowy 

plover and other listed species.

Clean Water Act

The Clean Water Act provides direction “to restore and maintain the chemical, physical, and 

biological integrity of the Nation’s waters”. To carry out this law, the State of Oregon has 

established state water quality standards for factors such as water temperature, sedimentation, 

habitat modification and pH, and an anti-degradation policy to protect water quality conditions. 

Under the anti-degradation policy in Section 303(d), water bodies that do not meet water quality 

standards are designated as “water quality limited”.

Best Management Practices and Management Requirements listed in Chapter 2 of the FEIS 

would ensure the protection of water quality. There would be no additional effect to the 

parameters for which certain streams were placed on the 303(d) list. Therefore, as indicated in 

the FEIS page 164, Modified Alternative 4 is consistent with the Clean Water Act.

National Historic Preservation Act

Background research for cultural resources was conducted for the project, including a thorough 

review of relevant historic records, reference literature, and cultural resource files on the Siuslaw 

National Forest. The Forest Archaeologist reviewed the list of proposed actions and assessed 

their potential to affect historic properties according to the terms of the 2004 Programmatic 

Agreement between the USDA Forest Service, Pacific Northwest Region (Region 6), the 

Advisory Council on Historic Preservation, and the Oregon State Historical Preservation Officer 

(PA).

21
The proposed actions analyzed for the current project are covered under Appendix B of the PA, 

which means that the undertaking(s) may be excluded from case-by-case review with the State 

Historic Preservation Office (SHPO) based on inspection or monitoring as determined by the 

Forest Archaeologist. Specifically, under Appendix B: 14 of the PA it is noted that: 

“Off-highway vehicle (OHV) trail designations that utilize existing roadways and trailways 

provided that no properties have been recorded within or adjacent to the roadways or trailways.” 

Civil Rights, Women, and Minorities

Adverse effects on civil rights, women and minorities are not expected from implementing 

Modified Alternative 4, as addressed on page 164 of the FEIS. To the greatest extent possible, all 

populations have been provided the opportunity to comment before decisions are rendered on 

proposals and activities affecting human health or the environment. The activities in this decision 

will not have a direct or indirect negative effect on minority or low-income populations.

Environmental Justice

Executive Order 12898 directs each Federal agency to make achieving environmental justice part 

of its mission by identifying and addressing, as appropriate, disproportionately high and adverse 

human health or environmental effects of its programs, policies, and activities on minority 

populations and low-income populations. This order is accompanied by a memorandum, 

emphasizing the need to consider these types of effects during NEPA analysis. Where Forest 

Service proposals have the potential to disproportionately adversely affect minority or lowincome populations, these effects must be considered and disclosed (and mitigated to the degree 

possible) through the NEPA analysis and documentation. Effects on the human environment 

from implementation of Alternative 4 are expected to be similar for all human populations, 

regardless of nationality, gender, race, or income (refer to Page 163 of the FEIS). Restrictions on 

motor vehicles necessary to protect the environment and applied equally to all visitors, are not 

discriminatory. Therefore, Alternative 4, Modified is found to be consistent with Executive 

Order 12898. 

Wetlands and Floodplains

Executive Order 11990 requires that government agencies take action to minimize the 

destruction, loss, or degradation of wetlands. Executive Order 11988 requires government 

agencies to take actions that reduce the risk of loss due to floods, to minimize the impact of 

floods on human health and welfare, and to restore and preserve the natural and beneficial values 

served by floodplains.

European beach grass created an unnaturally high foredune that has blocked the inward 

migration of sand from the beach. This has led to the creation of a larger, more permanent 

deflation plain and “exposure” of the water table over a larger area than would naturally occur. 

Off-highway vehicle traffic is having only a limited effect on the encroaching vegetation in these 

areas and is having little, if any, effect on exposure of the water table. Floodplains in the classic 

sense would not have existed in unstable, shifting sand dunes. Floodplains may be developing in 

areas where encroaching vegetation has stabilized the sand next to flowing water such as where 

Cleawox Creek flows through the deflation plain. Off-highway vehicle traffic is, again, having 

only a limited effect on the encroaching vegetation in these areas and is having little, if any, 

effect on the development of floodplains. 

