Chapter 6. Public Comments and 

Responses 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

Payette National Forest Travel Plan FEIS 6 - 1 

CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

This chapter reproduces timely comment letters received on the DEIS from Tribal, federal, state, 

and local agencies and officials as provided in the Forest Service NEPA Handbook 1909.15. 

Additional letters received late along with responses are contained in the project record. 

It also categorizes timely substantive public comments received on the DEIS, followed by the 

Forest Service’s agency response to each substantive comment, as provided by 40 CFR 1503.4. 
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6.1 Comments from Federal, Tribal, State, and Local Officials 

Comment #409, Idaho Department of Parks & Recreation 

Comment #416, Idaho Department of Fish & Game 

Comment #417, Nez Perce Tribal Executive Committee 

Comment #439, United States Environmental Protection Agency 
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6.2 Travel Management Plan DEIS – Public Comment and 

Response Summary 

Index of Comments and Responses 

Comment Period ............................................................................................................. 55

1. The Forest Service should extend the comment period to allow the public enough time to 

review the large amount of information presented in the Draft EIS......................................... 55

2. The Forest Service should consider that if the Selected Alternative is a mix of the 

alternatives presented in the DEIS, the public will not have had an opportunity to comment on 

this “blended” alternative. ....................................................................................................... 55

Comment Analysis .......................................................................................................... 55

3. The Forest Service should consider that the public comment process and analysis is often 

not understandable to the public............................................................................................... 55

Agency Organization, Funding & Staffing................................................................... 55

4. The Forest Service should reduce administrative costs to allow more funding for trail 

maintenance to reach the ground.............................................................................................. 55

Collaboration & Partnerships ....................................................................................... 55

5. The Forest Service may have improperly worked with State and local governments as 

cooperators in the travel planning process............................................................................... 55

Analysis - General........................................................................................................... 56

6. The Forest Service should complete the analysis of travel management with a minimum of 

paperwork. ................................................................................................................................ 56

7. The Forest Service should ensure that Recreation Objective REOB18 from the Forest Plan 

is followed. ................................................................................................................................ 56

8. The Forest Service should consider all resources when analyzing travel management....... 56

9. The Forest Service should only consider implementation of road closures/restrictions during 

travel planning, not during District-level NEPA planning. ...................................................... 56

10. The Forest Service should clarify the definition of closed so that it does not appear that 

areas, trails, or roads are closed to foot traffic as well............................................................ 56

11. The Forest Service should consider that combining both winter and summer recreation 

into three somewhat “polarized” alternatives makes it difficult for people to comment in a 

multi-use fashion....................................................................................................................... 56

12. The Forest Service should consider in the analysis the differences between the east and 

west zone of the forest. .............................................................................................................. 57

13. The Forest Service should indicate that many of the proposed ATV trails are in fact closed 

roads being converted to trails. ................................................................................................ 57

14. The Forest Service should consider access for the elderly and disabled as a significant 

issue........................................................................................................................................... 57

15. The Forest Service should separate winter closures proposed for wildlife protection from 

those proposed for non-motorized winter recreation................................................................ 57

16. The Forest Service failed to analyze an adequate range of alternatives for snowmobiling.

.................................................................................................................................................. 57
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17. The Forest Service should support the conclusions found in the document with research 

and indicate how applicable federal rules and regulations are being followed in each 

alternative. ................................................................................................................................ 58

18. The Forest Service failed to analyze an alternative that truly addresses the need to increase 

motorized opportunities. ........................................................................................................... 58

19. The Forest Service should analyze an alternative that meets the direction found in the 

NFMA for renewable and sustainable resources including motorized recreation. .................. 58

20. The Forest Service should display the amount of non-motorized and motorized 

opportunities available in an unbiased way. Non-motorized users in fact have the use of the 

entire Forest, including the Wilderness. ................................................................................... 58

21. The Forest Service should consider the environmental effects of past restriction of 

motorized use when proposing to close more motorized trails or areas. ................................. 58

22. The Forest Service should consider that the analysis presented in the DEIS appears to be 

biased against motorized use and users.................................................................................... 58

23. The Forest Service should analyze the semi-primitive experience in winter to assess the 

incompatibility of motorized and non-motorized winter sports. ............................................... 59

24. The Forest Service should do an analysis of the capabilities of the Forest to sufficiently 

monitor, enforce, and carry out public education in support of the new travel plan................ 59

25. The Forest Service should clarify the following: Page 3-17, MA 6. Goose Creek/Hazard 

Creek – Winter. first paragraph.. Since both ski areas are under Special Use Permit, as is the 

case for the Brundage Snow Cat operation, all three should be listed. (398:50200)............... 59

26. Attention needs to be given to the rounding off of figures all the way through the DEIS... 59

27. The Forest Service should clearly identify the reasons for, and opportunities created by, 

identifying areas as suitable for motorized or non-motorized use in winter. ........................... 59

28. The Forest Service should clearly explain how the analysis presented in the DEIS complies 

with sections 101 and 102(1) of the National Environmental Policy Act (NEPA) and other 

environmental laws. .................................................................................................................. 59

29. The Forest Service should ensure that the alternatives presented in the DEIS follow the 

direction found in Executive Order 11989................................................................................ 60

30. The Forest Service should clearly indicate that the travel plan decision will not be the only 

decision affecting road and trail closures. Rather NEPA analyses and decisions will continue 

on the Forest and more roads and trails may be closed to mitigate those actions................... 60

31. The Forest Service DEIS lacks sufficient site specific analysis. ......................................... 60

32. The Forest Service improperly used the travel plan to adjust ROS inventories. ................ 60

33. The Forest Service should develop a Winter Recreation Plan............................................ 61

34. The Forest Service should have separated winter and summer recreation in the DEIS..... 61

Purpose and Need ........................................................................................................... 61

35. The Forest Service’s stated purpose and need included wildlife, vegetation, soils, and 

watershed management, but the analysis focuses on recreation. ............................................. 61

36. The Forest Service should make sure the analysis supports the stated purpose and need for 

the project. ................................................................................................................................ 61

37. The Forest Service should display ALL pertinent Forest Plan direction............................ 61

Issues ................................................................................................................................ 61

38. The Forest Service should consider the importance of travel management to the 

snowmobiling community.......................................................................................................... 61
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39. The Forest Service should identify all existing resource problems affected by travel 

management. ............................................................................................................................. 62

40. The Forest Service should complete a road analysis to assess the effects of road 

management to all resources. ................................................................................................... 62

41. The Forest Service should consider an alternative that opens roads to non-motorized use 

only during the winter............................................................................................................... 62

42. The Forest Service should not consider allowing more motorized use in existing IRA’s... 62

43. The Forest Service should have good rationale for constructing any new roads or trails. 62

44. The Forest Service should consider an alternative that analyzes complete closure to oversnow travel................................................................................................................................ 63

45. The Forest Service should analyze an alternative that designates some areas open to motor 

vehicle use................................................................................................................................. 63

46. The Forest Service should analyze an alternative that opens all unauthorized roads and 

trails. ......................................................................................................................................... 63

47. The Forest Service should consider the resource effects of non-motorized winter 

recreation.................................................................................................................................. 63

48. The Forest Service should collaborate with local recreation groups to improve the 

alternatives................................................................................................................................ 63

49. The Forest Service did not adequately factor in the nationwide trend of increasing 

motorized use. ........................................................................................................................... 63

50. The Forest Service should consider the carrying capacity of the forest for various modes of 

recreation.................................................................................................................................. 64

51. The Forest Service should consider using old logging roads and roads planned for 

decommissioning as trails......................................................................................................... 64

52. The Forest Service should analyze the environmental effects of increasing snowmobile use, 

such as has occurred in the last decade. Effects to air quality, water quality, noise pollution, 

and wildlife should all be considered. ...................................................................................... 64

53. The Forest Service should consider that the project design features which address noxious 

weeds in the DEIS are insufficient to reduce the spread of these weeds to a non-significant 

issue when considered at the forest level. ................................................................................. 64

54. The Forest Service should analyze the effects of snowmobile exhaust on air quality as a 

significant issue......................................................................................................................... 64

55. The Forest Service needs to review the factors used when determining non-significance of 

issues to make sure they comply with the NEPA....................................................................... 64

Definitions........................................................................................................................ 65

56. The Forest Service should clarify the definition of “cross country motor vehicle use” 

particularly in designated corridors. ........................................................................................ 65

57. The Forest Service should fully define what is meant by “closure” in the FEIS, including 

the types of management that would be authorized to close routes.......................................... 65

58. The Forest Service has used the term “unauthorized” incorrectly in the DEIS................. 65

59. The Forest Service has incorrectly described the proposed winter closure at Granite 

Mountain in the DEIS which should be described as “snowmobile free” rather than nonmotorized due to the permitted snow cat operation in the area................................................ 65

Monitoring....................................................................................................................... 65
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60. The Forest Service should monitor all travel-way closures to assure that they are achieving 

the travel management objectives for which they are closed.................................................... 65

61. The Forest Service should consider more effective methods of road closure/barriers 

because current methods such as gates and berms seem to often be ineffective....................... 65

62. The Forest Service should commit to implementation and effectiveness monitoring for 

travel management.................................................................................................................... 66

Project Design Features.................................................................................................. 66

63. The Forest Service should include project design features to ensure recognition of 

environmental concerns that may arise as a result of travel route and area designation........ 66

64. The Forest Service should evaluate the description of Project Design Features to ensure 

they are feasible. ....................................................................................................................... 66

Maps & Data Display...................................................................................................... 66

65. The Forest Service should improve the presentation of the proposals and maps in the FEIS.

.................................................................................................................................................. 66

66. The Forest Service should improve the winter maps so they better display the areas closed 

to motorized over-snow use....................................................................................................... 66

67. The Forest Service should better describe the winter closures in the FEIS........................ 66

68. The Forest should change the way the alternatives are displayed in the Comparison of 

Alternatives tables..................................................................................................................... 66

69. The Forest Service should identify the Brundage Snow Cat permitted area on the maps in 

the FEIS. ................................................................................................................................... 66

Alternatives...................................................................................................................... 66

70. The Forest Service should choose an alternative that gives a better depiction of current 

recreation use than the No Action Alternative discussed in the DEIS...................................... 66

71. The Forest Service should develop another alternative that does not restrict motorized 

access anywhere except the Wilderness.................................................................................... 67

72. The Forest Service should develop an alternative that increases the opportunity for nonmotorized recreation................................................................................................................. 67

73. The Forest Service should complete a RAP and address more road closures, relocations, 

and obliterations because the current alternatives do not adequately mitigate current impacts 

to forest resources..................................................................................................................... 67

74. The Forest Service should consider an alternative that incorporates the ISSA proposals in 

their entirety, including entering the Secesh and Needles Recommended Wilderness areas. .. 67

75. The Forest Service should consider an alternative that addresses the loss of unauthorized 

roads. ........................................................................................................................................ 67

76. The Forest Service should develop an alternative that is more responsive to the increasing 

demand for motorized recreation opportunities. ...................................................................... 67

77. The Forest Service should develop an alternative that is more responsive to the increasing 

demand for both motorized and non-motorized recreation opportunities. ............................... 68

78. The Forest Service should develop an alternative that does not allow degradation of any 

natural resources over time. ..................................................................................................... 68

Cumulative Effects.......................................................................................................... 68

79. The Forest Service should consider the cumulative effects of the loss of OHV trail 

nationwide................................................................................................................................. 68

Fisheries ........................................................................................................................... 68
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80. The Forest Service should re-evaluate the use of number of stream crossings as a proxy for 

potential for fuel spills because fuel spills occur relatively rarely at stream crossings or 

otherwise................................................................................................................................... 68

81. The Forest Service should consider that if there are problems occurring with pollution or 

sediment at stream crossings on roads and trails, this is the fault of the design or maintenance 

of the facility, and not of the public who is using the facility.................................................... 68

82. The Forest Service should consider that there is no research to back up claims that OHV 

use and trails have any effect on fisheries populations............................................................. 68

Soil & Water.................................................................................................................... 68

83. The Forest Service should consider that while roads can affect the recruitment of large 

woody debris to streams, trails do not. ..................................................................................... 68

84. The Forest Service should consider erosion and sediment from the existing road and 

motorized trail network............................................................................................................. 69

85. The Forest Service should consider the soil and water resource damage caused by 

motorized cross-country travel. ................................................................................................ 69

86. The Forest Service should identify and mitigate environmental concerns associated with 

new road or trail construction. ................................................................................................. 69

87. The Forest Service should consider obliterating unauthorized road and relocating roads 

outside Riparian Conservation Areas (RCAs). ......................................................................... 69

88. The Forest Service should fully describe the methods used in road closures..................... 69

89. The Forest Service should consider the effects of differing snow melt patterns caused by 

snowmobile use on soil moisture levels; and. ........................................................................... 69

90. The Forest Service should consider the impacts of all uses, motorized and non-motorized, 

on sediment/erosion from trails. ............................................................................................... 70

91. The Forest Service should consider that erosion and sediment from trails that receive 

equestrian use is at least as great as that from motorized use.................................................. 70

92. The Forest Service should consider effects of snowmobile emissions, including crosscountry snowmobile use, on water quality................................................................................ 70

93. The Forest Service should not limit the extent of snowmobile use because of potential 

impacts to the soil resource. ..................................................................................................... 70

94. The Forest Service should consider that the sediment produced from disturbance on an 

OHV trail is considerably less than that produced from an open road. ................................... 71

95. The Forest Service should consider that the conclusions concerning the effects of vehicle 

use on soils and vegetation seem to be based on assumptions rather than research or local 

data. .......................................................................................................................................... 71

96. The Forest Service should clarify the data presentation in the Soil & Water section of the 

EIS............................................................................................................................................. 71

97. The Forest Service should discuss the effects of the alternatives on the drinking water 

supplies in Management Area 3................................................................................................ 71

Wildlife............................................................................................................................. 71

98. The Forest Service should analyze lynx management using the most recent information and 

amend the Forest Plan to reflect this direction......................................................................... 71

99. The Forest Service should consider the health and safety aspects of leaving snags when 

roads and trails are constructed or reconstructed.................................................................... 71
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100. The Forest Service should consider the effects of increasing snowmobile activity on 

wildlife....................................................................................................................................... 72

101. The Forest Service should consider that human recreation has little effect on wildlife. .. 72

102. The Forest Service should consider the likelihood that potential lynx habitat surrounding 

McCall is not occupied. ............................................................................................................ 72

103. The Forest Service should re-evaluate the suitability of areas identified as lynx habitat 

using more up-to-date information; and:.................................................................................. 72

104. The Forest Service should re-evaluate the potential effects of snowmobiling on lynx using 

the most up-to-date research; and:........................................................................................... 72

105. The Forest Service should amend the Forest Plan direction for lynx because no lynx are 

known to be present on the Forest and the most recent research would lead to different, 

probably smaller, delineations of potential habitat. ................................................................. 72

106. The Forest Service should consider the relative effects of motorized versus non-motorized 

recreation in winter on wildlife................................................................................................. 72

107. The Forest Service failed to adequately analyze the effects of snowmobile use on 

wolverine and lynx habitat........................................................................................................ 72

108. The Forest Service should evaluate in an unbiased manner the effects of motorbike use on 

elk security as compared to the effects of hunting. ................................................................... 72

109. The Forest Service should maintain wildlife migration corridors in all alternatives....... 72

110. The Forest Service should consider that the most recent research is inconclusive 

regarding the effects of human interactions with elk and elk habitat effectiveness.................. 72

111. The Forest Service should consider that it is the management policies of Idaho Fish & 

Game that are contributing to the harassment of big game species, rather than motorized 

traffic......................................................................................................................................... 72

112. The Forest Service should reanalyze the currently closed roads to determine if the new elk 

security guidance in the 2003 Forest Plan would still require these roads to be closed yearround......................................................................................................................................... 72

113. The Forest Service should consider that OHV use during hunting season increases animal 

vulnerability to harvest. ............................................................................................................ 73

114. The Forest Service should consider that OHV use throughout the year reduces the 

effectiveness of big game habitat. ............................................................................................. 73

115. The Forest Service should consider that the areas of wolverine denning habitat being 

protected in Alternative D are not those that should be the highest priority............................ 73

116. The Forest Service should evaluate the closure of additional roads and trails within elk 

summer and winter range to protect the animals from motorized vehicle use, especially during 

hunting season. ......................................................................................................................... 73

117. The Forest Service should limit over-snow motorized use until impacts to wintering 

wildlife habitat can be fully assessed........................................................................................ 73

Firewood .......................................................................................................................... 73

118. The Forest Service should consider that none of the alternatives provides sufficient access 

for firewood collection and that firewood cutting is a significant issue. .................................. 73

119. The Forest Service should consider that much of the forest has burned in the last 30 years 

and should be opened for fuelwood cutting. ............................................................................. 73

Noxious Weeds ................................................................................................................ 73
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120. The Forest Service should consider that motorized traffic on the forest contributes to the 

spread of noxious weeds. .......................................................................................................... 73

Trails - General ............................................................................................................... 74

121. The Forest Service should consider providing more opportunities for OHV trail riders 

because use is increasing.......................................................................................................... 74

122. Because motorized use is increasing the Forest Service should provide more motorized 

trails laid out in systems such as those recommended by the Blue Ribbon Coalition. ............. 74

123. The Forest Service should keep all motorized trails open because they provide such a 

variety of opportunities for all users motorized and non-motorized......................................... 74

124. The Forest Service should consider that with the closure of all off-road travel and the 

reduction in available motorized trails, adverse impacts and user conflicts are likely to occur 

due to overuse on the remaining motorized trails..................................................................... 74

125. The Forest Service should consider that restricting trail use to non-motorized due to lack 

of maintenance, or on those that receive little use or are considered “expert” is not valid. 

These trails have value to the public that uses them................................................................. 74

126. The Forest Service should open all trails outside the Wilderness to motorized use. ........ 74

127. The Forest Service should evaluate all 2-wheel trails to determine whether or not they 

can accommodate ATV traffic................................................................................................... 75

Trail Closure/Restriction................................................................................................ 75

128. The Forest Service should consider rerouting or improving maintenance on trails where 

there are water quality issues, rather than restriction to non-motorized use only. .................. 75

129. The Forest Service should not close motorized trails to gain non-motorized mileage, 

instead they should construct new non-motorized trails and keep all existing motorized trails.

.................................................................................................................................................. 75

130. The Forest Service should consider that the needed skill level limits the use on “expert” 

OHV trails................................................................................................................................. 75

131. The Forest Service should consider that expert level trails are scarce and there is a 

growing population of experienced OHV users out there that desire that experience. ............ 75

Single Track Motorized Trails....................................................................................... 75

132. The Forest Service should provide more, not less, single track motorized trails. ............ 75

133. The Forest Service should consider that the need for single track trail for mountain bike 

use is not being addressed on the Payette National Forest. ..................................................... 76

134. The Forest Service should consider that single-track trails often end up being used by 

ATV users as well...................................................................................................................... 76

Loop Trails ...................................................................................................................... 76

135. The Forest Service should provide more loop trail opportunities. ................................... 76

Groomed Snowmobile Trails ......................................................................................... 76

136. The Forest Service should use the most current lynx studies to assess the management of 

groomed snowmobile trails....................................................................................................... 76

137. The Forest Service should not decrease the amount of groomed snowmobile trail because 

use is increasing........................................................................................................................ 76

138. The Forest Service should add new “link” trails to the existing system........................... 77

139. The Forest Service should consider eliminating the Snowmobile Overlook because it 

leads to intrusion violations on the Brundage Ski Area permitted area. .................................. 77
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Closed Roads ................................................................................................................... 77

140. The Forest Service should provide turn-arounds at gates and barriers on closed roads. 77

141. The Forest Service should consider that by restricting access many families and seniors 

will no longer be able to participate in activities which they have historically enjoyed. ......... 77

142. The Forest Service should not close any more roads than those that are already closed. 77

Unauthorized Roads ....................................................................................................... 77

143. The Forest Service should consider an alternative that addresses the loss of unauthorized 

roads in currently open areas. .................................................................................................. 77

144. The Forest Service should not designate any unauthorized routes open because it rewards 

the illegal construction of these routes. .................................................................................... 78

145. The Forest Service should recognize that most summer motorized users would only use 

the existing (unauthorized) road beds and would not drive “off-road” and not penalize them 

because of the few users who do cause resource damage off-trail. .......................................... 78

146. The Forest Service should realize that creation and use of “unauthorized” routes is an 

indication of unmet demand for motorized recreation opportunities. ...................................... 78

Road & Trail Decommissioning .................................................................................... 78

147. The Forest Service should decommission roads or trails for every new mile of road or 

trail created............................................................................................................................... 78

Jurisdiction ...................................................................................................................... 78

148. The Forest Service should indicate roads that fall under other jurisdiction clearly on the 

maps so people can easily recognize them................................................................................ 78

149. The Forest Service should maintain public access on roads managed under cost share 

agreements. ............................................................................................................................... 79

Maintenance .................................................................................................................... 79

150. The Forest Service has not adequately considered the impacts from a lack of maintenance 

on the existing road network..................................................................................................... 79

151. The Forest Service should consider that trail maintenance has not been adequately 

funded for the past two decades, even with the existing system of trails. ................................. 79

152. The Forest Service should consider that lack of trail maintenance is a poor excuse for 

reducing the number of trails or limiting access. ..................................................................... 79

153. The Forest Service should consider that reducing the number of trails available for 

motorized use may also reduce the amount of trail maintenance funds available through 

partnerships with the IDPR and other grant and volunteer efforts. ......................................... 79

154. The Forest Service should consider that faulty design and maintenance of roads and trails 

are not the fault of the public but of the managing agency....................................................... 80

RS 2477 ............................................................................................................................ 80

155. The Forest Service should evaluate roads that it has closed since 1976 for potential RS 

2477 rights. ............................................................................................................................... 80

156. The Forest Service has not correctly addressed RS 2477 in the DEIS. The PNF lacks the 

authority to close roads or determine jurisdiction on roads..................................................... 80

Administrative Use.......................................................................................................... 81

157. The Forest Service should not use roads closed to the public under the guise of 

“administrative use”................................................................................................................. 81

Collaboration/Partnerships............................................................................................ 81
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158. The Forest Service should make better use of grants and partnerships to fund 

maintenance of trails and to keep trails open. .......................................................................... 81

159. The Forest Service should consider using volunteers and grants to help maintain trails, so 

that more trails may be kept open............................................................................................. 81

160. The Forest Service should consider using RPT grant monies and the Park N’Ski program 

to create more parking areas for winter recreation users. ....................................................... 81

161. The Forest Service should make better use of grants and partnerships to fund the 

snowmobile management program. .......................................................................................... 81

Motorized Recreation – General Comments................................................................ 81

162. The Forest Service should clearly define when there is sufficient snow for over-snow 

motorized travel to be allowed.................................................................................................. 81

163. The Forest Service should keep motorized and non-motorized users separate so that nonmotorized users can enjoy nature. ............................................................................................ 81

164. The Forest Service should not close any areas to motorized recreation. ......................... 81

165. The Forest Service should consider that motorized use on the Forest has affected all 

Tribal treaty resources.............................................................................................................. 81

166. The Forest Service should remove all motorized use from the National Forest because of 

the negative resource effects..................................................................................................... 82

167. The Forest Service should consider the impacts of non-motorized recreation as well as 

those of motorized recreation. .................................................................................................. 82

168. The Forest Service should consider that people have been using motorized trails and 

roads for a long time and the trails and country they access have great value to them. .......... 82

169. The Forest Service should use public education to prevent resource damage by motorized 

trail users. ................................................................................................................................. 82

170. The Forest Service should provide as many motorized opportunities as possible because 

so many people, including the very young, the elderly, the disabled, and veterans, value them.

.................................................................................................................................................. 82

171. The Forest Service should completely overhaul the legislation and direction that have led 

to the current management course............................................................................................ 83

172. The Forest Service should provide OHV recreation opportunities................................... 83

173. The Forest Service should consider that resource damage caused by OHV use usually 

only occurs in isolated areas. ................................................................................................... 83

174. The Forest Service should consider that it is easier for snowmobiles to travel a distance 

from trailheads/parking than for non-motorized users who need opportunities within a close 

distance from access points....................................................................................................... 83

Non-motorized Recreation – General Comments........................................................ 83

175. The Forest Service should consider the value of non-motorized recreation opportunities 

to society and the environment.................................................................................................. 83

176. The Forest Service should provide a balance between motorized and non-motorized 

recreation opportunities............................................................................................................ 83

177. The Forest Service should consider that motorized and non-motorized recreation is often 

incompatible.............................................................................................................................. 84

178. The Forest Service should consider that non-motorized trails tend to be under-utilized. 84

Access - General .............................................................................................................. 84
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6 – 50 Payette National Forest Travel Plan FEIS 

179. The Forest Service should consider that public access is an important resource for future 

generations................................................................................................................................ 84

180. The Forest Service should consider that a large portion of the population must use 

motorized vehicles to access the forest because of physical limitations. .................................. 84

181. The Forest Service should consider that providing a broad spectrum of recreation 

opportunities is good for the local economy............................................................................. 84

182. The Forest Service should consider that providing a broad spectrum of recreation 

opportunities disperses use and increases safety...................................................................... 84

183. The Forest Service should continue to allow access using the 1994/1995 travel map which 

the public is used to and finds to be adequate. ......................................................................... 85

184. The Forest Service should not limit access to any type of recreation............................... 85

185. The Forest Service should consider that there is a difference between the remote 

backcountry, which may still be accessed by road, and Wilderness which is entirely nonmotorized................................................................................................................................... 85

Separate Use .................................................................................................................... 85

186. The Forest Service should consider that non-motorized recreation provides the most 

resource protection and therefore motorized access should be limited.................................... 85

187. The Forest Service should provide more non-motorized areas within easy access distance 

from major roads and parking areas. ....................................................................................... 85

188. The Forest Service should continue to provide a winter non-motorized area in Bear Basin 

for use by Nordic skiers. ........................................................................................................... 85

189. The Forest Service should consider that separate use areas provide a number of benefits 

including a safer recreation experience and more protection of natural resources................. 85

190. The Forest Service should consider that motorized and non-motorized use is not 

compatible because the noise and air pollution from motorized vehicles is not amenable to 

non-motorized recreationists. ................................................................................................... 86

191. The Forest Service should consider that there is currently not enough area designated for 

non-motorized recreation on the Payette.................................................................................. 86

192. The Forest Service should consider the many people that utilize the areas available for 

snowmobiling on the Payette NF. ............................................................................................. 86

193. The Forest Service should consider that definable boundaries and separate use areas 

provide the best experience for the non-motorized recreationist in winter. ............................. 86

194. The Forest Service should consider that there are not as many non-motorized 

recreationists as motorized and that there are already several areas set aside for nonmotorized use, both summer and winter. .................................................................................. 86

195. The Forest Service should consider a seasonal closure in the area utilized by the 

Brundage Snow Cat special use permit. ................................................................................... 87

196. The Forest Service should consider that excluding snowmobiles from portions of the 

Brundage Mountain Snow Cat skiing permitted area is essential for the business to survive.. 87

197. ...(Continue 196) .For the safety of the program’s patrons.............................................. 87

198. The Forest Service should consider that snowmobiles have a much larger range than 

human-powered recreationists and can quickly travel by any non-motorized areas................ 87

199. The Forest Service should evaluate whether or not the non-motorized areas created 

would be large enough and distant enough from areas of motorized use to provide quiet and a 

feeling of solitude...................................................................................................................... 87
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

Payette National Forest Travel Plan FEIS 6 - 51 

200. The Forest Service should create exclusive use areas for snowmobilers as well if they are 

going to do so for non-motorized use........................................................................................ 87

Shared Use ....................................................................................................................... 87

201. The Forest Service should consider that additional access is needed for ATV riders...... 87

202. The Forest Service should consider that shared use areas and routes are not enjoyable or 

safe for non-motorized recreationists. ...................................................................................... 88

203. ...(Cont.202) Because snowmobiles are able to access areas they couldn’t in the past, and 

they can track up an area in minutes. ....................................................................................... 88

204. The Forest Service should consider that Nordic skiers and snowmobiles cannot safely 

share the same trails. ................................................................................................................ 88

205. The Forest Service should consider that creating separate use areas for non-motorized 

recreation is a form of discrimination. ..................................................................................... 88

206. The Forest Service should consider that the areas open to snowmobiling currently are 

crowded and that reducing the area open will increase the problems caused by crowding. ... 88

207. The Forest Service should consider that non-motorized recreationists typically only use 

areas within 4 miles of a parking lot or road, so only areas that meet these criteria should be 

set aside for exclusive non-motorized use................................................................................. 88

208. The Forest Service should consider that motorized and non-motorized use conflict in 

winter is very real and not just a perception............................................................................. 88

Restricted Off-road Motor Vehicle Use ........................................................................ 88

209. The Forest Service should consider that ATVs on existing unauthorized routes and on skid 

trails are the only means of forest access that some can physically use................................... 88

210. The Forest Service should consider that OHV use should be kept to open roads and 

motorized trails. ........................................................................................................................ 89

211. (Cont. 210) Because it causes resource damage. ............................................................. 89

212. (Cont. 210) Because it protects big game vulnerability and reduces hunter conflicts. .... 89

213. The Forest Service should consider that problems caused by off-road vehicle use are an 

enforcement problem and not all users should be punished for the few that abuse the privilege.

.................................................................................................................................................. 89

Corridors ......................................................................................................................... 89

214. The Forest Service should consider the creation of some open corridors on the Krassel 

Ranger District, as has been done on the rest of the Forest, because I see no valid reason for 

closing the entire District.......................................................................................................... 89

215. The Forest Service should consider that 300 foot corridors will not provide adequate 

opportunities for dispersed camping......................................................................................... 89

216. The Forest Service should create designated dispersed camping sites rather than creating 

corridors for dispersed camping along motorized routes......................................................... 89

Multiple Use..................................................................................................................... 90

217. The Forest Service should consider that the National Forest belongs to the people and not 

to the agency and therefore should be completely accessible by the public in the manner of 

their choosing; and:.................................................................................................................. 90

218. The Forest Service should consider that all of the Forest should be open for multiple 

uses; and:.................................................................................................................................. 90

219. The Forest Service should consider that the Forest is for the people............................... 90

Maps, Signs...................................................................................................................... 90
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

6 – 52 Payette National Forest Travel Plan FEIS 

220. The Forest Service should consider that there may not be adequate funds to sign all 

designated routes which will cause confusion for the public.................................................... 90

221. The Forest Service should consider that signing open routes only could be very confusing 

to the public............................................................................................................................... 90

222. The Forest Service should consider other methods besides signing or gates to indicate 

that routes are closed................................................................................................................ 90

223. The Forest Service should display the permitted boundary for the Brundage Snow Cat 

Program Special Use Permit. ................................................................................................... 90

224. The Forest Service should consider that the “closed to motorized use unless posted open” 

policy is both agency and public friendly. ................................................................................ 90

225. The Forest Service should realize that having the MVUM map as the main public 

education tool and enforcement mechanism is not very user friendly. ..................................... 91

226. The Forest Service should consider that better winter recreation maps showing 

topographical features are needed for the FEIS....................................................................... 91

Game Retrieval................................................................................................................ 91

227. The Forest Service should consider that the rules governing game retrieval are not clear 

in the DEIS................................................................................................................................ 91

228. The Forest Service should consider that some people are physically unable to retrieve 

game except by motorized means.............................................................................................. 91

229. The Forest Service should not allow an exception for travel off-designated routes for 

game retrieval. .......................................................................................................................... 91

Equestrian Use ................................................................................................................ 91

230. The Forest Service should consider that it is unclear if access to established trailheads 

for horse trailers has been maintained. .................................................................................... 91

User Education................................................................................................................ 91

231. The Forest Service should be proactive in user education for the new travel management 

plan to be effective. ................................................................................................................... 91

Enforcement .................................................................................................................... 91

232. The Forest Service should consider that the Selected Alternative will have to be enforced 

for it to be effective. .................................................................................................................. 91

233. The Forest Service should consider that user groups may be willing to help with selfpolicing and enforcement of the new travel plan...................................................................... 92

234. The Forest Service should consider that most problems with illegal ATV use occur during 

hunting season and could be mitigated by stepping up enforcement at this time. .................... 92

235. The Forest Service should consider that the Department of Fish & Game is authorized to 

help with enforcement during the hunting season..................................................................... 92

Trailheads/Parking ......................................................................................................... 92

236. The Forest Service should analyze parking and trailhead management as a significant 

issue because existing locations are currently at full or over-full levels of use; and:.............. 92

237. The Forest Service should consider that the increase in Forest visitors is leading to 

congestion and overcrowding at parking areas and trailheads, particularly in winter. .......... 92

238. The Forest Service should not analyze a parking facility on Smokey Boulder Road 

because adjacent private property owners are experiencing vandalism and trespass from forest 

visitors in the area already. ...................................................................................................... 92
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

Payette National Forest Travel Plan FEIS 6 - 53 

Special Use Permits......................................................................................................... 92

239. The Forest Service should consider that it is not always understandable to the public that 

exemptions to the travel plan route designations can be made for special use permits and 

administrative use. .................................................................................................................... 92

240. The Forest Service should make it clear that holders of special use permits may be given 

motorized access if needed to carry out the terms of their permit. ........................................... 92

Definable Boundaries ..................................................................................................... 93

241. The Forest Service should consider the CIRC proposal presented during scoping because 

it has the most identifiable and enforceable boundaries. ......................................................... 93

242. The Forest Service should ensure that areas designated for non-motorized use in winter 

have definable boundaries such as ridges. ............................................................................... 93

Budget .............................................................................................................................. 93

243. The Forest Service should not use the agency budget as a rationale for management. ... 93

Wilderness ....................................................................................................................... 93

244. The Forest Service should consider that only a small percentage of the public uses 

wilderness and additional “de facto” wilderness areas that exclude motorized use should not 

be created.................................................................................................................................. 93

245. The Forest Service should consider paving a road through the middle of the Frank 

Church River of No Return Wilderness so that it can be enjoyed by many more people.......... 93

246. The Forest Service should consider that the Frank Church River of No Return Wilderness 

provides ample non-motorized opportunities............................................................................ 93

247. The Forest Service should include the non-motorized trail opportunities available in the 

FCRNRW when displaying the alternatives.............................................................................. 94

248. The Forest Service should only consider the attributes associated with Wilderness 

through ROS designations. ....................................................................................................... 94

Recommended Wilderness ............................................................................................. 94

249. The Forest Service should reconsider the effects of snowmobile use on potential 

designation of recommended wilderness areas......................................................................... 94

250. The Forest Service should consider that any increase in, or the continued allowance of, 

motorized use in Recommended Wilderness areas could have a negative impact on their 

potential for future wilderness designation............................................................................... 94

251. The Forest Service should consider that snowmobile use in recommended wilderness 

areas would not impact their future consideration for wilderness areas because the impacts of 

snowmobiles are not lasting...................................................................................................... 94

252. The Forest Service should consider that only Congress can create Wilderness............... 94

253. The Forest Service should defer any travel management decisions for Recommended 

Wilderness until the State of Idaho’s Roadless Review process is complete. ........................... 95

Economics ........................................................................................................................ 95

254. The Forest Service should complete a more thorough economic analysis using studies 

such as the one funded by ISSA in 2005.................................................................................... 95

255. The Forest Service should consider the socio-economic value of Forest recreation, both 

motorized and non-motorized, on the local community. ........................................................... 95

256. The Forest Service should consider the economic analysis done for the Forest Plan and 

make sure it is consistent with any analysis done for the travel management plan.................. 96
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

6 – 54 Payette National Forest Travel Plan FEIS 

257. The Forest Service should draft a comprehensive plan for commercial recreation use on 

the Forest. ................................................................................................................................. 96

258. The Forest Service should take into account that the backcountry skiing industry has 

grown by 300 percent in the last year....................................................................................... 96

259. The Forest Service should consider that having a variety of recreation opportunities on 

the National Forest is best for the local economy..................................................................... 96

260. The Forest Service should consider that money isn’t everything, and that even recreation 

opportunities that generate little local income have value. ...................................................... 96

Pollution........................................................................................................................... 96

261. The Forest Service should consider the effects of snowmobile pollution on water quality.

.................................................................................................................................................. 96

262. The Forest Service should consider that more snowmobilers are using new technology to 

reduce noise and pollution by their machines........................................................................... 96

Noise ................................................................................................................................. 96

263. The Forest Service should consider that it is currently difficult for non-motorized winter 

recreationists to find an area without snowmobile traffic on the Forest. ................................. 96

264. The Forest Service should not allow more motorized use so that the quiet in the Forest is 

preserved................................................................................................................................... 96

Health & Safety............................................................................................................... 97

265. The Forest Service should consider that snowmobile use in the Brundage SnowCat 

program special use permit area is incompatible because of the potential for unsafe 

conditions.................................................................................................................................. 97

266. The Forest Service should reassess the safety of heavily used trails where motorized and 

non-motorized users mix; and: ................................................................................................. 97

267. The Forest Service should give the issue of safety more discussion in the DEIS; and:.... 97

268. The Forest Service should consider that snowmobiling and skiing do not mix because of 

safety issues............................................................................................................................... 97

Conflict of Uses/User Conflict........................................................................................ 97

269. The Forest Service should consider that the snowmobile community has worked with both 

Brundage Mountain Ski Resort and the Tamarack Resort to reduce the user conflicts occurring 

between their patrons and snowmobilers.................................................................................. 97

270. The Forest Service should consider that back country skiing and snowmobile use are 

usually not compatible. ............................................................................................................. 97

271. The Forest Service should consider that many user groups, including the BackCountry 

Horseman, are willing to work with other recreation user groups to reduce use conflict. ...... 97

272. The Forest Service should consider that decreasing the area available for both motorized 

and non-motorized recreation will increase user conflict; and:............................................... 97

273. The Forest Service should consider that user conflict is relatively isolated: and: ........... 97

274. The Forest Service should consider that conflict between recreational uses has 

incorrectly been identified as a significant issue; and:............................................................ 97

275. The Forest Service should consider that OHV use during hunting season causes conflict 

between hunters. ....................................................................................................................... 97

 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

Payette National Forest Travel Plan FEIS 6 - 55 

Public Involvement 

Comment Period 

1. The Forest Service should extend the 

comment period to allow the public enough 

time to review the large amount of 

information presented in the Draft EIS. 

Agency Response: The Forest Service 

received several requests for an extension on 

the 45-day comment period for the DEIS. The 

Forest granted an additional 45-day extension 

of the comment period to accommodate these 

requests. 

2. The Forest Service should consider that if 

the Selected Alternative is a mix of the 

alternatives presented in the DEIS, the public 

will not have had an opportunity to comment 

on this “blended” alternative. 

Agency Response: The Forest Service is 

providing an additional 30-day comment 

period on the FEIS to allow for public input on 

Alternative E – a new alternative combining 

elements of the other alternatives, responding 

to public comment on the DEIS, and reflecting 

site-specific access needs of the Ranger 

Districts. 

Comment Analysis 

3. The Forest Service should consider that the 

public comment process and analysis is often 

not understandable to the public. 

Agency Response: The Forest acknowledges 

that the agency’s environmental analysis 

process, which is prescribed by law and 

regulation, is complex and not always easy to 

understand. During the process, agency 

personnel have been available to discuss any 

questions the public may have on both the 

process and the technical analysis of the 

project. The Payette has held a number of 

public meetings, which have been good venues 

for the public to ask clarifying questions. 

Forest officials have also responded to 

inquiries by phone, e-mail, and in person. 

In addition, the County commissioners for 

Adams, Valley, and Washington Counties were 

part of the extended Interdisciplinary Team for 

the project. The commissioners were available 

to their local constituents for questions and 

information, and also held public meetings to 

discuss travel management. 

Agency Organization, Funding & 

Staffing 

4. The Forest Service should reduce 

administrative costs to allow more funding for 

trail maintenance to reach the ground. 

Agency Response: Administrative costs are 

not determined locally by the Payette National 

Forest, but at higher levels of the Forest 

Service and federal government. Control of 

these costs is outside the scope of this travel 

planning project and decision. 

Collaboration & Partnerships 

5. The Forest Service may have improperly 

worked with State and local governments as 

cooperators in the travel planning process. 

Agency Response: The authority for the 

Forest Service to participate in an agreement to 

cooperate with the counties is provided by the 

National Environmental Policy Act, 42 USC 

4321 et seq. The authority of the Counties to 

participate as cooperating agencies is provided 

by the NEPA regulations at 40 CFR 1501, 

1506, and 1508. The four local counties were 

invited to participate in the travel planning 

process as cooperating agencies as provided by 

the NEPA regulations. In addition, the State of 

Idaho Parks and Recreation Department 

participated informally in the travel 

management process, rather than under a 

Memorandum of Understanding as a 

cooperating agency. 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

6 – 56 Payette National Forest Travel Plan FEIS 

Environmental Analysis 

Analysis - General 

6. The Forest Service should complete the 

analysis of travel management with a minimum 

of paperwork. 

Agency Response: Due to the Forest-wide 

scope of travel management planning, the 

potential for broad resource and social effects, 

and the requirements of federal environmental 

laws and regulation, a certain level of analysis 

and accompanying paper work is required. The 

Agency does make every effort to keep 

paperwork (and costs) to a minimum while still 

meeting statutory requirements. Both the DEIS 

and the FEIS are available electronically, on 

the internet and on CD, to minimize paper 

costs. 

7. The Forest Service should ensure that 

Recreation Objective REOB18 from the Forest 

Plan is followed. 

Agency Response: Recreation Objective 

REOB18 (Forest Plan 2003: p. III-63) states: 

“Initiate a process of phased, site-specific 

travel management planning as soon as 

practicable. Prioritize planning based on areas 

where the most significant user conflicts and 

resource concerns are occurring. Identify and 

address inconsistent access management of 

roads, trails, and areas across Forest, Ranger 

District, and interagency boundaries.” The 

Forest initiated travel planning in 2004 in 

response to this objective and followed the 

direction therein during the development and 

analysis of travel management alternatives 

presented in the DEIS and FEIS. 

8. The Forest Service should consider all 

resources when analyzing travel management. 

Agency Response: The Forest Service has 

analyzed effects to those resources most likely 

to be affected by travel route designation. It 

would be unnecessarily burdensome and 

unproductive to analyze effects to resources 

that are not likely to be affected. 

9. The Forest Service should only consider 

implementation of road closures/restrictions 

during travel planning, not during Districtlevel NEPA planning. 

Agency Response: The designation of routes 

for travel management was analyzed at a 

Forest level, rather than at the narrower, sitespecific level of most Ranger District NEPA 

projects. Travel management planning is an 

on-going process, and situations change on the 

ground over time. Potential route designations 

would be reviewed as site-specific District 

projects are proposed. If management 

considerations require changes or alternate 

options for a specific area, these would be 

analyzed at that time and subject to public 

comment consistent with NEPA regulations 

(40 CFR 1500-1508) and Forest Service NEPA 

policy in the Forest Service manual and 

handbook (FSH 1909.15 section 18). 

10. The Forest Service should clarify the 

definition of closed so that it does not appear 

that areas, trails, or roads are closed to foot 

traffic as well. 

Agency Response: The DEIS was not clear, 

so the definition of closed has been revised in 

the FEIS to make it clearer that non-motorized 

traffic is almost always allowed on areas, 

roads, and trails anywhere on the Forest unless 

management considerations such as safety, or 

law, such as in designated Wilderness, where 

mechanized travel, including mountain biking, 

is not allowed. 

11. The Forest Service should consider that 

combining both winter and summer recreation 

into three somewhat “polarized” alternatives 

makes it difficult for people to comment in a 

multi-use fashion. 