22
Travel Management Rule

Executive Order 11644 and the Travel Management Rule, 36 CFR 212.55(b) instructs the 

responsible official to consider the effects on National Forest System natural and cultural 

resources, public safety, provision of recreational opportunities, access needs, conflicts among 

uses of National Forest System lands, the need for maintenance and administration of roads 

trails, and area that would arise if the uses under consideration are designated; and the 

availability of resources for maintenance and administration.

Specific criteria for designation of trails and area instruct the responsible official to consider 

effects on the following, with the objective of minimizing:

• Damage to soil, watershed, vegetation, and other forest resources.

Chapter 3, Environmental Consequences in the FEIS includes subsections that discuss 

effects to Botanical Resources, Hydrology and Soils, Fisheries and Aquatic Conservation 

Strategy.

• Harassment of wildlife and significant disruption of wildlife habitats.

Chapter 3, Environmental Consequences in the FEIS includes subsections that discuss 

effects to Wildlife

• Conflicts between motor vehicle use and existing or proposed recreational uses of National 

Forest lands of neighboring Federal lands.

Chapter 3, Environmental Consequences in the FEIS includes subsections that discuss 

effects to Recreation.

• Conflicts among different classes of motor vehicles uses of National Forest lands or 

neighboring Federal lands.

Chapter 3, Environmental Consequences in the FEIS includes subsections that discuss 

effects to Recreation.

• Compatibility of motor vehicle use with existing conditions in populated areas, taking in 

account sound, emissions, and other factors.

Chapter 3, Environmental Consequences in the FEIS includes subsections that discuss 

effects to Recreation.

The objective of the Designated Route Project is to implement the 1994 Dunes Plan designation 

of Management Area 10 (C). The five factors above were also analyzed extensively in the Dunes 

Plan which is an amendment to the Siuslaw National Forest Plan of which this project is tiered.

9. Objection Process

When the draft EIS was released, the associated documentation indicated that the upcoming 

decision would be subject to an administrative appeal process according to the Code of Federal 

Regulations (36 CFR 215); this process allowed people who submitted comments during the 

comment period on the draft EIS an opportunity to appeal the final decision after it is signed. 

However, on March 27, 2013, new regulations were released that apply to the Designated Routes 

project. 

23
The new regulations, found at 36 CFR 218, provide an opportunity for individuals, organizations 

and tribal entities to file an objection to a project before the final decision is signed. This allows 

interested individuals, organizations and tribal entities to advise the Deciding Official about 

concerns regarding the final decision before the decision is made. The new 218 regulations allow 

anyone who submitted timely, specific written comments about the proposed project during any 

designated opportunity for public comment, to file an objection to the draft decision (36 CFR 

218.5). The regulations can be found at 

http://federal.eregulations.us/cfr/title/5/28/2013/title36/chapterII/part218.

Objections were subject to review by a “reviewing officer;” because the Responsible Official for 

the Designated Routes project is the Siuslaw National Forest Supervisor, the reviewing officer is

the Regional Forester.

The objection process included an opportunity, on December 18, 2014, for the objectors to meet 

with the reviewing officer and the responsible official, with the goal of resolving the concerns 

expressed in their objection.

The responsible official cannot sign the final decision until the reviewing officer has responded 

in writing to all pending objections, and the decision must be consistent with any instructions 

issued by the reviewing officer. The final decision is the final administrative decision by the 

agency.

Objection Resolution

Ten objections were received. In conjunction with the Deputy Regional Forester, a resolution 

meeting was conducted on December 18, 2014. There was no resolution or remedy outlined 

during or after this meeting. The reviewing officer responded to all objectors’ concerns and sent 

a final response on January 16, 2015. No further review from any other Forest Service or USDA 

official of the reviewing officer’s written response to the objections is available (36 CFR 

218.11(b)(2)). 

In a letter to the objectors, the reviewing officer outlined a clarification that needed to be made 

before I signed this decision. This clarification was to attach to this decision Inventoried 

Roadless Area maps that were similar to the ones in the project record, outlining where each 

Inventoried Roadless Area was in relation to the proposed action.