Agency Response: The five alternatives 

analyzed in the FEIS balance between the 

extremes of too few to analyze the real options, 

or too many to be understandable. Formulating 

alternatives that emphasize different 

recreational uses reduces the number of 

alternatives and the length of analysis, and 

simplifies the understanding of alternatives. 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

Payette National Forest Travel Plan FEIS 6 - 57 

The public may comment on any elements or 

combination of proposals from the various 

alternatives, and reviewers are not confined to 

supporting one alternative or another. The 

Deciding Officer is also free to select different 

elements from each of the five alternatives 

when formulating the Selected Alternative. 

12. The Forest Service should consider in the 

analysis the differences between the east and 

west zone of the forest. 

Agency Response: Proposals for the DEIS 

were developed at the Management Area level 

(see DEIS Chapter 2). Management areas are 

land areas with similar management goals and 

are smaller than “east zone” and “west zone”. 

Using management areas separates out 

differences caused by both resource and 

management concerns. The thirteen 

management areas reflect east zone-west zone 

geographical differences. 

13. The Forest Service should indicate that 

many of the proposed ATV trails are in fact 

closed roads being converted to trails. 

Agency Response: Converting closed roads to 

trails is discussed in DEIS Chapter 2 – 

Alternatives, in the “Road and Trail Proposals 

by Alternative” table in each Management 

Area (MA) section. The table lists whether the 

proposal is on a road or trail for each Proposal 

ID. 

14. The Forest Service should consider access 

for the elderly and disabled as a significant 

issue. 

Agency Response: See DEIS p. 1-14 through 

1-16, “Access for people with disabilities” for 

the discussion of this issue. The Agency is 

bound by Federal law to protect the rights of 

disabled individuals in a non-discriminatory 

manner; therefore all alternatives address this 

issue by assuring that reasonable restrictions 

on motor vehicle use are applied to everyone. 

In conformance with section 504, wheelchairs 

are welcome on all NFS lands that are open to 

foot travel and are specifically exempted from 

the definition of motor vehicle, even if they are 

battery powered. 

15. The Forest Service should separate winter 

closures proposed for wildlife protection from 

those proposed for non-motorized winter 

recreation. 

Agency Response: The FEIS contains more 

discussion of the rationale for each winter 

closure area in the description of the 

alternatives found in Chapter 2. 

16. The Forest Service failed to analyze an 

adequate range of alternatives for 

snowmobiling. 

Agency Response: The four alternatives 

analyzed in the DEIS provide for between 

886,650 to 1,116,100 acres open to over-snow 

motorized use. The DEIS also analyzed 226 to 

245 miles of groomed snowmobile trails. The 

Forest Supervisor believed that the range of 

alternatives in the DEIS was adequate to 

respond to all significant issues raised in 

scoping and meet the Purpose and Need for the 

project. Between draft and final EIS, 

Alternative E was developed and analyzed to 

further consider public comments and resource 

specialist input. 

Over-snow motorized use has not yet reached 

levels that would necessitate allocating more 

area or regulating access to the currently 

available area. Crowding of vehicles and users 

at trailheads dissipates away from the 

trailheads. While snowmobile registrations 

have been going up in Valley and Adams 

counties, they dropped statewide in 2006 

(IDPR 2006). See Chapter 3, Recreation, for 

an analysis of the effects of the alternatives on 

snowmobiling. 

An additional alternative that considered 

access into the recommended wilderness areas 

of the Secesh and Needles inventoried roadless 

areas IRA was suggested by public comments, 

considered by the Forest Service, but dropped 

from further analysis. In the FEIS see Chapter 

2, Section 2.2, Alternatives Considered but 

Eliminated from Detailed Study for the 

discussion of this alternative. In the FEIS, 

additional acres open to over-snow motorized 

use were added into Alternative C adjacent to, 

but not in the Secesh and Needles 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

6 – 58 Payette National Forest Travel Plan FEIS 

recommended Wilderness and were analyzed 

in full in Alternative C, Chapter 3. 

17. The Forest Service should support the 

conclusions found in the document with 

research and indicate how applicable federal 

rules and regulations are being followed in 

each alternative. 

Agency Response: Whenever research is 

available to support analysis and conclusions 

in the document, it has been cited (see Chapter 

3 and Appendix B). Compliance with Federal 

laws, rules, and regulations is documented in 

Chapter 1, Purpose and Need, and 

Management Direction and Chapter 3, 

individual resource sections, Environmental 

Consequences. 

18. The Forest Service failed to analyze an 

alternative that truly addresses the need to 

increase motorized opportunities. 

Agency Response: Provision of recreational 

opportunities and access needs are two of 

several criteria the responsible official must 

consider under federal regulations when 

designating routes for motor vehicle use. The 

Payette National Forest is popular with many 

people for many uses. It is not possible to 

accommodate all user demands on all acres 

while also protecting water quality, wildlife 

habitat, and other natural resources that people 

come to enjoy and which laws have been 

enacted to protect. Forest Service managers 

need to balance user interests against these 

other criteria when designating routes and 

areas. 

Different alternatives provide for different 

degrees of motorized uses. Alternative C, in 

particular presented in Chapter 2 of the EIS, 

provides a feasible proposal for increasing 

motorized use while remaining within the 

scope of the travel management analysis. 

19. The Forest Service should analyze an 

alternative that meets the direction found in 

the NFMA for renewable and sustainable 

resources including motorized recreation. 

Agency Response: Designation of routes or 

areas to meet future potential demand is 

challenging at best. The Agency prefers to 

assure that current demand is being met while 

protecting resource values and staying within 

budgetary constraints. 

20. The Forest Service should display the 

amount of non-motorized and motorized 

opportunities available in an unbiased way. 

Non-motorized users in fact have the use of the 

entire Forest, including the Wilderness. 

Agency Response: The FEIS clarifies that 

non-motorized use, including foot travel, 

horseback riding, and bicycles, is allowed both 

on and off-trail across the Forest. The Payette 

includes approximately 791,000 acres of the 

Frank Church—River of No Return 

Wilderness. Wildernesses are not within the 

project area for travel management (DEIS 

Chapter 1, Section 1.5, Project Scope). 

However, it is considered in the recreation 

cumulative effects analysis (FEIS Chapter 3) 

21. The Forest Service should consider the 

environmental effects of past restriction of 

motorized use when proposing to close more 

motorized trails or areas. 

Agency Response: Effects of past 

management and other historic natural events 

are taken into account during the analysis and 

description of the current condition. See the 

discussion of existing condition in Chapter 3, 

resource sections. 

22. The Forest Service should consider that the 

analysis presented in the DEIS appears to be 

biased against motorized use and users. 

Agency Response: The Forest made every 

effort to avoid bias toward or against any 

recreation uses or users. All action alternatives 

do reduce motorized access to the Forest in 

terms of cross-country travel. This can reduce 

motorized opportunities, but lessens the 

potential for adverse resource impacts and 

follows national direction. The Travel Plan 

implements national Forest Service direction. 

The final rule for travel management of motor 

vehicle use directs all National Forests to 

evaluate limiting cross-country motor vehicle 

use to designated routes and areas only. 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

Payette National Forest Travel Plan FEIS 6 - 59 

Alternative C, described in Chapter 2 of the 

EIS, increases motorized trail opportunities 

above the current level. Alternative E, also 

described in Chapter 2 of the FEIS, maintains 

motorized opportunities at about the current 

level, with a reduction in two-wheel motorized 

trails and an increase in ATV/OHV trails. 

Recent Idaho survey data indicate that 

approximately 76% of motorized users ride an 

ATV and 22% ride motorcycles, so a shift in 

the balance of trails allocated to the two is not 

an unreasonable proposal (Achana 2005). 

Alternative B reduces area open to 

snowmobile by 2%, Alternative C increases 

access by 7%, and Alternatives D and E 

decrease access by 19 and 11% respectively 

within the project area. Statewide snowmobile 

registrations were down in 2006. These 

alternatives provide the Deciding Officer with 

a range of motorized access alternatives for 

winter travel. 

23. The Forest Service should analyze the 

semi-primitive experience in winter to assess 

the incompatibility of motorized and nonmotorized winter sports. 

Agency Response: Components of a semiprimitive experience are described in the 

Recreation effects analysis in Chapter 3, under 

the discussion for Recreation Issue 2: 

Motorized and non-motorized opportunities in 

winter. 

24. The Forest Service should do an analysis 

of the capabilities of the Forest to sufficiently 

monitor, enforce, and carry out public 

education in support of the new travel plan. 

Agency Response: The Forest Service agrees 

that availability of management resources 

should be a consideration in designating routes 

for motor vehicle use. The Deciding Officer 

will use judgment and discretion to determine 

a system of designated routes that is 

supportable by the average anticipated Forest 

budget. However, at times, resources are 

scarce, and the Payette staff does not believe 

that this scarcity should lead to blanket 

closures of lands to recreational users. 

Volunteers and cooperators can supplement 

agency resources for maintenance and 

administration, and their contributions are 

considered in this evaluation. See Chapter 3, 

Recreation, Effects Analysis, for a discussion 

of this issue by alternative. 

25. The Forest Service should clarify the 

following: Page 3-17, MA 6. Goose 

Creek/Hazard Creek – Winter. first 

paragraph.. Since both ski areas are under 

Special Use Permit, as is the case for the 

Brundage Snow Cat operation, all three should 

be listed. (398:50200) 

Agency Response: The description listed the 

two ski areas on the Forest, which are under 

ski area use permits. Brundage Mountain Snow 

Cat operation is not a ski area permit, but is an 

outfitter and guide activity offered by the 

Brundage Mountain Resort. Outfitters and 

guides are not listed in detail or individually. 

Also refer to: page 3-18, MA 7 Payette Lakes – 

Winter. 

26. Attention needs to be given to the rounding 

off of figures all the way through the DEIS. 

Agency Response: In the FEIS figures are 

rounded to reflect the available precision of the 

data and do not provide more decimal points 

than the technology supports. 

27. The Forest Service should clearly identify 

the reasons for, and opportunities created by, 

identifying areas as suitable for motorized or 

non-motorized use in winter. 

Agency Response: The FEIS contains 

additional discussion of the rationale for each 

winter closure area. 

28. The Forest Service should clearly explain 

how the analysis presented in the DEIS 

complies with sections 101 and 102(1) of the 

National Environmental Policy Act (NEPA) 

and other environmental laws. 

Agency Response: The Record of Decision to 

be issued after consideration of public 

comments on the FEIS will identify the 

Selected Alternative and discuss rationale for 

its selection, as provided in 40 CFR 1502 (B). 

The Selected Alternative will be that 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

6 – 60 Payette National Forest Travel Plan FEIS 

alternative which best meets section 101 of 

NEPA through the principles and requirements 

of section 102 as determined by the Deciding 

Officer. Subsection (1) requires that policies, 

regulations, and laws shall be interpreted and 

administered in accordance with the NEPA 

statute. The Travel Plan FEIS is consistent with 

the statute. 

29. The Forest Service should ensure that the 

alternatives presented in the DEIS follow the 

direction found in Executive Order 11989. 

Agency Response: The final rule is consistent 

with provisions of Executive Order 11644 and 

Executive 11989 regarding off-road use of 

motor vehicles on Federal Lands. Executive 

Order 11989 authorizes the agency to 

designate roads and trails as suitable for motor 

vehicle use and to close all other areas and 

trails to that use (DEIS Chapter 1, section 

1.11). The action alternatives presented in the 

DEIS close the Forest to all off-route travel 

with the exception of a 300 foot corridor on 

roads and a 100 foot corridor on motorized 

trails, which is open for dispersed camping. 

This corridor is designated only in areas where 

no adverse effects to forest resources are 

expected from the off-road use. Some areas, 

identified in the analysis and shown on the 

maps, would be closed to any motorized travel 

off designated routes due to sensitive resource 

protection needs. Areas with sensitive 

resources proposed for closure to motorized 

off-route travel include: known areas with 

northern Idaho ground squirrel colonies, the 

Lake Creek area on the McCall Ranger 

District, and the entire Krassel Ranger District. 

In these areas, all dispersed camping would be 

restricted to designated sites. 

Restriction of off-route vehicle travel is 

expected to reduce the likelihood of adverse 

resource effects across the Forest. The Forest 

still retains the authority given in Executive 

Order 11989 to close areas or routes where 

considerable adverse effects are occurring. 

30. The Forest Service should clearly indicate 

that the travel plan decision will not be the 

only decision affecting road and trail closures. 

Rather NEPA analyses and decisions will 

continue on the Forest and more roads and 

trails may be closed to mitigate those actions. 

Agency Response: The cumulative effects 

discussion in each resource section in Chapter 

3 in the DEIS covers known expected actions 

that may affect road or trail management. 

Appendix D lists the actions that have been 

considered in the analysis of cumulative effects 

for travel management. Future proposals, 

NEPA analyses, and decisions may have the 

effect of closing (or opening) more roads to 

motorized uses. 

31. The Forest Service DEIS lacks sufficient 

site specific analysis. 

Agency Response: Analyses completed at the 

Forest level, such as travel management, are 

less site-specific than analyses completed for 

projects done at a smaller scale. However, the 

EIS does provide site-specific, as opposed to 

programmatic (Forest Plan-level) analysis. 

Every Proposal ID route, whether a road or a 

trail has received extensive site-specific 

internal analysis and documentation. The 

summary analysis documentation presented in 

Chapter 3 of the DEIS reflects extensive sitespecific data, such as road and trail crossings. 

Most of the proposals analyzed in the action 

alternatives in the document were developed 

during site-specific RAPs (Road Analysis 

Processes) conducted by the Ranger Districts 

or based on trail inventory data. 

32. The Forest Service improperly used the 

travel plan to adjust ROS inventories. 

Agency Response: The Payette National 

Forest LRMP of 2003 includes the recreation 

objective of adjusting the ROS classes as a 

result of travel planning (found in the 

Management Area (MA) specific direction for 

each MA under Recreation Resources.). After 

the FEIS and Record of Decision are 

completed, the Forest may adjust the ROS 

classes to reflect the changes made in both 

summer and winter travel. 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

Payette National Forest Travel Plan FEIS 6 - 61 

33. The Forest Service should develop a 

Winter Recreation Plan. 

Agency Response: The Payette has considered 

the recommendation to prepare a Winter 

Recreation Plan. Such a plan would be a 

programmatic blueprint for winter recreation 

management across the Forest. While 

desirable, such a Plan is not a high enough 

priority for limited Forest budget and staff 

resources. The 2003 Forest Plan already 

provides some programmatic direction for 

recreation across the Forest and in the 13 

Management Areas. This Travel Plan analysis 

will provide additional recreational guidance at 

the site-specific level. If through monitoring, 

the combination of Forest Plan and Travel Plan 

direction proves inadequate in meeting 

recreational objectives, the Forest will review 

this option. 

34. The Forest Service should have separated 

winter and summer recreation in the DEIS. 

Agency Response: Inclusion of both summer 

and winter recreation in the DEIS does make 

the document fairly complex. However, the 

presentation of both seasons in one document 

does allow the Forest user to get the “big 

picture” for recreation on the Payette National 

Forest. As much as possible, the discussions of 

effects and display of data for the two seasons 

have been separated to keep the distinction 

between winter and summer management 

clear. 

Purpose and Need 

35. The Forest Service’s stated purpose and 

need included wildlife, vegetation, soils, and 

watershed management, but the analysis 

focuses on recreation. 

Agency Response: In addition to recreation, 

effects to wildlife, vegetation, and soil and 

water are all analyzed in Chapter 3 of the 

DEIS, and the FEIS. Additional information 

appears in this Response to Comments 

appendix and the Project Record. 

36. The Forest Service should make sure the 

analysis supports the stated purpose and need 

for the project. 

Agency Response: The degree to which each 

alternative meets the purpose and need of the 

planning project is answered in several places 

throughout the DEIS and FEIS. DEIS p. 1-4 

lists the six elements of the “purpose” of the 

project. Table 2-1, Forest Summary – Travel 

Opportunities by Alternative – compares the 

miles and acres of roads, trails, and areas open 

and closed to motorized uses by alternative. 

The effects of alternatives tables throughout 

Chapter 3 compare how each alternative meets 

the resource effects elements of the purpose 

and need. And the Record of Decision to be 

issued after the FEIS comment period will 

evaluate each alternative in terms of how well 

it meets the purpose and need among other 

factors. 

37. The Forest Service should display ALL 

pertinent Forest Plan direction. 

Agency Response: The DEIS and FEIS 

identified selected goals, objectives, standards, 

and guidelines that are particularly pertinent to 

Travel Planning. The option of reprinting all 

Forest Plan direction and placing it in the FEIS 

was considered but not accepted because of 

substantial bulk and costs compared to the 

limited benefit. 

Issues 

38. The Forest Service should consider the 

importance of travel management to the 

snowmobiling community. 

Agency Response: The Payette National 

Forest staff does understand the importance of 

travel management planning to the 

snowmobile community. Alternative C, 

described in the Chapter 2 of the DEIS, was 

developed partly to reflect the desire the oversnow motorized community has for additional 

motorized over-snow play areas by adding an 

additional 78,160 acres of over-snow 

motorized opportunities. 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

6 – 62 Payette National Forest Travel Plan FEIS 

39. The Forest Service should identify all 

existing resource problems affected by travel 

management. 

Agency Response: Across the Forest there are 

numerous resource problems of various 

degrees of magnitude. The Agency does not 

believe that an exhaustive analysis of every 

potential effect that might be caused or has 

been caused by travel route designation is 

necessary or would serve the public interest 

very well. The Forest has focused the analysis 

on those issues and resources that are most 

likely to be affected by route designation, and 

that will give the Deciding Officer the most 

relevant information in making her decision 

from among the alternatives described. 

40. The Forest Service should complete a road 

analysis to assess the effects of road 

management to all resources. 

Agency Response: The Payette Forest Plan 

(2003) included a Forest-wide roads analysis 

process (RAP) at the broad scale. A large 

amount of the PNF watersheds have had a 

more specific RAP. The Forest Service 

disagrees that a complete inventory of usercreated routes is required in order to complete 

the designation process. A complete detailed 

inventory would be time-consuming and 

expensive, delaying completion of route 

designation. Planning based on public 

involvement, careful design, and site specific 

environmental analysis provides the best 

method for identifying a sustainable, managed 

system of routes and areas addressing user 

needs and safety, with a minimum of 

environmental impacts. See comment 39 for 

additional response. 

41. The Forest Service should consider an 

alternative that opens roads to non-motorized 

use only during the winter. 

Agency Response: An alternative that 

considered only one type of use, be it solely 

motorized or non-motorized, would not meet 

the Purpose and Need for this project, which, 

in part, is to balance management 

considerations with recreation opportunities. 

Nor would it meet many of the goals and 

objectives of the Forest Plan, one of which is 

to “Provide an array of winter recreation 

experiences, while mitigating conflicts 

between motorized and non-motorized use and 

wintering wildlife.” Through this travel 

management process the Forest has strived to 

provide opportunities both for motorized and 

for non-motorized users. 

42. The Forest Service should not consider 

allowing more motorized use in existing IRA’s. 

Agency Response: All inventoried roadless 

areas (IRAs) on the Payette National Forest 

provide for both motorized and non-motorized 

recreation opportunities, while maintaining the 

undeveloped character of the area. Only those 

IRAs recommended for wilderness designation 

(portions of the Needles and Secesh IRAs) 

have Forest Plan standards that do not allow 

for development of additional motorized use. 

This issue is analyzed in the FEIS in Chapter 

2, under Alternatives Considered but 

Eliminated from Detailed Study. 

43. The Forest Service should have good 

rationale for constructing any new roads or 

trails. 

Agency Response: No new road construction 

was proposed in the alternatives analyzed in 

the DEIS or FEIS. New trail construction is 

limited to small segments of trail construction 

to connect existing routes or to relocate/reroute a trail to avoid resource damage. These 

activities are subject to project design features 

to limit resource impacts (see Section 2.2.2 of 

the FEIS). Some unauthorized roads are 

proposed for conversion to NFS roads. If 

selected for conversion, these roads would be 

brought up to the appropriate standard for their 

level of use. The Payette agrees that proposals 

for new trail construction must have good 

rationale, because funding for trail 

maintenance is not adequate to cover the 

current trail system. Therefore, in Alternatives 

B and C only a few miles of new trail are 

proposed that would connect and create some 

ATV trail loop opportunities. Most of these 

“new” trail miles are actually conversion of 

either unauthorized roads or trails to NFS 

trails, or closed NFS roads to trails. All added 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

Payette National Forest Travel Plan FEIS 6 - 63 

ATV trails would need to be brought up to 

appropriate trail standards before being 

designated for use. 

44. The Forest Service should consider an 

alternative that analyzes complete closure to 

over-snow travel. 

Agency Response: Such an alternative would 

not meet the Purpose and Need for this project, 

which, in part, is to balance management 

considerations with recreation opportunities. 

Nor would it meet many of the goals and 

objectives of the Forest Plan, one of which is 

to “Provide an array of winter recreation 

experiences, while mitigating conflicts 

between motorized and non-motorized use and 

wintering wildlife.” (Forest Plan 2003: III-62: 

REGO06). Through this travel management 

process the Forest has strived to provide 

opportunities for both motorized and nonmotorized users. 

45. The Forest Service should analyze an 

alternative that designates some areas open to 

motor vehicle use. 

Agency Response: Areas open to crosscountry motor vehicle use were analyzed as 

part of the No Action alternative. This 

alternative, or portions of this alternative, 

could be chosen by the Deciding Officer. In all 

action alternatives a corridor for motorized 

access to dispersed camping within300 feet of 

open roads, and 100 feet of motorized trails, is 

proposed when such use would not 

compromise resource values. There were no 

additional areas proposed for inclusion in any 

of the action alternatives either by Agency 

personnel or by the public. Inclusion of 

additional cross-country travel areas would 

also be inconsistent with national direction (36 

CFR Parts 212, 251, 261, 295 “Travel 

Management; Designated Routes and Areas 

for Motor Vehicle Use” Federal Register 2005: 

70FR68264) to limit indiscriminate travel 

through designating defined routes for motor 

vehicle use. 

46. The Forest Service should analyze an 

alternative that opens all unauthorized roads 

and trails. 

Agency Response: The Forest considered and 

added some individual roads and trails that 

were recommended during the public scoping 

process into Alternative C, and Alternative D. 

Alternative E in the FEIS also added several 

additional routes in response to public 

comments on the DEIS. 

The addition of all unauthorized roads and 

trails into the NF system would result in an 

unaffordable road system that could not be 

brought up to Agency standards or maintained 

at the Agency’s current budget levels. The 

Agency’s budget is expected to continue to 

decline in the foreseeable future. In addition, 

allowing use on all uanuthorized roads would 

likely have unacceptable impacts to wildlife, 

water, fisheries, and other resources. 

47. The Forest Service should consider the 

resource effects of non-motorized winter 

recreation. 

Agency Response: Effects of non-motorized 

and motorized recreation in winter and 

summer were discussed in the Wildlife 

analysis in the DEIS, Chapter 3. 

48. The Forest Service should collaborate with 

local recreation groups to improve the 

alternatives. 

Agency Response: The alternatives presented 

in the DEIS were developed as a result of 

extensive public involvement with local 

recreation groups and users through the public 

comment process on the Proposed Action, and 

as a result of discussions by the Winter 

Recreation Forum. Also, Valley, Adams, and 

Washington County participated as cooperating 

agencies and helped to develop the 

alternatives. Idaho State Parks and Recreation 

and Idaho Department of Fish and Game also 

participated as informal members of the team. 

Alternative E, which is analyzed in the FEIS, 

was formulated by incorporating public 

comments on the DEIS, including those from 

local recreation groups. 

49. The Forest Service did not adequately 

factor in the nationwide trend of increasing 

motorized use. 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

6 – 64 Payette National Forest Travel Plan FEIS 

Agency Response: See response to comment 

19. 

50. The Forest Service should consider the 

carrying capacity of the forest for various 

modes of recreation. 

Agency Response: At this point in time the 

Forest does not receive enough recreation use 

and crowding to warrant assessing the carrying 

capacity for different forms of recreation. 

(USDA Forest Service 2003b: NVUM). 

It is possible that in the future such studies 

could be necessary. 

51. The Forest Service should consider using 

old logging roads and roads planned for 

decommissioning as trails. 

Agency Response: During travel planning the 

Forest considered many routes that public or 

internal comment brought forward as potential 

trails, including routes on old logging roads. 

Roads already planned for decommissioning 

by previously signed decision were considered 

already evaluated for their merits for other 

uses. 

Any future projects where road 

decommissioning is proposed will be presented 

to the public for comment. Should some of 

these routes be desirable as potential trails they 

will be evaluated during the analysis of that 

future project. 

52. The Forest Service should analyze the 

environmental effects of increasing 

snowmobile use, such as has occurred in the 

last decade. Effects to air quality, water 

quality, noise pollution, and wildlife should all 

be considered. 

Agency Response: The DEIS and FEIS 

include such effects in the environmental 

analysis of Chapter 3 and in disclosures of 

non-significant effects in Chapter 1. Also see 

comment responses above and below for each 

resource section listed. 

53. The Forest Service should consider that the 

project design features which address noxious 

weeds in the DEIS are insufficient to reduce 

the spread of these weeds to a non-significant 

issue when considered at the forest level. 

Agency Response: All Forest Plan 

management direction, including direction 

pertaining to noxious weeds, is incorporated by 

reference in this project. See Section 1.7, 

Management Direction, in the DEIS and FEIS, 

and Chapter 3, Management Direction, in the 

Payette National Forest Plan. This direction 

presents a comprehensive Integrated Weed 

Management approach for control and 

eradication of noxious weeds. 

54. The Forest Service should analyze the 

effects of snowmobile exhaust on air quality as 

a significant issue. 

Agency Response: The Forest does not have 

jurisdiction over vehicle use emissions, so 

remedies for this concern are outside the scope 

of the proposed action. Also, effects of all 

motorized vehicles together across the Forest 

are not expected to risk violation of air quality 

standards. See Chapter 1, Section 1.10.2 NonSignificant Issues in the DEIS. 

55. The Forest Service needs to review the 

factors used when determining nonsignificance of issues to make sure they comply 

with the NEPA. 

Agency Response: As stated on p. 1-9 of the 

DEIS, the Forest ID team grouped all public 

comments into categories, developed issues, 

and separated issues into two categories—

significant, and non-significant. The significant 

issues were those that were useful in 

formulating an alternative to the proposed 

action, or in disclosing environmental effects. 

The CEQ Regulations state several times that a 

NEPA analysis needs to focus on significant 

issues and discuss only briefly issues other 

than significant issues. For example, 40 CFR 

1500.1 (b), 1500.2(b), and 1500.4(c). As 

instructed in Forest Service national training, 

significant issues are “significant” by reason of 

their scope, magnitude, or extent of their 

effects. Note that “significant issues” have a 

separate and distinct definition from 

“significant effects” (40 CFR 1508.27). 

Chapter 1 lists and discusses the significant 

issues (section 1.10.1), and then lists and 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

Payette National Forest Travel Plan FEIS 6 - 65 

describes the non-significant issues including 

rationale for their non-significance in the 

environmental analysis (section 1.10.2). 

Definitions 

56. The Forest Service should clarify the 

definition of “cross country motor vehicle use” 

particularly in designated corridors. 

Agency Response: This term has been better 

defined in the FEIS. 

57. The Forest Service should fully define what 

is meant by “closure” in the FEIS, including 

the types of management that would be 

authorized to close routes. 

Agency Response: The definition of “closed” 

in the FEIS has been clarified so that it is 

understood that non-motorized use is allowed 

on all closed routes and areas unless prohibited 

due to management concerns. See response to 

Comment 56 above. 

Travel management is a route designation 

process and does not authorize closure 

activities such as decommissioning, placement 

of gates, or construction of earthen berms. 

Such proposals would require additional sitespecific NEPA analysis. 

58. The Forest Service has used the term 

“unauthorized” incorrectly in the DEIS. 

Agency Response: The Forest’s use of the 

term is as described in the national travel 

management rule (Federal Register 2005: 

70FR68264). See Appendix A, Glossary, in the 

DEIS and FEIS. 

59. The Forest Service has incorrectly 

described the proposed winter closure at 

Granite Mountain in the DEIS which should be 

described as “snowmobile free” rather than 

non-motorized due to the permitted snow cat 

operation in the area. 

Agency Response: The snow cat skiing 

operation is under a Special Use authorization 

and is an exception (as authorized under their 

Special Use Permit) to the non-motorized 

status of the Granite Mountain closure area in 

Alternatives B, C, D, and E that will allow 

back-country skiers access to a snowmobilefree slope. During the winter, when the snow 

cat skiing operation is not running, the area 

will be completely non-motorized. There have 

been many seasons where snow levels have not 

been sufficient to run the snow cat at any time 

during the season. As the DEIS stated (p. 2-

33), this closure would create an area “for nonmotorized winter recreation within reasonable 

distance of parking.” The intent of the closure 

is to provide a non-motorized backcountry 

skiing area separate from snowmobiling use 

areas. 

Monitoring 

60. The Forest Service should monitor all 

travel-way closures to assure that they are 

achieving the travel management objectives for 

which they are closed. 

Agency Response: Implementation and 

effectiveness monitoring of travel plan 

designations will occur periodically after the 

decision is made to adopt a plan. Monitoring 

was generally addressed in the DEIS on p. 2-7. 

Specific implementation and effectiveness 

monitoring plans are listed in Appendix E in 

the FEIS, and when finalized will become part 

of the Record of Decision for this project. 

61. The Forest Service should consider more 

effective methods of road closure/barriers 

because current methods such as gates and 

berms seem to often be ineffective. 

Agency Response: Part of the purpose and 

need identified in the DEIS is to designate a 

system of open roads, trails, and areas. All 

roads and trails are considered closed to 

motorized use unless designated open by the 

PNF motor vehicle use map (MVUM), which 

will follow the travel plan decision. Designated 

routes would be identified on the MVUM 

using nationally directed uniform standards, 

and signs identifying those routes open to 

public travel would be posted on the ground to 

the extent practicable. (DEIS page 2-4). Actual 

physical closure or road obliteration is 

considered outside the scope of this document 

but may be considered with future site-specific 

projects (DEIS p. 2-2). 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

6 – 66 Payette National Forest Travel Plan FEIS 

62. The Forest Service should commit to 

implementation and effectiveness monitoring 

for travel management. 

Agency Response: The Forest is committed to 

implementation and effectiveness monitoring 

for travel management. The Project Design 

Features in Chapter 2 Section 2.2.2 of the 

DEIS, and the monitoring and evaluation listed 

in Section 2.2.3 all are designed to evaluate the 

effectiveness of the route and area designation 

made with the travel management plan 

decision. Specific implementation and 

effectiveness monitoring plans are listed in 

Appendix E in the FEIS, and are expected to 

be part of the Record of Decision for this 

project. 

Project Design Features 

63. The Forest Service should include project 

design features to ensure recognition of 

environmental concerns that may arise as a 

result of travel route and area designation. 

Agency Response: The alternatives do include 

such project design features, as described in 

Chapter 2, description of the alternatives. 

64. The Forest Service should evaluate the 

description of Project Design Features to 

ensure they are feasible. 

Agency Response: The Forest believes all 

Project Design Features (PDFs) listed in the 

FEIS are feasible. Monitoring will evaluate if 

travel management decisions including PDFs 

are implemented, and how effective the 

implementation is in accomplishing the desired 

outcomes. 

Maps & Data Display 

65. The Forest Service should improve the 

presentation of the proposals and maps in the 

FEIS. 

Agency Response: The Forest has updated 

and streamlined the maps for the FEIS. 

66. The Forest Service should improve the 

winter maps so they better display the areas 

closed to motorized over-snow use. 

Agency Response: The winter maps have 

been reconfigured to better display winter 

closure areas. 

67. The Forest Service should better describe 

the winter closures in the FEIS. 

Agency Response: See response to comment 

15. 

68. The Forest should change the way the 

alternatives are displayed in the Comparison 

of Alternatives tables. 

Agency Response: The format and level of 

detail in the Comparison of Alternatives tables 

were selected to highlight key information that 

varies between alternatives in order to provide 

a reasoned basis for choice. They were 

designed to focus on differences rather than 

similarities. 

69. The Forest Service should identify the 

Brundage Snow Cat permitted area on the 

maps in the FEIS. 

Agency Response: The Brundage Snow Cat 

operation is only one of hundreds of special 

use activities that are permitted on the Forest. 

Many of these permitted activities have effects 

on route or area use. These activities are 

authorized only for the permittee however, and 

do not apply to the public at large, and 

therefore would not be displayed on the 

MVUM or in the EIS for travel management 

planning. The Brundage Snow Cat operation is 

discussed in the Recreation Section of Chapter 

3 of the DEIS 

A discussion of permitted uses can be found in 

Chapter 2 Section 1.10.2 Non-Significant 

Issues. 

Alternatives 

70. The Forest Service should choose an 

alternative that gives a better depiction of 

current recreation use than the No Action 

Alternative discussed in the DEIS. 

Agency Response: The No Action Alternative 

in the DEIS and FEIS is continuation of the 

current condition for travel route designation 

as described in the 1995 Travel Plan Map as 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

Payette National Forest Travel Plan FEIS 6 - 67 

modified by the 2004 Backroads map. Current 

levels of use for designated routes and areas 

were described and compared to the action 

alternatives in the resource sections in Chapter 

3 of the DEIS. 

71. The Forest Service should develop another 

alternative that does not restrict motorized 

access anywhere except the Wilderness. 

Agency Response: While the National Forest 

belongs to all Americans, they do not have a 

right to unrestricted use of National Forests. 

Congress established the Forest Service to 

provide reasonable regulation of the National 

Forest so that they can be enjoyed by future 

generations. Presidential orders affirm the 

authority to manage motorized use. 

The primary goal of the travel management 

plan is to provide a system of roads, trails, and 

areas that provides recreation opportunities for 

both motorized and non-motorized users in a 

manner that is environmentally sustainable 

over the long term. An alternative that 

emphasizes only one type of use would not 

provide this array of opportunities. 

While off-highway vehicle travel has been 

recognized as an appropriate activity on Forest 

system lands, the agency has been given recent 

direction to manage OHV travel (36 CFR Parts 

212, 251, 261, 295 “Travel Management; 

Designated Routes and Areas for Motor 

Vehicle Use” Federal Register 2005: 

70FR68264). Executive Orders direct the 

Forest Service to manage OHV travel on 

Forest system lands to protect forest resources 

and reduce conflict of uses (Executive Order 

[E.O.] 11644 (February 8, 1972) as amended 

by E.O. 11989 (May 24, 1977).Allowing OHV 

travel on the Forest anywhere at any time 

would not comply with these orders. 

72. The Forest Service should develop an 

alternative that increases the opportunity for 

non-motorized recreation. 

Agency Response: Alternative D, described in 

Chapter 2 of the DEIS, provides increased 

opportunities for non-motorized recreation. 

This alternative was developed in response to 

internal and public comment on the Proposed 

Action (Alternative B). Like the other action 

alternatives, it limits motorized travel off 

roads. 

73. The Forest Service should complete a RAP 

and address more road closures, relocations, 

and obliterations because the current 

alternatives do not adequately mitigate current 

impacts to forest resources. 

Agency Response: As presented in Chapter 3 

of the DEIS the analysis of resource impacts 

for the alternatives does not indicate that 

unacceptable impacts are occurring due to the 

No Action condition, or would occur due to 

implementation of any of the action 

alternatives. Road relocation and road 

decommissioning were both outside the scope 

of the proposed action. 

74. The Forest Service should consider an 

alternative that incorporates the ISSA 

proposals in their entirety, including entering 

the Secesh and Needles Recommended 

Wilderness areas. 

Agency Response: See response to comment 

16. 

75. The Forest Service should consider an 

alternative that addresses the loss of 

unauthorized roads. 

Agency Response: The DEIS did consider and 

disclose the consequences of not designating 

unauthorized roads in the Environmental 

Consequences section in Chapter 3, under the 

recreation issue sections pertaining to miles of 

open and seasonally open roads, and in acres 

open to cross-country motor vehicle use on 

pages 3-24, 3-33, 3-35, and 3-36; and in the 

Cumulative Effects section for recreation on 

pages 3-55. 

76. The Forest Service should develop an 

alternative that is more responsive to the 

increasing demand for motorized recreation 

opportunities. 

Agency Response: See response to comments 

18 and 19. 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

6 – 68 Payette National Forest Travel Plan FEIS 

77. The Forest Service should develop an 

alternative that is more responsive to the 

increasing demand for both motorized and 

non-motorized recreation opportunities. 

Agency Response: See response to comments 

18 and 19. 

78. The Forest Service should develop an 

alternative that does not allow degradation of 

any natural resources over time. 

Agency Response: The Payette does not agree 

that motor vehicle use should be allowed only 

when and where it can be clearly proven in 

advance to be harmless to the environment. 

Rather, designation decisions need to be made 

balancing public desires for recreation 

opportunities with acceptable impacts to 

resources. 

Cumulative Effects 

79. The Forest Service should consider the 

cumulative effects of the loss of OHV trail 

nationwide. 

Agency Response: One principle of 

cumulative effects analysis is that the 

geographical area of analysis needs to be large 

enough to capture off-site or delayed effects of 

a causative action, but also small enough that 

the incremental effect is not lost in the large 

background. In the case of the Payette, gain or 

loss of OHV trails locally would not be 

discernible at the national scale, and thus 

analysis at that scale would provide no value. 

In the case of reduction of OHV trail by this 

Travel Plan, there is no substantial loss of trail 

mileage in any alternative. 

Natural Resources 

Management 

Fisheries 

80. The Forest Service should re-evaluate the 

use of number of stream crossings as a proxy 

for potential for fuel spills because fuel spills 

occur relatively rarely at stream crossings or 

otherwise. 

Agency Response: The term “spill” as it is 

used in the DEIS uses the EPA definition for 

“harmful discharge” which includes a vehicle 

leaving an oily sheen on the surface of the 

water as it passes through, not just 

contamination from a ruptured fuel tank or 

other mishap. Normal vehicle use at fords 

often leaves a residue of oil on the surface of 

the water from outside contamination of the 

vehicle with petroleum products. 

81. The Forest Service should consider that if 

there are problems occurring with pollution or 

sediment at stream crossings on roads and 

trails, this is the fault of the design or 

maintenance of the facility, and not of the 

public who is using the facility. 

Agency Response: See response to comment 

154. 

82. The Forest Service should consider that 

there is no research to back up claims that 

OHV use and trails have any effect on fisheries 

populations. 

Agency Response: Many studies have 

indicated that OHV use has negative effects on 

natural resources, including fish and fish 

habitat. Stokowki and LaPointe completed a 

comprehensive literature review in 2000 

(Environmental and Social Effects of ATVs and 

ORVs: An Annotated Bibliography and 

Research Assessment.) Research conducted on 

the Payette National Forest is cited in Chapter 

3, Fisheries, Environmental Effects. 

Soil & Water 

83. The Forest Service should consider that 

while roads can affect the recruitment of large 

woody debris to streams, trails do not. 

Agency Response: The Payette agrees the 

potential effects of roads and trails on 

recruitment of large woody debris to streams is 

dependent on the width of the cleared area and 

proximity to the stream. However, the Forest 

does not agree with a blanket statement that 

trails do not affect recruitment of large woody 

debris since it is dependent upon the size and 

location of the trail. 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

Payette National Forest Travel Plan FEIS 6 - 69 

84. The Forest Service should consider erosion 

and sediment from the existing road and 

motorized trail network 

Agency Response: Soil and water issue 1 

(DEIS p. 1-11) states “the type, extent, and 

location of roads, trails, and motorized areas in 

the travel management plan may degrade soil 

productivity, accelerate erosion, and deliver 

sediment to streams.” Six soil and water 

indicators deal specifically with type, extent, 

and location of open roads and types of 

motorized trails (DEIS p. 3-69). A qualitative 

description of the soil and water resource 

damage and a quantitative change from the No 

Action Alternative is found in the Soil and 

Water resource section of Chapter 3, Affected 

Environment and Environmental 

Consequences. 

85. The Forest Service should consider the soil 

and water resource damage caused by 

motorized cross-country travel. 

Agency Response: All action alternatives 

prohibit motorized cross-country travel, 

including travel on all unauthorized roads 

(DEIS p. 1-5). Impacts to soil and water 

resources from motorized cross-country travel 

are addressed with two soil and water 

indicators – SW1: Percent of the Management 

Area (MA) designated open to cross-country 

motor vehicle use and/or limited motorized 

access; and SW2: Percent of riparian 

conservation areas (RCAs) in designated areas 

open to cross-country motor vehicle use and/or 

limited motorized use (DEIS p. 1-11). A 

qualitative description of the soil and water 

resource damage and a quantitative change 

from the no action alternative is found in the 

Soil and Water Resource section of Chapter 3, 

Affected Environment and Environmental 

Consequences. 

86. The Forest Service should identify and 

mitigate environmental concerns associated 

with new road or trail construction. 

Agency Response: No new road construction 

is proposed in the alternatives analyzed in the 

DEIS or FEIS. New trail construction is 

limited to small segments of trail construction 

to connect existing routes or to relocate/reroute a trail to avoid resource damage. These 

activities are subject to project design features 

to limit resource impacts (see Section 2.2.2 of 

the FEIS) and mitigate environmental 

concerns. 

87. The Forest Service should consider 

obliterating unauthorized road and relocating 

roads outside Riparian Conservation Areas 

(RCAs). 

Agency Response: Road obliteration and road 

relocation is not part of any of the alternatives 

and was considered to be outside the scope of 

this proposed action (DEIS p. 2-2). The 

authorized use of unauthorized roads within 

RCAs is reduced by the elimination of crosscountry travel. “Limited motorized access for 

dispersed camping would be permissible 

within 300 feet of designated roads and 100 

feet of designated motorized trails as long as it 

does not result in resource damage such as 

rutting, fording of streams, crossing wet 

meadows, creating new unauthorized routes, 

spreading noxious weeds, or similar resource 

degradation” (DEIS p. 2-4). 

88. The Forest Service should fully describe 

the methods used in road closures. 

Agency Response: Part of the purpose and 

need identified in the DEIS is to designate a 

system of open motorized vehicle routes. All 

roads and trails are considered closed unless 

designated open. The PNF motor vehicle use 

map (MVUM) will use nationally directed 

uniform standards, and signs identifying those 

routes open to public travel would be posted 

on the ground to the extent practicable (DEIS 

p. 2-4). Physical closure or road obliteration is 

considered outside the scope of this proposed 

action but is an appropriate option to be 

considered on future site-specific projects. 

89. The Forest Service should consider the 

effects of differing snow melt patterns caused 

by snowmobile use on soil moisture levels; 

and. 

Agency Response: Agency Response: Fahey 

and Wardle (1998) provide an excellent review 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

6 – 70 Payette National Forest Travel Plan FEIS 

of effects of differing snowmelt pattern caused 

by snowmobile use on soil moisture levels. In 

summary, snow compaction by snowmobiles 

and snow grooming equipment affects soil by: 

1) Decreasing soil temperature, 2) Increasing 

frost penetration, 3) Increasing the time that 

soil takes to thaw, 4) Causing soil to thaw at 

the surface rather than uniformly through the 

profile, 5) Increasing snow density and thermal 

conductivity, resulting in slower snowmelt, 

which in-turn impacts on bacterial 

decomposers and litter decomposition, 6) 

Retarding snowmelt which is likely to cause 

changes in vegetation composition through 

changes in length of growing season and soil 

moisture distribution, 7) Reducing temperature 

gradients within the snow which can have an 

impact on organisms inhabiting the subniveal 

environments, 8) Grooming on ski runs can 

cause up to a 70% reduction in abundance of 

whole soil fauna. Literature review does 

indicate snowmobile use can change the soil 

moisture and the soil environment. The 

greatest impacts will occur on groomed ski 

runs and groomed snowmobile trails. 