I have attached three maps showing the Woahink (5,060 acres) and Tenmile (7,798 acres) 

Inventoried Roadless Areas in relation to Modified Alternative 4 – the selected alternative, 

completing the reviewing officer’s clarification instructions.

Even though the reviewing officer had only one clarification, I recognize the other concerns 

brought up by the objectors and would like to discuss some of these concerns in detail below.

Several of the objections mentioned the requirement for an Advisory Committee called for by the 

1972 Act designating the Oregon Dunes Recreation Area. That Advisory Committee was 

appointed in 1972, served for five years, and was disbanded in 1977 by Forest Service Chief

John McGuire in accordance with the 1976 Federal Advisory Committee Act. Public 

participation in management of the ODNRA, however, has been continuous since designation. 

Counties, riders, environmental groups, and local residents participated extensively in 

development of the 1979 Dunes Plan, in revision of the Dunes Plan in 1994, and in subsequent 

24
decisions around alcohol and sand camping (indeed, those ODNRA decisions were made in 

conjunction with affected counties so that similar rules applied across multiple ownerships).

As the Siuslaw National Forest prepared for route designation in Management Area 10 (C), the 

agency utilized an independent contractor to assemble and facilitate a working group with a wide 

variety of interests to discuss challenges and opportunities associated with OHV use in that 

portion of the Oregon Dunes NRA zoned for riding on designated routes. The working group 

held public meetings and field trips throughout the Dunes, and in 2010 provided a report 

including a range of different ideas and recommendations regarding trails and riding areas, 

posted on the Forest website. More recently, Save The Riders Dunes and WildEarth Guardians 

have begun exploration of a collaborative bringing riders and environmentalists together to 

support dunes restoration.

The Siuslaw National Forest is committed to an open, continuous and collaborative relationship 

with all parties to manage the ODNRA. The Siuslaw piloted Stewardship collaboration 

beginning in 1999. There are now four stewardship collaborative groups encompassing about 97 

percent of the forest. Retained receipts from stewardship groups have been invested on the 

Oregon Dunes NRA for snowy plover enhancement and invasive species removal. I believe that 

this collaborative relationship and the Siuslaw’s continued commitment to collaboration and 

communication will fulfill much of the intent behind the original advisory committee without the 

formal process requirements of the Federal Advisory Committee Act.

• Within Chapter 3, Environmental Consequences, Recreation Section, the FEIS discusses 

cumulative effects on three components; 1) Understandable and Comprehensive Designated 

Route System; 2) Trail Riding Experience; and 3) Sand Camp Access. The cumulative 

effects analysis for recreation is bounded by the Oregon Dunes National Recreation Area as a 

whole. This boundary reflects the fact that recreation use routinely crosses in and out of the 

various ODNRA management areas, and changes affecting recreation use in Management 

Area 10 (C) can affect recreation use on the Dunes more generally. Effects from past and 

present actions, including the Dunes Plan, the alcohol ban, designation of sand camping, 

development of Riley Ranch access and dune restoration at Bull Run, are reflected in the 

existing condition and described in detail in the FEIS. There are no other reasonably 

foreseeable future actions within the Dunes with cumulative impacts on recreation use. 

Potential future actions may include additional dunes restoration treatments. Currently, 

invasive vegetation is changing the nature of this dynamic dune system to a more static 

system by hindering sand movement. If additional actions are proposed to restore sand 

movement, both OHV use and natural ecosystems would benefit. However, because we have 

yet to identify specific proposals, additional cumulative effects analysis would be both 

speculative and premature. Cumulative effects of past and present actions are fully disclosed 

in the FEIS. There are no reasonably future actions that overlap in time or space and would 

contribute to cumulative effects on recreation.