Backcountry snowmobile use should disperse 

the amount of compaction and reduce the soil 

impacts. While the Forest recognizes the 

potential change on soil moisture and soil 

ecosystems, the Forest does not believe these 

impacts result in any significant issues.

90. The Forest Service should consider the 

impacts of all uses, motorized and nonmotorized, on sediment/erosion from trails. 

Agency Response: Soil and water issue 1 

(DEIS p. 1-11) states “the type, extent, and 

location of roads, trails, and motorized areas in 

the Travel Management Plan may degrade soil 

productivity, accelerate erosion, and deliver 

sediment to streams. “Hiking and horseback 

riding would be permitted anywhere on the 

Forest, unless otherwise posted” (DEIS p. 2-4). 

There are five specific indicators dealing 

directly with the type, extent, and location of 

motorized trails (DEIS p. 3-69). The FEIS 

expands on the description of erosional 

impacts of hikers, horses, motorcycles, and 

mountain bikes. 

91. The Forest Service should consider that 

erosion and sediment from trails that receive 

equestrian use is at least as great as that from 

motorized use. 

Agency Response: See response to Comment 

90. 

92. The Forest Service should consider effects 

of snowmobile emissions, including crosscountry snowmobile use, on water quality. 

Agency Response: The Forest has conducted a 

literature review on the issue of snowmobile 

emissions and its effects on the chemistry of 

snowmelt runoff and has determined that this 

is a non-significant issue for the Payette. 

Please refer to Chapter 1 of the FEIS. The most 

comprehensive studies have been done within 

the last decade at Yellowstone National Park. 

Studies by Ingersol (1998), Tyler (2000), 

Arnold and Koel (2006) have found that 

pollutants are found at detectable levels in the 

snowpack areas with high snowmobile use. 

However, these concentrations are generally 

low and are dispersed and diluted as they enter 

the surrounding watershed and streams. Even 

in the areas of high snowmobile use, 

concentration of pollutants in the watershed 

are below levels likely to threaten human or 

ecosystem health. In Olliff, Legg, and Kaeding 

(1999), the authors concluded, “Appreciable 

contamination from emissions from 

backcountry snowmobiles probably occurs 

with less frequency than high use areas along 

groomed routes”. These references are 

discussed in the FEIS and are part of the 

Project Record. 

93. The Forest Service should not limit the 

extent of snowmobile use because of potential 

impacts to the soil resource. 

Agency Response: The Payette agrees that 

snowmobile use does not degrade soil 

productivity. “Winter access is not addressed 

as a soil and water issue because over-snow 

vehicle use (snowmobiles) does not degrade 

soil productivity, accelerate erosion, or deliver 

sediment to streams”. (DEIS p. 3-69) 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

Payette National Forest Travel Plan FEIS 6 - 71 

94. The Forest Service should consider that the 

sediment produced from disturbance on an 

OHV trail is considerably less than that 

produced from an open road. 

Agency Response: The Forest did consider 

that sediment produced from OHV trails may 

differ from sediment produced from open 

roads. On page 3-96 in the DEIS the Forest 

stated, “ATV trails can have similar effects to 

soil productivity and water quality as roads but 

the effects differ based on the width of the 

travel way”. In addition, the Forest disclosed 

that, “ATV trails create additional problems 

due to steep grades, lack of designed stream 

crossings, and difficulty of maintaining water 

management features.” As stated in the DEIS, 

the ATV and OHV indicator “is best used to 

evaluate the relative difference between the 

alternatives on the extent of designated ATV 

and OHV trails”. 

95. The Forest Service should consider that the 

conclusions concerning the effects of vehicle 

use on soils and vegetation seem to be based 

on assumptions rather than research or local 

data. 

Agency Response: The foundation of the 

conclusions concerning the effects of vehicle 

use on soils and vegetation are based on a 

combination of widely accepted publications, 

research, professional experience, and local 

data. The effects of road and trail construction 

and vehicle use on accelerated erosion and 

sediment rates are well established. The Forest 

referred to Meyers 2002, “Managing Degraded 

Off-Highway Vehicle Trails in Wet, Unstable, 

and Sensitive Environments”, when describing 

the Existing Conditions and the Environmental 

Consequences. Subwatershed vulnerability is 

derived from local land system inventories and 

inherent erosion ratings. 

96. The Forest Service should clarify the data 

presentation in the Soil & Water section of the 

EIS. 

Agency Response: Based on public comment 

the Forest adjusted the data presentation in the 

Soil and Water section between the DEIS and 

the FEIS. The Forest added the acre numbers 

to Soil and Water Indicators 1 and 2, while 

retaining the percentage figures. This should 

clarify exactly how many acres are affected 

and how the percentage numbers where 

calculated. 

97. The Forest Service should discuss the 

effects of the alternatives on the drinking water 

supplies in Management Area 3. 

Agency Response: There are no surface 

public drinking water supplies located on the 

Payette NF within Management Area 3. 

Wildlife 

98. The Forest Service should analyze lynx 

management using the most recent information 

and amend the Forest Plan to reflect this 

direction. 

Agency Response: The analysis of the effects 

of the Travel Plan on lynx used the most recent 

information available and described where this 

information may differ from current Forest 

Plan direction. In summer 2007, the PNF plans 

to work with the Lynx Biology Team to 

reevaluate the Forest’s lynx analysis areas 

(LAUs) and lynx habitat. The Lynx Biology 

Team is comprised of federal agency biologists 

and was chartered to develop the Lynx 

Conservation Assessment and Strategy (LCAS 

August 2000) to provide consistent 

information and guidance. Since its 

completion, the Lynx Biology Team has 

provided assistance with lynx habitat mapping 

and interpretation of the LCAS upon request 

by several National Forests. If amendments to 

lynx management are found to be warranted, 

then lynx direction in the Forest Plan may be 

modified in the future. 

99. The Forest Service should consider the 

health and safety aspects of leaving snags 

when roads and trails are constructed or 

reconstructed. 

Agency Response: As discussed in Comment 

43 above, the Travel Plan alternatives propose 

minor amounts or road and trail reconstruction 

or construction that would follow Forest 

Service and Forest Plan direction. Due to low 

numbers of snags in some area of the Forest, it 

may be beneficial to include direction to 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

6 – 72 Payette National Forest Travel Plan FEIS 

maintain snags during road and trail work, but 

safety concerns would take precedence in 

those cases. 

100. The Forest Service should consider the 

effects of increasing snowmobile activity on 

wildlife. 

Agency Response: The effects of over-snow 

motor vehicle use, particularly snowmobiles, 

were analyzed in the wildlife section of 

Chapter 3. Concerns over the effects of this 

activity to wildlife, were part of the reason for 

the development of Alternative D. 

Approximately 18 percent of the winter 

closures in this alternative were proposed to 

protect wildlife. 

101. The Forest Service should consider that 

human recreation has little effect on wildlife. 

Agency Response: The effects of human 

recreation on wildlife are disclosed in the 

wildlife section of Chapter 3. 

102. The Forest Service should consider the 

likelihood that potential lynx habitat 

surrounding McCall is not occupied. 

Agency Response: Information on lynx 

occurrence on the PNF was described in the 

DEIS and updated in the FEIS. 

103. The Forest Service should re-evaluate the 

suitability of areas identified as lynx habitat 

using more up-to-date information; and: 

104. The Forest Service should re-evaluate the 

potential effects of snowmobiling on lynx using 

the most up-to-date research; and: 

105. The Forest Service should amend the 

Forest Plan direction for lynx because no lynx 

are known to be present on the Forest and the 

most recent research would lead to different, 

probably smaller, delineations of potential 

habitat. 

Agency Response: See response to Comment 

98. 

106. The Forest Service should consider the 

relative effects of motorized versus nonmotorized recreation in winter on wildlife. 

Agency Response: These activities and the 

potential effects on wildlife species of concern 

were addressed in Chapter 3. 

107. The Forest Service failed to adequately 

analyze the effects of snowmobile use on 

wolverine and lynx habitat. 

Agency Response: The potential effects of 

snowmobile use on wolverine and lynx habitat 

were addressed in Chapter 3. 

108. The Forest Service should evaluate in an 

unbiased manner the effects of motorbike use 

on elk security as compared to the effects of 

hunting. 

Agency Response: Additional discussion was 

provided in the FEIS on the effects of 

motorized recreation activities and hunting on 

elk. 

109. The Forest Service should maintain 

wildlife migration corridors in all alternatives. 

Agency Response: Each alternative would 

allow for wildlife migration corridors, but the 

alternatives differ by the amount, extent, and 

connectivity of the corridors. See discussion of 

environmental effects on wildlife corridors in 

Chapter 3. 

110. The Forest Service should consider that 

the most recent research is inconclusive 

regarding the effects of human interactions 

with elk and elk habitat effectiveness. 

Agency Response: Elk habitat security and 

human impacts on elk were addressed in 

Chapter 3 of the DEIS and FEIS. 

111. The Forest Service should consider that it 

is the management policies of Idaho Fish & 

Game that are contributing to the harassment 

of big game species, rather than motorized 

traffic. 

Agency Response: See response to comment 

108. 

112. The Forest Service should reanalyze the 

currently closed roads to determine if the new 

elk security guidance in the 2003 Forest Plan 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

Payette National Forest Travel Plan FEIS 6 - 73 

would still require these roads to be closed 

year-round. 

Agency Response: Some closed roads were 

proposed to be opened in one or more of the 

alternatives. Elk security for each alternative is 

analyzed in Chapter 3of the DEIS and FEIS. 

113. The Forest Service should consider that 

OHV use during hunting season increases 

animal vulnerability to harvest. 

Agency Response: The effects of OHV use 

during hunting season were considered in the 

development of the alternatives particularly B, 

D, and E as evidenced by the number of OHV 

trails that would have seasonal closures to 

improve elk security.

114. The Forest Service should consider that 

OHV use throughout the year reduces the 

effectiveness of big game habitat. 

Agency Response: In the analysis of effects 

to elk security (Chapter 3), OHV and ATV 

trails were considered to have the same 

impacts as roads. 

115. The Forest Service should consider that 

the areas of wolverine denning habitat being 

protected in Alternative D are not those that 

should be the highest priority. 

Agency Response: The Forest Service met 

with Idaho Department of Fish and Game 

biologists to further understand their concerns 

about protection of potential wolverine 

denning habitat. Based on IDF&G’s concerns, 

an additional closure area (Bruin Mountain) 

was proposed in Alternative D in the FEIS. 

The wildlife analysis in Chapter 3 discusses 

the potential benefits of this additional closure.

116. The Forest Service should evaluate the 

closure of additional roads and trails within 

elk summer and winter range to protect the 

animals from motorized vehicle use, especially 

during hunting season. 

Agency Response: Closure of additional 

roads and trails within summer and winter elk 

range was analyzed as part of Alternative D in 

the DEIS and FEIS. Environmental effects are 

described in the wildlife section of Chapter 3.

117. The Forest Service should limit oversnow motorized use until impacts to wintering 

wildlife habitat can be fully assessed. 

Agency Response: Over-snow motorized use 

is limited to various degrees in each 

alternative. Alternative D would provide the 

greatest reduction and protection to wildlife. 

Firewood 

118. The Forest Service should consider that 

none of the alternatives provides sufficient 

access for firewood collection and that 

firewood cutting is a significant issue. 

Agency Response: The Payette agrees that 

access for firewood cutting is an important 

issue. However, this issue is outside the scope 

of route designation for travel management 

planning because it is handled by the Forest in 

a separate permitting process. In the DEIS and 

FEIS see Chapter 1 Section 1.10.2 NonSignificant Issues for a discussion of access for 

firewood cutting. 

119. The Forest Service should consider that 

much of the forest has burned in the last 30 

years and should be opened for fuelwood 

cutting. 

Agency Response: This concern is outside the 

scope of the travel management planning 

purpose and need (see response to Comment 

118 above). Access to areas for recovery of 

burned timber for fuelwood is covered under 

the firewood permitting process. 

Noxious Weeds 

120. The Forest Service should consider that 

motorized traffic on the forest contributes to 

the spread of noxious weeds. 

Agency Response: The potential for spread of 

noxious weeds by motorized traffic as a result 

of travel route designation is discussed in the 

DEIS and FEIS in Chapter 1, Section 1.10.2, 

Non-Significant Issues. 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

6 – 74 Payette National Forest Travel Plan FEIS 

Transportation System 

Management 

Trails - General 

121. The Forest Service should consider 

providing more opportunities for OHV trail 

riders because use is increasing. 

Agency Response: In Alternatives B, C, and E 

the Forest recognizes the need for additional 

ATV trails and provides for them in varying 

numbers of additional miles. In addition, 

Alternative C provides an additional mile of 

OHV trail (4-wheel drive road). In the 

“Recreation Opportunities” section of the 

FEIS, the Forest has identified a future 

opportunity for preparation and distribution of 

an ATV route map. 

While OHV use is increasing locally (almost 

67% in the past five years), only 15.6% of 

surveyed Forest visitors in 2003 indicated that 

motorized recreation was their primary reason 

for visiting the area, and of that 15.6 % only 

2.8 % of visitors were visiting for off-road 

vehicle use (most were in passenger cars). 

Given this level of use and declining Forest 

budgets, large increases in trail mileage are 

probably not needed or feasible at this time. 

122. Because motorized use is increasing the 

Forest Service should provide more motorized 

trails laid out in systems such as those 

recommended by the Blue Ribbon Coalition. 

Agency Response: Alternatives B, C, and E, 

presented in Chapter 2 of the FEIS, do provide 

ATV loop trail opportunities in response to 

requests from summer motorized 

recreationists. These alternatives increase the 

amount of ATV trail offered on the Forest. 

Alternative C, designed with the help of the 

Adams County commissioners, provides a 

number of large ATV loop systems using 

existing roads on the west side of the Forest. 

ATV trails are also available for use by 2-

wheel motorized users, although Forest staff 

understand that for many 2-wheel motorized 

riders ATV trails do not provide their preferred 

single-track riding experience. 

123. The Forest Service should keep all 

motorized trails open because they provide 

such a variety of opportunities for all users 

motorized and non-motorized. 

Agency Response: The Forest recognizes the 

valuable resource all trails, motorized and nonmotorized, provide to the public, and believes 

the miles of motorized trails through all 

alternatives provide an acceptable array of 

manageable (safe, affordable) opportunities. 

This reflects part of the purpose and need for 

the project. 

124. The Forest Service should consider that 

with the closure of all off-road travel and the 

reduction in available motorized trails, 

adverse impacts and user conflicts are likely to 

occur due to overuse on the remaining 

motorized trails. 

Agency Response: Some motorized trails 

already receive heavy use, especially on peak 

weekends during the summer. But many 

motorized trails on the Payette, receive little 

use because they are not known or are not 

located next to a popular campground or 

trailhead. Closing a popular trail within a 

popular area could concentrate use on the 

remaining trails. Closing some “little used” 

motorized routes in “low use” areas would 

have little effect on trail use patterns. 

125. The Forest Service should consider that 

restricting trail use to non-motorized due to 

lack of maintenance, or on those that receive 

little use or are considered “expert” is not 

valid. These trails have value to the public that 

uses them. 

Agency Response: The Forest understands 

that steep, challenging trails do provide an 

opportunity for some expert riders. When 

proposing different motorized and nonmotorized designations through the five 

alternatives in the FEIS, these opportunities, 

and their potential loss were analyzed and 

disclosed in Chapter 3. 

126. The Forest Service should open all trails 

outside the Wilderness to motorized use. 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

Payette National Forest Travel Plan FEIS 6 - 75 

Agency Response: The National Forest is not 

reserved for the exclusive use of any one 

group, nor must every use be accommodated 

on every acre. It is entirely appropriate for 

different areas of the National Forest to 

provide different opportunities for recreation. 

Recreation is not the dominant purpose for the 

creation of Wilderness, but rather the purpose 

is maintenance of wilderness characteristics. 

Most non-motorized recreational use is 

expected to occur outside the Wilderness. 

Therefore the Forest will manage for a balance 

of uses in the project area (which does not 

include the Wilderness). 

127. The Forest Service should evaluate all 2-

wheel trails to determine whether or not they 

can accommodate ATV traffic. 

Agency Response: The Payette recognizes the 

value of maintaining the single-track trail 

experience for 2-wheel motorized use only. 

Many 2-wheel motorized users prefer using 

single-track trail. All alternatives provide 4-

wheel ATV opportunities to some degree. See 

Chapter 2 Alternatives for a description of the 

ATV trail opportunities in each alternative. 

Trail Closure/Restriction 

128. The Forest Service should consider 

rerouting or improving maintenance on trails 

where there are water quality issues, rather 

than restriction to non-motorized use only. 

Agency Response: The Forest has included 

improvements or small areas of trail re-route to 

address water quality and other resource issues 

associated with motorized trails in many areas. 

However there are situations where it is 

impossible to reroute trails completely around 

meadows and other wet areas, and conversion 

to non-motorized use is the only option to 

protect these resources. 

Also, while some funding is available through 

grants and agreements with the State and other 

groups, the Forest budget for trail management 

is very limited. Many grants require that the 

Forest match with an equal amount of funds. 

Funds for trail relocation, which is a costly 

activity, divert monies that could perhaps be 

better used elsewhere. 

129. The Forest Service should not close 

motorized trails to gain non-motorized 

mileage, instead they should construct new 

non-motorized trails and keep all existing 

motorized trails. 

Agency Response: The Forest Service budget 

has been declining for many years. 

Construction of new trail, either motorized or 

non-motorized, is limited (due to funding) to 

approximately 1 mile a year. Partnerships and 

grants allow for some minor amounts of trail 

construction, reconstruction, and maintenance, 

but most require a matching contribution by 

the Forest Service. 

130. The Forest Service should consider that 

the needed skill level limits the use on 

“expert” OHV trails. 

Agency Response: The Agency agrees that 

expert trails provide a desired recreation 

experience. However, due to potential safety 

and liability issues the Forest is limited in the 

amount of such opportunities it can provide. 

The Forest has attempted to provide a diversity 

of motorized trail experiences for varying 

levels of riding ability. Also, many trail users 

are new to the area and may not realize the 

level of experience needed to negotiate a trail 

until they have ridden several miles. 

131. The Forest Service should consider that 

expert level trails are scarce and there is a 

growing population of experienced OHV users 

out there that desire that experience. 

Agency Response: See response to Comment 

130. 

Single Track Motorized Trails 

132. The Forest Service should provide more, 

not less, single track motorized trails. 

Agency Response: The Payette acknowledges 

the value of the single-track motorized trail 

and provides a system of trails we believe are 

manageable for the future in the alternatives 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

6 – 76 Payette National Forest Travel Plan FEIS 

analyzed in the DEIS and FEIS. Alternative A 

provides the most single-track motorized trail 

miles, and Alternative D provides the fewest. 

All alternatives meet the purpose and need 

statement which is to provide a “manageable” 

system of trails, which means an affordable 

and safe system. 

With limited financial resources available for 

trail construction the Forest must allocate 

money carefully. Only 2.8% of Forest visitors 

surveyed in 2003 came to the Forest with offroad vehicle riding as their primary activity. 

Even when considered as part of multiple 

activities, only 7.4% of surveyed visitors used 

off-road vehicles to reach their destination. In 

addition, most off-highway vehicle users in 

Idaho use ATVs (77%), while only 22% use 2-

wheel motorbikes (Achana 2005). All 

alternatives accommodate this level of use, 

when balanced against other motorized and 

non-motorized recreation opportunities on the 

Forest. 

133. The Forest Service should consider that 

the need for single track trail for mountain 

bike use is not being addressed on the Payette 

National Forest. 

Agency Response: The alternatives in the 

FEIS provide from 408 to 582 miles of singletrack motorized trail, and 495 to 614 miles of 

non-motorized, mostly single-track width, trail 

available for mountain bike use. In addition, 

the Central Idaho Mountain Bike Association 

(CIMBA) has proposed a trail system for 

future NEPA analysis in the Bear Basin area. 

This opportunity is listed under Management 

Area 6 in Chapter 2 of the EIS. 

134. The Forest Service should consider that 

single-track trails often end up being used by 

ATV users as well. 

Agency Response: Under all alternatives in 

the EIS ATV use is restricted to trails 

designated for ATV use and to open roads (for 

State licensed drivers). The Forest recognizes 

unauthorized ATV use occurs, but with 

enforcement, education and public selfpolicing will strive for improved compliance. 

Any use of other routes by ATV users is 

unauthorized and subject to action by Forest 

law enforcement personnel. 

Loop Trails 

135. The Forest Service should provide more 

loop trail opportunities. 

Agency Response: One of the main objectives 

of Alternative C summer management 

proposals was to provide ATV loop 

opportunities. Many of the proposed ATV trails 

on closed roads in Alternative C connect with 

open NFS roads to provide loop opportunities. 

Many single track and non-motorized trails can 

also provide “loop” trails when using open 

NFS roads as connectors. A section on “loop 

opportunities” was added to the FEIS Chapters 

2 and 3 to address trail “loop” opportunities. 

The Forest hopes to provide a map of ATV 

loops in partnership with local motorized user 

groups and Idaho State Parks & Recreation. 

Groomed Snowmobile Trails 

136. The Forest Service should use the most 

current lynx studies to assess the management 

of groomed snowmobile trails. 

Agency Response: The analysis of the effects 

of the Travel Plan, including groomed 

snowmobile trails, on lynx utilizes the most 

recent information available, and describes 

where this information may differ from current 

Forest Plan direction. This was assessed in the 

wildlife section of the FEIS in Chapter 3. 

137. The Forest Service should not decrease 

the amount of groomed snowmobile trail 

because use is increasing. 

Agency Response: The Payette National 

Forest works in conjunction with Idaho State 

Parks and Recreation and Valley County to 

develop and maintain the network of groomed 

snowmobile trails on the Forest. Routes are 

agreed to and maintained by Valley County 

through a 5 year cost share agreement signed 

by the Payette National Forest, Valley County 

and Idaho State Department of Parks and 

Recreation. 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

Payette National Forest Travel Plan FEIS 6 - 77 

While the numbers in Chapter 2 in Table 2-1. 

Forest Summary – Travel Opportunities by 

Alternative in the DEIS make it appear that the 

amount of groomed snowmobile trail is going 

down, in fact, they remain steady or are 

proposed to increase. Alternative A does not 

reflect the amount of trail that is currently 

groomed. Rather, Alternative A mileage 

reflects the amount that is authorized under the 

cost share agreement currently. However, the 

County has chosen not to groom this entire 

system for some years. Alternatives B and D 

reflect the amount of trail that is currently 

being groomed by the County. Alternatives C 

and E add a few routes requested through 

public input. 

138. The Forest Service should add new “link” 

trails to the existing system. 

Agency Response: Alternatives C and E 

propose adding new link trails to the groomed 

snowmobile trail system. These trails, by 

creating loop systems, would improve 

grooming efficiency and provide the loop 

experience recreation users desire. 

139. The Forest Service should consider 

eliminating the Snowmobile Overlook because 

it leads to intrusion violations on the Brundage 

Ski Area permitted area. 

Agency Response: The Payette recognizes 

that motorized over-snow intrusions have 

occurred within the non-motorized ski area 

boundaries, and will continue to monitor the 

area, patrol, sign, and educate snowmobilers 

on this issue in cooperation with the ski resort 

and local snowmobile groups. 

Closed Roads 

140. The Forest Service should provide turnarounds at gates and barriers on closed roads. 

Agency Response: Forest Service design 

policy requires a turnaround for the “critical 

vehicle” at all road closure points and at the 

terminus of a dead end road. The “critical 

vehicle” is the largest vehicle that is 

determined to use the road under the road 

management objectives. 

Actual physical closure or road obliteration is 

considered outside the scope of the travel plan 

purpose and need but may be considered on 

future site specific projects. This issue would 

be addressed as physical closures are 

implemented. 

141. The Forest Service should consider that 

by restricting access many families and seniors 

will no longer be able to participate in 

activities which they have historically enjoyed. 

Agency Response: The Forest will continue to 

maintain between 1,606 miles (Alternative A) 

and 1,638 miles (Alternative D) of open road 

to provide access for general forest recreation. 

With fall seasonal road closures between 1,134 

miles (Alternative A) and 1,123 miles 

(Alternative D) of road would remain open. 

Access for people with mobility problems is 

discussed in the DEIS, Chapter 1, pages 1-14 

through 1-15. 

142. The Forest Service should not close any 

more roads than those that are already closed. 

Agency Response: Access on Forest roads is 

restricted for a variety of reasons including 

resource problems, duplicate access, and 

wildlife protection. Cost of maintenance of 

open or seasonal roads versus the cost of 

maintaining closed roads is another factor in 

road management decisions. 

The Forest Service road maintenance program 

is not fully funded by Congress, and minimum 

maintenance funding for the current road 

system often does not occur. Adding more 

roads to the Forest Service system through 

adoption of unauthorized roads is not 

economically feasible. In addition, many 

unauthorized roads have design and location 

problems causing resource damage. These 

problems would have to be corrected before 

the roads could be added to the National Forest 

system adding to the financial burden. 

Unauthorized Roads 

143. The Forest Service should consider an 

alternative that addresses the loss of 

unauthorized roads in currently open areas. 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

6 – 78 Payette National Forest Travel Plan FEIS 

Agency Response: See response to comment 

0. 

144. The Forest Service should not designate 

any unauthorized routes open because it 

rewards the illegal construction of these 

routes. 

Agency Response: All alternatives incorporate 

some specific unauthorized travel route 

proposals, but beyond these specific proposals 

the remaining unauthorized roads will not be 

designated. Unauthorized travel routes have a 

variety of origins. Some are historical roads 

built to access timber or range facilities, some 

are from early mining and exploration, and 

some have been recently created by offhighway vehicle use. Under the 1988 Forest 

Plan, 33% of forest acres outside of Wilderness 

were managed as open to cross-country 

motorized travel, therefore travel was allowed 

on unauthorized routes within these open 

areas. 

Not all user created routes were created by 

unauthorized off-road use. Road and trail 

inventory information has been collected for 

some of the unauthorized routes found in the 

project area. This information is available in 

the Project Record. 

145. The Forest Service should recognize that 

most summer motorized users would only use 

the existing (unauthorized) road beds and 

would not drive “off-road” and not penalize 

them because of the few users who do cause 

resource damage off-trail. 

Agency Response: While it is no doubt true 

that recreationists would use the existing 

unauthorized route system to travel, adding 

this entire route system to the Forest’s System 

trail networks is not fiscally feasible or 

environmentally responsible. Funding for trail 

management is not sufficient to allow for the 

addition of hundreds of miles of new trail that 

would have to be maintained, relocated, etc. 

Therefore during the scoping period for travel 

management the Forest asked the public to 

help the Agency identify any of the 

unauthorized routes that are receiving enough 

use to make their addition to the National 

Forest trail system worth evaluation. 

146. The Forest Service should realize that 

creation and use of “unauthorized” routes is 

an indication of unmet demand for motorized 

recreation opportunities. 

Agency Response: Rather than being an 

indication of unmet demand, oftentimes these 

user-created unauthorized routes instead reflect 

a desire of the rider to explore new territory, 

test the limits of themselves or their machine, 

or to arrive at a destination by a more direct 

route than may already exist. 

The Payette feels the five alternatives provide 

a sufficient range of motorized and nonmotorized recreation opportunities at this time. 

Road & Trail Decommissioning 

147. The Forest Service should decommission 

roads or trails for every new mile of road or 

trail created. 

Agency Response: The Forest identified those 

areas in need of a high level of watershed 

protection in the 2003 LRMP as Management 

Prescription Categories 3.1 and 3.2 – Passive 

and Active Restoration and Maintenance of 

Aquatic, Terrestrial and Hydrologic Resources. 

Because management actions, including road 

and trail reconstruction, may only temporarily 

degrade watershed conditions it becomes 

necessary to decommission some road or trail 

for every new mile of road or trail created. For 

the remainder of the Forest it was not deemed 

necessary from a watershed standpoint to 

offset road and trail construction, although 

during future site-specific analysis road and 

trail decommissioning may be proposed. 

Jurisdiction 

148. The Forest Service should indicate roads 

that fall under other jurisdiction clearly on the 

maps so people can easily recognize them. 

Agency Response: In the DEIS and FEIS 

roads not under Forest Service jurisdiction 

were depicted using a different line symbol. 

The MVUM will adhere to agency-wide 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

Payette National Forest Travel Plan FEIS 6 - 79 

mapping standards which include displaying 

only roads that will be open to motorized 

travel. Roads under non-Federal jurisdiction 

that will remain open to motorized travel are 

distinguished by jurisdiction on the maps. 

Other non-Federal roads and non-system roads 

(referred to as “unauthorized roads” in the 

Travel Plan) will not be displayed on the maps, 

according to national direction. 

149. The Forest Service should maintain 

public access on roads managed under cost 

share agreements. 

Agency Response: The Forest Service has 

primary jurisdiction on roads covered by Cost 

Share Road Easements. The Forest Service 

retains traffic regulation authority over the 

roads. Therefore, the Forest Service 

determines, on a road-by-road basis, the level 

of management, including whether a road 

should be open or closed to motorized public 

use. The agency bases road management 

decisions on agency goals, Forest Plan 

direction, and funds available for road 

maintenance. When public use is allowed on 

such roads, the Forest Service is responsible to 

ensure that the public use does not materially 

interfere with the other landowner’s easement 

rights. 

Maintenance 

150. The Forest Service has not adequately 

considered the impacts from a lack of 

maintenance on the existing road network. 

Agency Response: Forest personnel check 

NFS roads during the course of carrying out 

their job duties and routinely report 

maintenance problems to the appropriate 

department. The Forest implements 

approximately 100 to 200 miles of scheduled 

road maintenance a year. The analysis in 

Chapter 3 of the DEIS for watershed 

conditions across the Forest addresses this 

concern. Soil and water indicators SWI 3, 6, 7, 

and 8 all are broad indicators of the potential 

for negative impacts due to road surface 

erosion and events such as culvert failure. 

151. The Forest Service should consider that 

trail maintenance has not been adequately 

funded for the past two decades, even with the 

existing system of trails. 

Agency Response: The Forest did consider 

trail funding and maintenance costs in the 

DEIS and FEIS and the effects are displayed in 

Chapter 3, Recreation – Effects of Alternatives, 

Cost to Program. 

152. The Forest Service should consider that 

lack of trail maintenance is a poor excuse for 

reducing the number of trails or limiting 

access. 

Agency Response: The issue regarding 

funding, which drives the Forest’s ability to 

carry out trail maintenance, is beyond the 

scope of this project. Congress authorizes 

Forest Service appropriations. The Forest is 

committed to using whatever funds are 

available or can leverage to implement the 

decision for travel management once it is 

adopted. The Forest makes appropriate use of 

all other sources of funding, and has a number 

of successful cooperative relationships with the 

state of Idaho and other partners. Volunteer 

agreements with user groups and others have 

proven successful in extending agency 

resources for trail construction, maintenance, 

monitoring, and mitigation. 

Costs in trail maintenance, as well as the need 

for trails to provide a satisfactory recreation 

experience to the motorized and non-motorized 

users, were both considered when proposing 

the future trail systems in all alternatives. The 

proposed system was not purely the result of 

finances, although budget was one 

consideration. 

153. The Forest Service should consider that 

reducing the number of trails available for 

motorized use may also reduce the amount of 

trail maintenance funds available through 

partnerships with the IDPR and other grant 

and volunteer efforts. 

Agency Response: The amount of funds 

available through partnerships and grants is 

dependent upon trail-specific projects and the 

ability of the Forest to match the grant funds 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

6 – 80 Payette National Forest Travel Plan FEIS 

rather than the total miles of motorized trail on 

the Forest. 

154. The Forest Service should consider that 

faulty design and maintenance of roads and 

trails are not the fault of the public but of the 

managing agency. 

Agency Response: The Payette does not 

consider Agency infrastructure or budget 

problems to be the fault of the public. 

However, the ability of the Forest to correct 

resource problems caused by faulty design and 

maintenance is limited by budget realities and 

must be considered when proposing viable 

road and trail management options. 

RS 2477 

155. The Forest Service should evaluate roads 

that it has closed since 1976 for potential RS 

2477 rights. 

Agency Response: The Forest Plan states that 

before taking any action to close or remove a 

road from the landscape, the Forest Service 

should evaluate the merits of an assertion of 

public right-of-way under R.S. 2477. To 

establish a right-of-way under R.S. 2477 

requires three tests as outlined in Forest 

Service Intermountain Region direction 

(Regional Forester 5510/2730 memo of 

February 12, 2001): 

3⁄4 It must be shown that the statutory grant 

of the right-of-way was accepted prior to 

inclusion of the land in the National 

Forest System (NFS), 

3⁄4 It must be shown that a highway had 

been constructed and dedicated to public 

use in accordance with applicable laws 

prior to inclusion of the land into the 

NFS, and 

3⁄4 It must be shown that the right-of-way 

has been continuously used and 

maintained as a public highway. If not, it 

may be deemed abandoned by applicable 

laws. 

The Forest Service cannot evaluate or concur 

with assertions for public rights-of-way 

without sufficient information to determine if 

any of these elements have been met. Without 

sufficient evidence of title, the Forest Service 

cannot recognize any claim of a real property 

interest in land under its administration. If the 

public has specific information that could help 

the agency evaluate the existence and validity 

of historic R.S. 2477 routes, even those the 

Forest Service may have closed or 

decommissioned prior to or post-1976, the 

agency could review past road closures and 

take appropriate action to re-establish historic 

routes. Without supporting evidence or a 

judicial determination of validity, the Forest 

Service may take action necessary to protect 

resources where there is a demonstrated, 

compelling, and immediate need to take such 

action. See FEIS Chapter 1, Section 1.10.2 

Non-Significant Issues for an in-depth 

discussion of R.S. 2477 Rights-of-Way. 

156. The Forest Service has not correctly 

addressed RS 2477 in the DEIS. The PNF 

lacks the authority to close roads or determine 

jurisdiction on roads. 

Agency Response: The Forest Service does 

not assume jurisdiction over legitimately 

established public roads. The Forest Service is 

not, through travel planning, proposing to 

physically remove from the landscape or 

prohibit public foot travel on any road or trail 

within the Payette National Forest. The agency 

is, however, proposing to manage motorized 

use on roads that may or may not be public 

under R.S. 2477. The agency has the authority 

to restrict the method of public travel--

specifically, motorized--on roads or trails 

across National Forest System lands. The issue 

not being addressed through travel planning is 

whether a large number of roads and trails for 

which assertions of public right-of-way under 

R.S. 2477 have been filed are indeed public 

roads. The Forest Service cannot evaluate or 

concur with assertions for public rights-of-way 

without sufficient information to determine if 

any of the elements required for establishment 

of title to the right-of-way have been met (See 

response to comment 155). See FEIS Chapter 

1, Section 1.10.2 Non-Significant Issues for an 

in-depth discussion of R.S. 2477 Rights-ofWay. 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

Payette National Forest Travel Plan FEIS 6 - 81 

Administrative Use 

157. The Forest Service should not use roads 

closed to the public under the guise of 

“administrative use”. 

Agency Response: As stated in the DEIS and 

FEIS administrative use will be limited, 

regulated, and done on approval of a line 

officer only. Exceptions to this are emergencies 

such as fire suppression, and search and rescue 

operations. 

Collaboration/Partnerships 

158. The Forest Service should make better 

use of grants and partnerships to fund 

maintenance of trails and to keep trails open. 

Agency Response: The Forest understands, 

values, and depends on partnerships to sustain 

the developed recreation and trails programs 

on the Forest. These partnerships and their 

contributions were discussed in the DEIS and 

FEIS in Chapter 3, Recreation – 

Environmental Consequences. 

159. The Forest Service should consider using 

volunteers and grants to help maintain trails, 

so that more trails may be kept open. 

Agency Response: The Forest does consider 

and use volunteers and other partners to the 

degree appropriate, as described in Chapter 3 

Recreation – Cost to Program, in the DEIS and 

FEIS. 

160. The Forest Service should consider using 

RPT grant monies and the Park N’Ski program 

to create more parking areas for winter 

recreation users. 

Agency Response: The Forest Service will 

pursue funds available through grants and 

partnerships once the Record of Decision is 

signed for this travel management analysis. 

161. The Forest Service should make better 

use of grants and partnerships to fund the 

snowmobile management program. 

Agency Response: Many aspects of the 

Forest’s snowmobile program management are 

funded through grants and partnerships with 

the Counties, Idaho Department of Parks and 

Recreation, and local snowmobiling clubs. 

Recreation Management 

Motorized Recreation – General 

Comments 

162. The Forest Service should clearly define 

when there is sufficient snow for over-snow 

motorized travel to be allowed. 

Agency Response: Defining over-snow 

seasons with dates are not feasible because of 

the varying weather patterns affecting the snow 

base. The best way to define sufficient snow 

for over-snow use is to state that the user must 

have sufficient snow coverage on the ground to 

maneuver and drive the motorized vehicle 

without causing any impact to the soils beneath 

the snow (no rutting or vehicle tracks). This 

information has been added to the FEIS in 

Chapter 2, Project Design Features. 

163. The Forest Service should keep motorized 

and non-motorized users separate so that nonmotorized users can enjoy nature. 

Agency Response: The alternatives analyzed 

in the DEIS and FEIS provide a range of both 

motorized and non-motorized opportunities in 

both summer and winter. Non-motorized use 

areas and trails are provided for enjoyment of 

nature in a quiet environment. 

164. The Forest Service should not close any 

areas to motorized recreation. 

Agency Response: See response to comments 

121, 126, 127, and 129. 

165. The Forest Service should consider that 

motorized use on the Forest has affected all 

Tribal treaty resources. 

Agency Response: The Nez Perce Treaty of 

1855 provides in part for: “the right of taking 

fish at all the usual and accustomed places... 

and or erecting temporary buildings for curing, 

together with the privilege of hunting, 

gathering roots and berries, and pasturing their 

horses and cattle upon the unclaimed lands.” 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

6 – 82 Payette National Forest Travel Plan FEIS 

The Nez Perce Tribe has reserved certain rights 

in their ceded territory. 

The Fort Bridger Treaty of 1868 for the 

Shoshone-Bannock Tribes provides that the 

Tribe “has the right to hunt on the unoccupied 

lands of the United States.” The ShoshoneBannock Tribes have reserved certain rights in 

their ceded territory. Also, the Tribes claim to 

have reserved guaranteed continuous use 

“rights” to utilize resources, off the reservation 

and within the region that encompasses and 

includes lands of the Snake and Salmon River 

watersheds. The ceded lands of the Nez Perce 

and the Shoshone-Bannock Tribes do not 

overlap. The Forest Service does not have the 

authority to adjudicate the meaning of these 

phrases. There are several possible legal 

theories, some of which conflict with one 

another. 

The Shoshone-Paiute Tribes have longstanding 

interest in the resources on the land that 

encompasses what is now the west half or the 

Payette National Forest. 

As the DEIS Chapter 3 Affected Environment 

acknowledged, illegal damage to cultural 

resource sites does occur on the Payette NF 

facilitated by illegal off-highway vehicle use. 

Although the Agency does not believe that this 

constitutes a violation of treaty rights, it is 

taking measures to reduce such damage. One 

way is by applying Forest Plan standards and 

guidelines for reduction of unsanctioned offhighway use. Another is the national OHV rule 

that prohibits unauthorized motorized uses. A 

third is this travel planning process to establish 

a system of roads, trails, and areas where 

motorized use is allowed. Through these and 

other means the Agency strives to protect the 

fish, wildlife, plant, and other natural elements 

the Treaties were designed to protect. 

166. The Forest Service should remove all 

motorized use from the National Forest 

because of the negative resource effects. 

Agency Response: This option would not be 

consistent with national policies or the Forest 

Plan. National Forests are managed by law for 

multiple use. They are managed not only for 

recreation, but also for timber, grazing, mining, 

and other specific uses. Uses must be balanced 

overall, rather than one given preference over 

another. 

167. The Forest Service should consider the 

impacts of non-motorized recreation as well as 

those of motorized recreation. 

Agency Response: The design of the five 

alternatives and analysis of environmental 

effects in the EIS in Chapter 3 consider 

impacts from both forms of recreation. 

168. The Forest Service should consider that 

people have been using motorized trails and 

roads for a long time and the trails and 

country they access have great value to them. 

Agency Response: The Agency recognizes 

these values. Public comment periods for the 

proposed action and the DEIS allowed for the 

public to bring forward roads and trails that 

have historical value to them. These roads and 

trails could then be analyzed for inclusion in 

one of the alternative proposals. 

169. The Forest Service should use public 

education to prevent resource damage by 

motorized trail users. 

Agency Response: The Forest has, and will 

continue to, promote “Tread Lightly” 

education objectives with continued signing 

and recreation patrol education with forest 

visitors. The Payette will also use the correct 

design standards for ATV, mountain bike, and 

2-wheel motorized trails when constructing 

and reconstructing trails. 

The Forest will work in conjunction with the 

popular and well-known Idaho Interagency 

OHV Coordinating Group, and the Statewide 

Ad Campaign organizations who continue to 

champion the “Stay on the Trails” campaign 

and promote responsible riding of motorized 

vehicles on all public lands. 

170. The Forest Service should provide as 

many motorized opportunities as possible 

because so many people, including the very 

young, the elderly, the disabled, and veterans, 

value them. 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

Payette National Forest Travel Plan FEIS 6 - 83 

Agency Response: The Forest has analyzed 

five alternatives in the FEIS. These alternatives 

provide an array of motorized and nonmotorized opportunities. Not all proposed 

changes were a result of damage caused by 

motorized use. Proposals are also tied to a 

“desired recreation experience” the forest 

wants to provide to recreational users, which in 

some cases is a quieter, non-motorized 

experience. 

While it is true that a recent Idaho Parks and 

Recreation Survey found that 52.4 percent of 

Idaho residents engage in some form of 

motorized recreation (Achana 2005), site 

specific statistics for the Payette (USDA Forest 

Service 2003b) indicated that 7.4% of visitors 

annually participate in off highway vehicle 

travel, with 2.4% visiting the Forest with off 

highway vehicle travel being their only form of 

recreation. Snowmobile travel accounts for 

6.4% of the total annual visits to the Forest. 

The most popular motorized activity on the 

Forest is driving for pleasure on roads, with 

22.3% of forest visitors participating annually. 

171. The Forest Service should completely 

overhaul the legislation and direction that 

have led to the current management course. 

Agency Response: The OHV rule, which 

guided the process the Payette National Forest 

used during the travel management analysis, is 

not legislation, but a federal rule. This rule 

went through several years of formulation and 

public involvement prior to becoming a rule. 

The final rule requires designation at the field 

level, with public input, of those NFS roads, 

trails, and areas that are open to motor vehicle 

use. The final rule would have no effect on 

users or on the environment until designation 

of roads, trails, and areas is complete for a 

particular administrative unit or Ranger 

District, with opportunity for public 

involvement. This final rule is essentially 

procedural and “overhauling” it is outside the 

scope of this EIS. 

172. The Forest Service should provide OHV 

recreation opportunities. 

Agency Response: The Forest provides OHV 

opportunities in all the alternatives to varying 

degrees. Alternative A provides the most 

opportunities with 645.4 miles of motorized 

trail, and 511,950 acres of area open to offroad motorized use. Alternative D provides the 

least with 468.9 miles of OHV trail. 

173. The Forest Service should consider that 

resource damage caused by OHV use usually 

only occurs in isolated areas. 

Agency Response: The Forest analyzed and 

considered affects to resources caused by OHV 

use in the EIS in Chapter 3 recreation, soils, 

wildlife, and fisheries sections. 

174. The Forest Service should consider that it 

is easier for snowmobiles to travel a distance 

from trailheads/parking than for nonmotorized users who need opportunities within 

a close distance from access points. 

Agency Response: This issue is addressed in 

Chapter 3 Recreation, Issue 2. Access points 

and proximity to them were an important 

factor in determining the proposed locations 

for winter non-motorized use areas. 