• Within Chapter 3, Environmental Consequences, Visual Resources, the FEIS discusses the 

direct and indirect effects of the project. The cumulative effects analysis for visual resources 

is bounded by the ODNRA as a whole, as any visual impacts could affect the immediate 

views from anywhere in the ODNRA. Effects from past actions are reflected in the existing 

condition. There are no present actions or reasonably foreseeable future actions affecting

visual resources within the ODNRA. Therefore, there are no cumulative effects because 

there are no past, present, or reasonably future actions that overlap in time or space.

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• Within Chapter 3, Environmental Consequences, Law Enforcement, Environmental 

Consequences, the FEIS discusses the direct and indirect effects of the project. The 

cumulative effects analysis for law enforcement is bounded by the Siuslaw National Forest as 

a whole, since law enforcement officers assigned to the Siuslaw and partner organizations 

must split their time among enforcement priorities on the Dunes and elsewhere on the 

Siuslaw National Forest. Effects from past actions are reflected in the existing condition. 

Effects of present actions in route designation are fully described in the FEIS. There are no 

reasonably foreseeable future actions within the ODNRA affecting law enforcement. 

Therefore, there are no cumulative effects because there are no past, present, or reasonably 

future actions that overlap in time or space.

• Within Chapter 3, Environmental Consequences, Botany Section, the FEIS discusses 

cumulative effects on two components; 1) Native Vegetation; and 2) Invasive Plants. This 

discussion primarily covers the existing condition and the direct and indirect effects of the 

project. The cumulative effects analysis for each species is associated with its specific 

habitat and range, as described in the FEIS. Effects from past actions are reflected in the 

existing condition. Effects of present route designation actions are fully described in the 

FEIS. There are no reasonably foreseeable future actions affecting native vegetation and 

invasive plants in the ODNRA. Potential foreseeable future actions may include additional 

dunes restoration treatments. Currently, invasive vegetation is changing the nature of this 

dynamic dune system to a more static system by hindering sand movement. If additional 

actions are proposed to restore sand movement, native plants would benefit. However, 

because we have yet to identify specific proposals, the exact cumulative effects cannot be 

calculated. Therefore, there are no cumulative effects because there are no past, present, or 

reasonably future actions that overlap in time or space.

• Chapter 3, Environmental Consequences, Wildlife Section, discusses cumulative effects on 6 

components; 1) Federally-listed species; 2) Sensitive Species; 3) Other Rare or Uncommon 

Species (Strategic Species); 4) Survey and Manage; 5) Management Indicator Species and 6) 

landbirds. The effects analysis revealed no measureable direct or indirect effect to these 

components; therefore there are no cumulative effects.

• Chapter 3, Environmental Consequences, Economics and Heritage Sections effects analyses 

found no measureable direct or indirect effects; therefore there are no cumulative effects.

I believe this is the right course of action in order to continue our collaborative efforts on the 

Oregon Dunes NRA. I assessed these changes and find them to be within the range of 

environmental effects analyzed in the final EIS. 

10. Implementation

Implementation may begin after the Record of Decision is signed.

11. Contact Information

For additional information on the FEIS and ROD, please contact Angie Morris, Interdisciplinary 

Team Leader, Central Coast Ranger District-Oregon Dunes National Recreation Area, P.O. Box 

400, Waldport, Oregon 97394; Telephone (541)-563-8464.

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The FEIS, ROD, and supporting documents are available for inspection during regular business 

hours (Monday through Friday, 7:45 A.M. to 4:30 P.M) at the Central Coast Ranger DistrictOregon Dunes National Recreation Area offices in Reedsport and Waldport along with the 

Siuslaw National Forest Headquarter in Corvallis. The FEIS and ROD are also posted on the 

Siuslaw National Forest website at:

http://www.fs.fed.us/nepa/fs-usda-pop.php/?project=34220

Signature and Date

I have been delegated the authority and I am the Responsible Official for the decisions outlined 

in this ROD. Note that in many cases this ROD summarized information described more 

completely in the accompanying FEIS. For more detailed information, please refer to the FEIS 

and its associated project administrative record.

Jeremiah C. Ingersoll 1 – 29- 2015

JEREMIAH C. INGERSOLL Date

Forest Supervisor

Siuslaw National Forest

Attachment 1: Inventoried Roadless Area Maps and Modified Alternative 4

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