Non-motorized Recreation – 

General Comments 

175. The Forest Service should consider the 

value of non-motorized recreation 

opportunities to society and the environment. 

Agency Response: The Forest considered the 

importance of non-motorized recreation in 

both summer and winter months, and has 

addressed those needs, at different scales, in 

Alternatives A through E in the FEIS. 

176. The Forest Service should provide a 

balance between motorized and non-motorized 

recreation opportunities. 

Agency Response: The Forest provided for 

both motorized and non-motorized trail 

opportunities across the Forest in summer and 

winter months. However, opportunities were 

not allocated on a percentage basis, but instead 

to provide for both experiences. 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

6 – 84 Payette National Forest Travel Plan FEIS 

People’s opinion on what constitutes a 

“balance” between these uses is highly 

variable. The alternatives provide a mix of 

motorized and non-motorized opportunities. 

The Deciding Officer can choose any of the 

five FEIS alternatives or a combination of 

alternatives. 

177. The Forest Service should consider that 

motorized and non-motorized recreation is 

often incompatible. 

Agency Response: The Forest has provided a 

mix of motorized and non-motorized routes 

and areas in the Alternatives described in 

Chapter 2 of the DEIS and FEIS. Some areas 

provide a mostly motorized experience, such 

as is found in Management Area 3, described 

on page 2-21 in the FEIS. Other areas such as 

Management Area 13 (DEIS, p. 2-59) provide 

a more non-motorized experience. Across the 

project area (the Forest not including 

Wilderness), the experience is generally a mix 

of motorized and non-motorized reflecting the 

multiple use policy that guides the Agency. 

178. The Forest Service should consider that 

non-motorized trails tend to be under-utilized. 

Agency Response: Data collected during the 

National Visitor Use Monitoring study 

conducted in 2003 on the Payette indicate that 

a majority of recreation on the Forest is nonmotorized. In the same study perception of 

crowding also shows that of surveyed users, 

motorized and non-motorized, 65% feel there 

is “hardly anyone there”. On a scale of 1 to 10, 

85% of surveyed visitors perceived crowding 

as less than a 5. All areas of the Forest, 

including developed campsites, are not 

perceived as over crowded or even crowded by 

most visitors. It appears that motorized and 

non-motorized recreation opportunities, 

including non-motorized trails, are not being 

fully utilized. This lack of crowding (relatively 

low utilization) is considered a positive 

attribute and valuable drawing point for 

recreation on the Forest. 

Access - General 

179. The Forest Service should consider that 

public access is an important resource for 

future generations. 

Agency Response: Access to the Forest is 

maintained in various degrees in all five 

alternatives in the FEIS. The selecting official 

will have five to choose from to provide access 

for the future. 

180. The Forest Service should consider that a 

large portion of the population must use 

motorized vehicles to access the forest because 

of physical limitations. 

Agency Response: Comment acknowledged. 

All alternatives provide a diversity of access 

options including open roads and motorized 

trails for those with physical limitations. The 

selecting official will have the choice of the 

five Alternatives in respect to access by 

motorized means. 

181. The Forest Service should consider that 

providing a broad spectrum of recreation 

opportunities is good for the local economy. 

Agency Response: All alternatives presented 

in the DEIS and FEIS provide for a broad 

spectrum of motorized and non-motorized 

recreation opportunities. Chapter 2 in the DEIS 

and FEIS describes the alternatives. 

Economics are discussed on page 1-17 in the 

DEIS. The discussion of the impact of travel 

management on the economy has been 

expanded in the FEIS (See Chapter 2 in the 

FEIS). 

182. The Forest Service should consider that 

providing a broad spectrum of recreation 

opportunities disperses use and increases 

safety. 

Agency Response: See response to Comment 

178. The lack of crowding indicates that use is 

fairly dispersed and most areas of the forest are 

safe. In some areas, particularly around 

popular camp spots, trailheads, and parking, 

there may be sufficient crowding that forest 

users need to use care to have a safe 

experience. See Chapter 3, Recreation for a 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

Payette National Forest Travel Plan FEIS 6 - 85 

discussion of the effects by alternative on 

crowding and safety. 

183. The Forest Service should continue to 

allow access using the 1994/1995 travel map 

which the public is used to and finds to be 

adequate. 

Agency Response: The 1994/95 travel map, as 

modified by the BackRoads map, is one of the 

alternatives considered in the DEIS – 

Alternative A, No Action (DEIS, p. 2-9). This 

alternative is described in Chapter 2 of the 

DEIS and analyzed in Chapter 3 of the DEIS. 

184. The Forest Service should not limit access 

to any type of recreation. 

Agency Response: The Forest Service 

believes that the Agency should provide access 

for both motorized and non-motorized users in 

a manner that is environmentally sustainable 

over the long term. The National Forest 

System (NFS) is not reserved for the exclusive 

use of any one group, nor must every use be 

accommodated on every acre. It is entirely 

appropriate for different areas of the National 

Forests to provide contrasting opportunities for 

recreation. 

185. The Forest Service should consider that 

there is a difference between the remote 

backcountry, which may still be accessed by 

road, and Wilderness which is entirely nonmotorized. 

Agency Response: The Wilderness is not part 

of the project area for this travel management 

planning. The primary purpose of Wilderness 

is preservation of an area where evidence of 

man is minimal to non-existent rather than as 

an area for extensive non-motorized recreation. 

Types of use designations allowed in 

wilderness are already decided by legislation 

(Wilderness Act). Therefore the Wilderness 

was not included in the project area. 

The analysis area does include many areas of 

remote ground accessible by road, and 

motorized and non-motorized trail. The 

Alternatives presented in the DEIS and FEIS 

generally retain access to all areas although the 

balance of motorized versus non-motorized 

access may vary by alternative. 

Separate Use 

186. The Forest Service should consider that 

non-motorized recreation provides the most 

resource protection and therefore motorized 

access should be limited. 

Agency Response: The Payette does not agree 

that motor vehicle use should be allowed only 

when it can be clearly proven to be harmless to 

the environment. While resource effects should 

be minimized, the importance of providing a 

broad spectrum of recreation opportunities, 

including opportunities for motorized use, is 

recognized. See 36 CFR §212.55, Criteria for 

designation of roads, trails, and areas, of the 

national motor vehicle use rule (Federal 

Register 2005: 70FR68264) for a complete 

listing of criteria the Deciding Officer must 

evaluate prior to making his or her selection 

for route designation. 

187. The Forest Service should provide more 

non-motorized areas within easy access 

distance from major roads and parking areas. 

Agency Response: The Forest considered nonmotorized areas within easy access as one of 

the major recreation issues, and analyzed it in 

the DEIS and FEIS, Chapter 3 – Recreation 

(Recreation Issue #2). 

188. The Forest Service should continue to 

provide a winter non-motorized area in Bear 

Basin for use by Nordic skiers. 

Agency Response: The Bear Basin nonmotorized area was considered and analyzed in 

differing amounts of acres in Alternatives B, C, 

D, and E in the FEIS. 

189. The Forest Service should consider that 

separate use areas provide a number of 

benefits including a safer recreation 

experience and more protection of natural 

resources. 

Agency Response: The Forest considered 

safety as a major recreation issue and analyzed 

it in Chapter 3, Recreation – Environmental 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

6 – 86 Payette National Forest Travel Plan FEIS 

Consequences section: Recreation Issue 4: 

Safety. 

While research generally supports the notion 

that non-motorized recreation has fewer 

resource impacts than motorized use, this is 

not always the case. In some instances nonmotorized use causes comparable or even 

greater impacts than motorized use. Impacts to 

trails from horseback riding, hiking, and biking 

can cause rutting on trails, especially during 

the wet season. Recreational use can cause 

disturbance and adverse impacts to wildlife. 

The effects of motorized versus non-motorized 

use is addressed by all natural resources within 

Chapter 3. 

190. The Forest Service should consider that 

motorized and non-motorized use is not 

compatible because the noise and air pollution 

from motorized vehicles is not amenable to 

non-motorized recreationists. 

Agency Response: The Forest recognizes that 

some types of recreation experiences need 

separation of uses for the user to fully enjoy 

their opportunity. Therefore, throughout the 

alternatives analyzed in the DEIS and FEIS, 

the Forest did consider allocating use in some 

areas solely to non-motorized use, to provide 

for some reduction in the potential for conflict 

of uses, and in some cases, improved safety of 

the users. 

191. The Forest Service should consider that 

there is currently not enough area designated 

for non-motorized recreation on the Payette. 

Agency Response: Alternative D analyzed in 

the DEIS and FEIS was developed to address 

concerns for more non-motorized recreation 

opportunities in summer and winter. Additional 

winter non-motorized areas were added to 

Alternative D in the FEIS to address wildlife 

habitat concerns. 

192. The Forest Service should consider the 

many people that utilize the areas available for 

snowmobiling on the Payette NF. 

Agency Response: Perception of crowding as 

measured in the National Visitor Use 

Monitoring Study in 2003 on the Payette 

National Forest indicated that only 15% of 

surveyed visitors (summer and winter) felt that 

the area they visited was crowded or 

overcrowded. Most survey respondents (65%) 

indicated they experienced little to no 

crowding. 

While popular snowmobile play areas such as 

Goose Lake and Brundage Reservoir, or 

trailheads and trails immediately adjacent to 

parking areas, may experience some crowding 

on busy days, for the most part the current 

available open area can accommodate the level 

of use the Payette is receiving. Alternatives B 

and D do reduce the available area open to 

snowmobiles. With the exception of the 

Granite Mountain closure, the areas selected 

for closure to motorized use are not expected 

to heavily impact or cause crowding of 

snowmobiles. Alternative C analyzed in the 

DEIS increases the amount of area open to 

snowmobiling. 

193. The Forest Service should consider that 

definable boundaries and separate use areas 

provide the best experience for the nonmotorized recreationist in winter. 

Agency Response: The Forest did consider 

and has proposed several separate use areas for 

non-motorized winter recreation in the action 

alternatives presented in the FEIS. Chapter 3, 

Recreation provides documentation of the 

analysis of these areas and assesses the 

boundaries for ease of recognition. 

194. The Forest Service should consider that 

there are not as many non-motorized 

recreationists as motorized and that there are 

already several areas set aside for nonmotorized use, both summer and winter. 

Agency Response: Payette National Forest 

recreation data collected in 2003 indicate that 

most of the recreation use on the Forest is nonmotorized rather than motorized with 15.6 

percent of respondents stating that their 

primary activity was some form of motorized 

recreation (includes off-highway vehicle travel 

– 2.8%, driving for pleasure on roads – 6.2%, 

snowmobile travel – 5.4%, motorized water 

travel – 1.0%, and other motorized land/air 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

Payette National Forest Travel Plan FEIS 6 - 87 

activities – 0.2%). The remainder of 

respondents did not list motorized activities as 

the focus of their recreation on the Forest 

although they may have used some form of 

motorized vehicle to access their primary 

activity recreation. (USDA Forest Service 

2003b NVUM) 

195. The Forest Service should consider a 

seasonal closure in the area utilized by the 

Brundage Snow Cat special use permit. 

Agency Response: The permitted area for the 

Brundage Snow Cat operation is independent 

of non-motorized recreation area designation. 

Parts of the permitted area are proposed for 

closure to motorized use, and other parts 

would remain open. In Alternative A, 

representing the existing situation, most of the 

permitted Snow Cat skiing area is also open to 

motorized use. Generally, designation of a 

seasonal closure would create more confusion 

for the public and more managerial costs for 

the Forest. 

196. The Forest Service should consider that 

excluding snowmobiles from portions of the 

Brundage Mountain Snow Cat skiing permitted 

area is essential for the business to survive. 

Agency Response: Alternatives B, C, D, and 

E all close a portion of the area currently under 

Special Use Permit to Brundage Snow Cat to 

allow for additional non-motorized over-snow 

back-country ski opportunities. Permitees must 

consider existing land use allocations when 

applying for a Special Use authorization with 

the Forest. The Forest is not responsible for 

modifying existing land uses to make any 

outfitter or guide operation more viable. That 

is the responsibility of the permittee, and one 

of the many considerations their business must 

take into consideration when applying for a 

Special Use Authorization. 

197. ...(Continue 196) .For the safety of the 

program’s patrons. 

Agency Response: Safety is discussed in the 

FEIS in Chapter 3, Recreation, Recreation 

Issue 4, Safety. The issue of skier safety in 

areas of snowmobile use is one facet discussed 

under this issue. Effects by alternative on 

safety are analyzed in Chapter 3. 

198. The Forest Service should consider that 

snowmobiles have a much larger range than 

human-powered recreationists and can quickly 

travel by any non-motorized areas. 

Agency Response: See response to comment 

187. 

199. The Forest Service should evaluate 

whether or not the non-motorized areas 

created would be large enough and distant 

enough from areas of motorized use to provide 

quiet and a feeling of solitude. 

Agency Response: This issue is evaluated in 

the FEIS, Chapter 3, Recreation, Issue 5: 

Recreation Opportunity Spectrum (ROS). The 

analysis discusses the impacts of the 

alternatives on the ROS for both summer and 

winter. One aspect of ROS classification is the 

probability that the user will experience 

solitude and tranquility. 

200. The Forest Service should create 

exclusive use areas for snowmobilers as well if 

they are going to do so for non-motorized use. 

Agency Response: Areas that are heavily 

used by snowmobile do tend to end up as 

exclusive use areas for snowmobilers, due to 

safety concerns, noise, and other impacts many 

non-motorized users seek to avoid. However, 

in areas of more dispersed motorized use, 

conflicts between the two uses are minimal, 

and therefore multiple use can be emphasized. 

Given the large acreages of the Payette open to 

over-snow motorized use under all the 

alternatives considered in the travel plan (57 % 

to 73 %), the need for areas dedicated to 

exclusive motorized use has not been widely 

expressed or proven as necessary. 

Shared Use 

201. The Forest Service should consider that 

additional access is needed for ATV riders. 

Agency Response: See response to comments 

0, 121, and 122. 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

6 – 88 Payette National Forest Travel Plan FEIS 

202. The Forest Service should consider that 

shared use areas and routes are not enjoyable 

or safe for non-motorized recreationists. 

Agency Response: See response to comment 

189. 

203. ...(Cont.202) Because snowmobiles are 

able to access areas they couldn’t in the past, 

and they can track up an area in minutes. 

Agency Response: The action alternatives 

presented in the FEIS all propose some areas 

of closure to motorized over-snow use. These 

areas are proposed partly to provide the nonmotorized public with a snowmobile free 

untracked powder experience. 

204. The Forest Service should consider that 

Nordic skiers and snowmobiles cannot safely 

share the same trails. 

Agency Response: See response to comment 

189. 

205. The Forest Service should consider that 

creating separate use areas for non-motorized 

recreation is a form of discrimination. 

Agency Response: Part of the purpose and 

need for the project was to reduce conflict 

between uses. A valid method of 

accomplishing this is by separating motorized 

and non-motorized use areas and routes. The 

Forest believes that we should provide for both 

motorized and non-motorized users. However, 

the Forest is not reserved for the exclusive use 

of any one group, nor must every use be 

accommodated on every acre. It is entirely 

appropriate for different areas of the Forest to 

provide different opportunities for recreation. 

The best method for making choices on the 

designation of areas and routes for use is 

through involvement and planning with local 

interested parties as is being done for this 

travel management analysis. 

206. The Forest Service should consider that 

the areas open to snowmobiling currently are 

crowded and that reducing the area open will 

increase the problems caused by crowding. 

Agency Response: While crowding can occur 

on some of the groomed snowmobile routes, it 

is not common in the play areas. Payette Forest 

data (USDA Forest Service 2003b) do not 

indicate that forest users - both summer and 

winter - are feeling yet that the Forest is 

crowded. Most survey respondents indicated 

that on a scale of 1 to 10 there was “hardly 

anyone there” (over 50%). While some popular 

areas may be crowded on high use days 

(weekends/holidays), recreationists are 

dispersed sparsely throughout the vast majority 

of the forest. 

The alternatives analyzed in the FEIS provide 

a range of area open to snowmobiling, with 

Alternative C providing the most open area. 

207. The Forest Service should consider that 

non-motorized recreationists typically only use 

areas within 4 miles of a parking lot or road, 

so only areas that meet these criteria should be 

set aside for exclusive non-motorized use. 

Agency Response: While it is true that back 

country skiers who do not own snowmobiles 

can only reasonably access areas within 3 to 4 

miles of a parking area, some back country 

skiers do use snowmobiles to access skiable 

terrain. Alternatives B, C, and D in the DEIS 

all include some areas designated for nonmotorized winter use that can only be accessed 

by snowmobile. This serves to disperse use by 

back country skiers. 

The Forest analyzed this issue under 

Recreation Issue #2 in Chapter 3 of the FEIS, 

Recreation – Environmental Consequences. 

208. The Forest Service should consider that 

motorized and non-motorized use conflict in 

winter is very real and not just a perception. 

Agency Response: The Forest acknowledges 

that conflict among motorized and nonmotorized uses is occurring, particularly in 

winter. This issue is addressed in the FEIS, 

Chapter 3, Recreation Issue 2. 

Restricted Off-road Motor Vehicle 

Use 

209. The Forest Service should consider that 

ATVs on existing unauthorized routes and on 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

Payette National Forest Travel Plan FEIS 6 - 89 

skid trails are the only means of forest access 

that some can physically use. 

Agency Response: Many unauthorized roads 

were recommended for conversion to system 

roads or trails and were analyzed in the 

alternatives in the FEIS. Opening all 

unauthorized roads would not meet the 

purpose and need for this travel plan. 

210. The Forest Service should consider that 

OHV use should be kept to open roads and 

motorized trails. 

Agency Response: All action alternatives do 

limit OHV use to open roads and designated 

motorized ATV trails. The action alternatives 

do allow for limited motorized use in a 300’ 

corridor along open roads and 100’ of 

motorized trails for dispersed camping so long 

as there are no negative impacts to resources. 

211. (Cont. 210) Because it causes resource 

damage. 

Agency Response: See comment response 

210. 

212. (Cont. 210) Because it protects big game 

vulnerability and reduces hunter conflicts. 

Agency Response: See comment response 

210. 

213. The Forest Service should consider that 

problems caused by off-road vehicle use are an 

enforcement problem and not all users should 

be punished for the few that abuse the 

privilege. 

Agency Response: Forest Service law 

enforcement personnel play a critical role in 

ensuring compliance with laws and 

regulations, protecting public safety, and 

protecting National Forest resources. The 

travel plan will not increase the agency’s 

budget or the number of law enforcement 

officers. Proposed travel management must be 

reasonable to enforce given the existing and 

anticipated law enforcement budget and 

personnel level. 

The Forest did not receive any substantive 

public or internal comments indicating that the 

Forest should consider opening any areas of 

the Forest to off-road motor vehicle use in 

summer except for dispersed camping, and for 

requests for firewood collection, which will be 

covered under a separate permitting process. 

Corridors 

214. The Forest Service should consider the 

creation of some open corridors on the Krassel 

Ranger District, as has been done on the rest 

of the Forest, because I see no valid reason for 

closing the entire District. 

Agency Response: Alternative A in the DEIS 

and FEIS analyzed a 300 foot corridor on the 

Krassel Ranger District. The Deciding Officer 

could select some open corridors on the 

District. 

215. The Forest Service should consider that 

300 foot corridors will not provide adequate 

opportunities for dispersed camping. 

Agency Response: Three hundred foot 

corridors should accommodate most demand 

for dispersed camping. In high use areas or 

areas with sensitive resources the Forest may 

identify additional dispersed campsites beyond 

the 300 foot corridor. Designated dispersed 

campsites will be identified on the MVUM as 

well. 

216. The Forest Service should create 

designated dispersed camping sites rather than 

creating corridors for dispersed camping 

along motorized routes. 

Agency Response: The Interdisciplinary Team 

for this project did discuss designating all 

dispersed campsites on the Forest. The team 

determined identifying, signing, and 

enforcement of all designated dispersed sites 

was not feasible or cost effective. 

Identification of Forest corridors were deemed 

more cost effective and posed little risk to 

resource values. In areas where sensitive 

resources have been identified, including 

northern Idaho ground squirrel habitat on the 

west side, the Lake Creek area on the McCall 

Ranger District, and the Krassel Ranger 

District on the east, the Forest would designate 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

6 – 90 Payette National Forest Travel Plan FEIS 

dispersed sites if one of the action alternatives 

is selected. These sites would be located on the 

MVUM. For the future, the Forest retains the 

authority to prohibit dispersed camping in 

areas where unacceptable resource damage 

occurs. Such areas would be added to the 

MVUM. 

Multiple Use 

217. The Forest Service should consider that 

the National Forest belongs to the people and 

not to the agency and therefore should be 

completely accessible by the public in the 

manner of their choosing; and: 

218. The Forest Service should consider that 

all of the Forest should be open for multiple 

uses; and: 

219. The Forest Service should consider that 

the Forest is for the people. 

Agency Response: Comments are 

acknowledged. 

Maps, Signs 

220. The Forest Service should consider that 

there may not be adequate funds to sign all 

designated routes which will cause confusion 

for the public. 

Agency Response: The Forest is committed to 

allocating funds for on-the-ground signing 

efforts once the travel plan is complete. 

Education, including on-the-ground signing of 

routes and enforcement activities, will be 

accomplished through leveraging limited funds 

and personnel with partners and other funding. 

Although not required under the new travel 

rule, which states under Subpart A, 36 CFR 

261.13 that the MVUM is the only requirement 

for enforcement of travel restrictions on the 

ground, travel route status will be signed on 

the ground to the greatest extent possible. It 

will also be the responsibility of the user to 

have and understand the motor vehicle use 

map displaying all of the open motorized 

routes on the Forest. 

221. The Forest Service should consider that 

signing open routes only could be very 

confusing to the public. 

Agency Response: The new national policy 

for managing OHV use on National Forest 

System lands establishes the same signing and 

mapping policy for all Forests across the 

nation, therefore making it less confusing. 

Once all Forests have completed the travel 

planning process, mapping for roads and trails 

will follow this policy displaying only open 

motorized routes. 

The MVUM will be the legal document used 

to enforce the Travel Management Plan. This 

will be the case on all National Forests under 

the new rule. 

222. The Forest Service should consider other 

methods besides signing or gates to indicate 

that routes are closed. 

Agency Response: The Forest will continue to 

utilize some barrier rocks, gates, and berms to 

close off roads, but policy will state that only 

the posting of open motorized roads and trails, 

and production of a motor vehicle use map, 

available to the public, is required to enforce 

the closures. See response to Comments 218 

and 219. 

223. The Forest Service should display the 

permitted boundary for the Brundage Snow 

Cat Program Special Use Permit. 

Agency Response: Special uses, including the 

Brundage Snow Cat permit, are addressed in 

Chapter 1 of the FEIS. No alternative is 

developed specifically for the Brundage Snow 

Cat permit. There are no other special use 

permit areas displayed on any of the maps and 

it would not be consistent to display the 

permitted boundary of only one of numerous 

special use permit holders. Alternatives B, C, 

D, and E all have winter non-motorized areas 

on lands within the permitted boundary for the 

Brundage Snow Cat operation. 

224. The Forest Service should consider that 

the “closed to motorized use unless posted 

open” policy is both agency and public 

friendly. 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

Payette National Forest Travel Plan FEIS 6 - 91 

Agency Response: Comment is 

acknowledged. 

225. The Forest Service should realize that 

having the MVUM map as the main public 

education tool and enforcement mechanism is 

not very user friendly. 

Agency Response: The Forest will continue to 

use signs to provide information and inform 

users. However, the Forest has found that 

posting routes as open or closed has often not 

been effective in controlling use. Signs have 

proven difficult to maintain, and are often 

subject to damage and vandalism. Therefore, 

the Agency has decided to place more 

responsibility on the user to obtain a copy of 

the MVUM and to remain on designated routes 

or designated areas displayed on the MVUM. 

226. The Forest Service should consider that 

better winter recreation maps showing 

topographical features are needed for the 

FEIS. 

Agency Response: The Forest is providing a 

Forest winter recreation map in the map packet 

accompanying the FEIS, and the Record of 

Decision, if different. However, to be 

manageable, these maps will still be at a large 

enough scale that fine detail, such as 

topographical lines, will not be displayed. 

Game Retrieval 

227. The Forest Service should consider that 

the rules governing game retrieval are not 

clear in the DEIS. 

Agency Response: Changes to game retrieval 

distances apply to motorized use only. There 

are no proposed changes to any type of nonmotorized methods of game retrieval including 

equestrian access and wheeled deer carts. 

228. The Forest Service should consider that 

some people are physically unable to retrieve 

game except by motorized means. 

Agency Response: There is no legal 

requirement to allow people with disabilities to 

use OHVs or other motor vehicles on roads, 

trails, and areas closed to motor vehicle use 

when such access is not open to the general 

public. All hunters will be responsible for 

assuring that they are able to retrieve game that 

they have killed by authorized means. 

229. The Forest Service should not allow an 

exception for travel off-designated routes for 

game retrieval. 

Agency Response: While the national rule 

regulating motor vehicle use does allow for 

creation of corridors for game retrieval, use of 

this provision is not encouraged. The Regional 

Forester in Region 4 has determined that 

regional policy will not allow creation of 

corridors specifically for game retrieval. ID 

Fish and Game also does not support travel off 

designated routes for game retrieval. 

Equestrian Use 

230. The Forest Service should consider that it 

is unclear if access to established trailheads 

for horse trailers has been maintained. 

Agency Response: No established developed 

recreational trailheads were eliminated under 

any alternative. Some unauthorized roads will 

not be designated for use, which could 

potentially eliminate some parking and 

informal trailheads along these routes. Popular 

dispersed parking areas were marked by the 

public and recreation resource specialists for 

retention as parking areas. They are shown on 

the FEIS maps for Alternative E. 

User Education 

231. The Forest Service should be proactive in 

user education for the new travel management 

plan to be effective. 

Agency Response: See response to comment 

232. 

Enforcement 

232. The Forest Service should consider that 

the Selected Alternative will have to be 

enforced for it to be effective. 

Agency Response: The Forest is committed to 

proceed with education and enforcement of the 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

6 – 92 Payette National Forest Travel Plan FEIS 

travel management decision using articles in 

the local papers, signing, extra on-site patrol, 

and by producing and making available maps 

of both summer and winter motorized 

designations. The Payette has recently 

recruited and filled a second law enforcement 

officer position. The Forest will also rely on 

continued cooperation with the Idaho 

Department of Fish and Game, the public, and 

local county law enforcement. 

233. The Forest Service should consider that 

user groups may be willing to help with selfpolicing and enforcement of the new travel 

plan. 

Agency Response: Forest staff acknowledge 

how important the use of volunteers and user 

groups will be to the success of the new travel 

designations. The Payette will encourage and 

rely on help from all users to implement the 

new designation decision. 

234. The Forest Service should consider that 

most problems with illegal ATV use occur 

during hunting season and could be mitigated 

by stepping up enforcement at this time. 

Agency Response: The Forest does have 

additional enforcement officers during hunting 

season. Typically the Idaho Department of Fish 

and Game provides help during this time of 

year. However, even with additional 

enforcement officers the Forest is too large to 

adequately patrol. 

235. The Forest Service should consider that 

the Department of Fish & Game is authorized 

to help with enforcement during the hunting 

season. 

Agency Response: The Payette acknowledges 

this role and works closely with the IDF&G 

during that time. 

Trailheads/Parking 

236. The Forest Service should analyze 

parking and trailhead management as a 

significant issue because existing locations are 

currently at full or over-full levels of use; and: 

237. The Forest Service should consider that 

the increase in Forest visitors is leading to 

congestion and overcrowding at parking areas 

and trailheads, particularly in winter. 

Agency Response: The scope of travel 

management planning on the Payette does not 

include trailhead and parking construction. The 

project is designed to designate a system of 

roads, trails, and areas for motorized use. New 

parking and trailhead facilities would be 

assessed in separate site-specific NEPA 

analyses, and will continue to be assessed in 

the future as the need arises. 

238. The Forest Service should not analyze a 

parking facility on Smokey Boulder Road 

because adjacent private property owners are 

experiencing vandalism and trespass from 

forest visitors in the area already. 

Agency Response: There are no proposals 

currently under consideration for any parking 

facility along Smokey Boulder road. If 

construction of a parking facility on the 

Smokey Boulder Road is analyzed by the 

Forest, public input will be solicited during the 

specific NEPA process. Comments and 

concerns about this potential facility are best 

directed to the Forest at that time. 

Special Use Permits 

239. The Forest Service should consider that it 

is not always understandable to the public that 

exemptions to the travel plan route 

designations can be made for special use 

permits and administrative use. 

Agency Response: See response to comment 

240. 

240. The Forest Service should make it clear 

that holders of special use permits may be 

given motorized access if needed to carry out 

the terms of their permit. 

Agency Response: The FEIS discusses how 

special use permits are handled and their 

relationship to travel planning. Any route or 

area needed to carry out a special use permit 

will be analyzed and, if deemed necessary, 

authorized under the permit. 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

Payette National Forest Travel Plan FEIS 6 - 93 

Definable Boundaries 

241. The Forest Service should consider the 

CIRC proposal presented during scoping 

because it has the most identifiable and 

enforceable boundaries. 

Agency Response: Every effort has been made 

to place winter closure area boundaries on 

definable topographical landmarks. However, 

it is not always possible to meet this goal and 

stay within the desired area. Some signing will 

be needed for closure areas, regardless of the 

alternative selected. For instance, many closure 

areas abut the Forest boundary. Usually this 

boundary is not recognizable, particularly in 

winter when property tags may be buried in 

snow. The Central Idaho Recreation 

Coalition’s (CIRC) proposal was considered in 

the development of both Alternatives B and D 

in the DEIS. However, other comments from 

other winter recreation groups were also taken 

into account. 

242. The Forest Service should ensure that 

areas designated for non-motorized use in 

winter have definable boundaries such as 

ridges. 

Agency Response: See response to 

comment 241. 

Budget 

243. The Forest Service should not use the 

agency budget as a rationale for management. 

Agency Response: The Forest must consider 

the expected budget and funding trends when 

proposing changes in management. It would be 

misleading to the public if the Forest proposed 

management actions it is unlikely to be able to 

fund. Forest recreation and law enforcement 

funds are already stretched thin under the 

current travel plan. While partnerships and 

grants can make up for some budget shortfalls, 

it is unrealistic to expect these avenues to fund 

the Forest’s primary recreation programs, 

including the trail maintenance, construction, 

and management of General Forest Areas 

across the Forest. General Forest Areas are 

dispersed recreation areas – dispersed camping 

areas in the summer, and snowmobile play 

areas in the winter. See Chapter 3, Recreation, 

in the FEIS for a discussion of sources of 

funding and current recreation budget trends. 

Land and Special Designations 

Wilderness 

244. The Forest Service should consider that 

only a small percentage of the public uses 

wilderness and additional “de facto” 

wilderness areas that exclude motorized use 

should not be created. 

Agency Response: The Forest is not 

proposing to create any additional 

Recommended Wildernesses with the travel 

management proposals. In most cases, areas 

retain some level of motorized access, unless it 

did not exist prior to this analysis. In fact, 

portions of the Secesh and Needles 

Recommended Wilderness areas currently 

allow motorized use, including winter 

motorized use, and there are no plans to 

change this at this time. 

245. The Forest Service should consider 

paving a road through the middle of the Frank 

Church River of No Return Wilderness so that 

it can be enjoyed by many more people. 

Agency Response: Travel management within 

the Frank Church Wilderness of No Return 

was not within the scope of this project, nor 

was it included within the project area. Road 

construction of any kind is not permitted in 

Wilderness areas. Under the Wilderness Act, 

evidence of man or his activities is to be 

minimal or non-existent in designated 

Wilderness. Recreation is not the driving force 

behind Wilderness creation. The complete 

Wilderness Act of 1964 provides a definition 

and management rationale for Wilderness. 

246. The Forest Service should consider that 

the Frank Church River of No Return 

Wilderness provides ample non-motorized 

opportunities. 

Agency Response: Recreation is not the 

driving force behind the creation of 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

6 – 94 Payette National Forest Travel Plan FEIS 

Wilderness. Therefore, management of nonmotorized opportunities on the Forest rightly 

focuses on the non-Wilderness portion of the 

Forest. The following is a quote from the 

Wilderness Act of 1964: “A wilderness, in 

contrast with those areas where man and his 

own works dominate the landscape, is hereby 

recognized as an area where the earth and its 

community of life are untrammeled by man, 

where man himself is a visitor and does not 

remain. An area of wilderness is further 

defined to mean in this chapter an area of 

undeveloped Federal land retaining its 

primeval character and influence, without 

permanent improvements or human habitation, 

which is protected and managed so as to 

preserve its natural conditions and which (1) 

generally appears to have been affected 

primarily by the forces of nature, with the 

imprint of man’s work substantially 

unnoticeable; (2) has outstanding 

opportunities for solitude or a primitive and 

unconfined type of recreation; ....” 

247. The Forest Service should include the 

non-motorized trail opportunities available in 

the FCRNRW when displaying the alternatives. 

Agency Response: See comment response 

246. 

248. The Forest Service should only consider 

the attributes associated with Wilderness 

through ROS designations. 

Agency Response: The Frank Church River 

of No Return Wilderness was not within the 

project area for this Travel Management Plan, 

thus this is outside the scope of this project. 

Recommended Wilderness 

249. The Forest Service should reconsider the 

effects of snowmobile use on potential 

designation of recommended wilderness areas. 

Agency Response: The Forest has analyzed 

the effects of over-snow motorized use in the 

Secesh and Needles IRA. This analysis can be 

found in the FEIS, Chapter 2, Alternatives 

considered but eliminated from detailed study. 

250. The Forest Service should consider that 

any increase in, or the continued allowance of, 

motorized use in Recommended Wilderness 

areas could have a negative impact on their 

potential for future wilderness designation. 

Agency Response: Existing mechanical 

transport (which includes mountain bicycles) 

uses in recommended wilderness areas are 

allowed to continue, as provided for by the 

Forest Plan guidelines for recommended 

wilderness. The continued use as allowed so 

long as it does not degrade wilderness values, 

cause resource damage, or result in user 

conflict. (Forest Plan 2003: p. III-74: 

WRGU05). Forest Plan standard 1203 states 

that “No new motorized or mechanical uses 

will be allowed, except where these uses must 

be allowed in response to reserved or 

outstanding rights, statute, or treaty.” This 

direction has been further analyzed and 

clarified in the FEIS, Chapter 2, Alternatives 

considered but eliminated from detailed study. 

251. The Forest Service should consider that 

snowmobile use in recommended wilderness 

areas would not impact their future 

consideration for wilderness areas because the 

impacts of snowmobiles are not lasting. 

Agency Response: See response to Comment 

250. While the direct effects of snowmobile 

use—noise, exhaust, tracks, and displacement 

of other uses—are temporary, there are also 

indirect effects that happen later in time or at a 

distance from the snowmobiling. And in the 

case of proposed wilderness, establishing a 

new use of a roadless area can decrease the 

area’s future suitability for wilderness 

designation. In addition, Payette Forest Plan 

direction is to not promote motorized or other 

non-conforming uses in proposed wilderness 

(Forest Plan 2003: III-74). The Plan allows 

existing mechanical uses of proposed 

wilderness provided it does not degrade 

wilderness values, cause resource damage, or 

result in user conflicts. 

252. The Forest Service should consider that 

only Congress can create Wilderness. 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

Payette National Forest Travel Plan FEIS 6 - 95 

Agency Response: The Forest is not 

proposing to create any additional Wilderness 

(or recommended Wilderness) areas with this 

travel plan action. 

253. The Forest Service should defer any 

travel management decisions for 

Recommended Wilderness until the State of 

Idaho’s Roadless Review process is complete. 

Agency Response: Recently, the State of Idaho 

moved forward with recommendations for the 

management of Idaho’s IRAs using the 

Petition of Governor James Risch: State 

Specific Rulemaking for Roadless Areas in 

Idaho, September 20, 2006. 

In the petition, the Governor’s Office states 

they received both county and individual 

recommendations to form their guiding 

principles. Generally these themes outline 

basic management activities that may or may 

not occur within a given IRA. 

The “Idaho Roadless Area Themes” developed 

by former Governor Risch recommended the 

entire Secesh and Needles Recommended 

Wilderness areas for designations of “Wild 

Land Recreation” – Management Theme 1. 

This theme designation is the most restrictive 

of all recommendations with the exception of 

already designated Wilderness, which is listed 

as “Primitive”. 

Management Theme 1 “Wild Land Recreation” 

emphasizes: 

• A desired future condition that will 

continue to show little evidence of 

historical or human use. 

• That natural process of the area will 

continue to predominate, which will 

allow visitors to enjoy the same type 

of primitive recreation opportunities 

they found in the past. 

• Areas will be managed to protect the 

wilderness characteristics and 

primitive recreation opportunities of 

the area if and until Congress exercises 

its authority pursuant to the Wilderness 

Act to formally designate the area as 

“Wilderness”. 

In regards to motorized travel Theme I 

preserves currently existing routes and class of 

vehicle, but recognizes the potential for further 

limitations through National Forest Travel 

Planning. 

The Governors Petition treats the 

recommended Wilderness with almost 

identical protection as the Forest Plan under 

this MPC. 

The Governors public involvement efforts 

further affirm the Idaho publics desire to keep 

these areas as they are. . 

Social and Economic 

Economics 

254. The Forest Service should complete a 

more thorough economic analysis using 

studies such as the one funded by ISSA in 

2005. 

Agency Response: Because none of the 

alternatives in the FEIS limit numbers of users 

entering an area, it is speculative to analyze an 

economic effect with the different alternatives. 

A negative impact to snowmobile use could 

positively affect non-motorized use, and 

balance out any expected economic changes. 

Several economic studies were reviewed for 

both motorized and non-motorized economic 

benefits. See the FEIS section responding to 

the need for an economics analysis in Chapter 

1 “Non-significant issues”. Additional citations 

for local economic studies, including ISSA’s 

study, have been reviewed and are listed in the 

references section. 

255. The Forest Service should consider the 

socio-economic value of Forest recreation, 

both motorized and non-motorized, on the 

local community. 

Agency Response: The Forest did analyze the 

socio-economic impacts of travel management 

in the DEIS, Chapter 1, Section 1.10.2 NonSignificant Issues. Additional analysis can be 

found in the same section in the FEIS. 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

6 – 96 Payette National Forest Travel Plan FEIS 

256. The Forest Service should consider the 

economic analysis done for the Forest Plan 

and make sure it is consistent with any 

analysis done for the travel management plan. 

Agency Response: While the overall trend for 

number of recreation jobs and amount of 

income created by Forest Service recreation in 

local communities is predicted to rise over the 

course of this decade, the percentage 

contribution of recreation jobs and income to 

the total economy is relatively stable. (USDA 

Forest Service 2003a: FEIS Vol. 3: p. 3-957). 

There was no analysis done assessing potential 

shifts over time in the type of recreation 

conducted on the Forest. 

257. The Forest Service should draft a 

comprehensive plan for commercial recreation 

use on the Forest. 

Agency Response: Comment noted. This 

suggestion is more extensive and outside the 

scope of travel management planning. 

258. The Forest Service should take into 

account that the backcountry skiing industry 

has grown by 300 percent in the last year. 

Agency Response: Almost all recreation 

sectors have experienced growth in the recent 

past. Refer to Chapter 1 in the FEIS for a 

discussion of the role of economics and 

recreation on local communities and 

businesses. 

259. The Forest Service should consider that 

having a variety of recreation opportunities on 

the National Forest is best for the local 

economy. 

Agency Response: The Forest does consider a 

variety of recreation opportunities as important 

for the local economy and the Travel Plan 

strives to provide a diversity of opportunities 

in concert with maintaining resource values. 

See Chapter 1 of the FEIS for a discussion of 

the role of economics and recreation on local 

communities and businesses. 

260. The Forest Service should consider that 

money isn’t everything, and that even 

recreation opportunities that generate little 

local income have value. 

Agency Response: Comment acknowledged. 

Pollution 

261. The Forest Service should consider the 

effects of snowmobile pollution on water 

quality. 

See Section 1.10.2 Non-Significant Issues in 

Chapter 1 of the FEIS. This non-significant 

issue is discussed under Effects of Snowmobile 

Use. 

262. The Forest Service should consider that 

more snowmobilers are using new technology 

to reduce noise and pollution by their 

machines. 

Agency Response: Comment is 

acknowledged. New technology is beneficial 

in some respects to motorized and nonmotorized users and may be a factor in 

selection of a travel plan alternative.

Noise 

263. The Forest Service should consider that it 

is currently difficult for non-motorized winter 

recreationists to find an area without 

snowmobile traffic on the Forest. 

Agency Response: The Forest has taken this 

into consideration and this is one of the 

reasons action alternatives all propose 

additional closures to over-snow motorized 

use. See Chapter 2 in the DEIS and FEIS for a 

description of proposed winter closures. 

264. The Forest Service should not allow more 

motorized use so that the quiet in the Forest is 

preserved. 

Agency Response: The Forest recognized the 

need to provide for a non-motorized winter 

recreation experience, and analyzed different 

options for providing for that opportunity in 

the DEIS and FEIS. 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

Payette National Forest Travel Plan FEIS 6 - 97 

Health & Safety 

265. The Forest Service should consider that 

snowmobile use in the Brundage SnowCat 

program special use permit area is 

incompatible because of the potential for 

unsafe conditions. 

Agency Response: See response to 

Comments 194 and 195. 

266. The Forest Service should reassess the 

safety of heavily used trails where motorized 

and non-motorized users mix; and: 

267. The Forest Service should give the issue 

of safety more discussion in the DEIS; and: 

268. The Forest Service should consider that 

snowmobiling and skiing do not mix because of 

safety issues. 

Agency Response: Although this tendency 

may be true in some cases, the degree of 

compatibility between the two uses varies on a 

site-specific basis. The alternatives provide for 

different degrees of mixes of the uses and 

safety is addressed as a primary issue under all 

alternatives in Chapter 3: Recreation.

Conflict of Uses/User Conflict 

269. The Forest Service should consider that 

the snowmobile community has worked with 

both Brundage Mountain Ski Resort and the 

Tamarack Resort to reduce the user conflicts 

occurring between their patrons and 

snowmobilers. 

Agency Response: The Forest acknowledges 

that good work has been done to date to reduce 

user conflicts, and anticipates that this 

education, signing, and relationship building 

will continue. The Forest also recognizes that 

to address the concerns of the non-motorized 

community, an analysis looking at some 

potential land use allocations for nonmotorized winter recreation was necessary. 

270. The Forest Service should consider that 

back country skiing and snowmobile use are 

usually not compatible. 

Agency Response: Although this may be true 

in some cases, the degree of compatibility 

between the two uses varies on a site-specific 

basis. 

271. The Forest Service should consider that 

many user groups, including the BackCountry 

Horseman, are willing to work with other 

recreation user groups to reduce use conflict. 

Agency Response: Comment noted and the 

Payette thanks you for your response. The 

Forest will look for your support during the 

implementation stage of the travel plan. 

272. The Forest Service should consider that 

decreasing the area available for both 

motorized and non-motorized recreation will 

increase user conflict; and: 

273. The Forest Service should consider that 

user conflict is relatively isolated: and: 

274. The Forest Service should consider that 

conflict between recreational uses has 

incorrectly been identified as a significant 

issue; and: 

Agency Response: See response to 

Comments 22, 0, 176, 177, and 190 

275. The Forest Service should consider that 

OHV use during hunting season causes 

conflict between hunters. 

Agency Response: See analysis presented on 

conflict with hunting and OHV users, Chapter 

3, Recreation. 
CHAPTER 6. PUBLIC COMMENTS AND RESPONSES 

6 – 98 Payette National Forest Travel Plan FEIS