United States 

Department of 

Agriculture 

Forest 

Service 

Pacific Southwest 

Region 

R5-MB-205b 

July 2010 

Record of Decision 

Motorized Travel 

Management 

(formerly Motorized 

Route Designation) 

Klamath National Forest 

California and Oregon
Klamath National Forest 

Motorized Travel Management 

Record of Decision 

Lead Agency: USDA Forest Service 

Responsible Official: Patricia A. Grantham, Forest Supervisor 

 Klamath National Forest 

 1312 Fairlane Road 

 Yreka, CA 96097 

For Further Information Contact: 

Togan Capozza, Recreation Officer 

Klamath National Forest 

1312 Fairlane Road 

Yreka, CA 96097 

(530) 841-4467 

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

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alternative means for communication of program information (Braille, large print, audiotape, etc.) 

should contact USDA's TARGET Center at (202) 720-2600 (voice and TDD). To file a complaint of 

discrimination, write to USDA, Director, Office of Civil Rights, 1400 Independence Avenue, S.W., 

Washington, D.C. 20250-9410, or call (800) 795-3272 (voice) or (202) 720-6382 (TDD). USDA is an 

equal opportunity provider and employer. 
Table of Contents 

Introduction ........................................................................................................................................... 1

Background ........................................................................................................................................... 1

Project Location ............................................................................................................................. 2

Purpose and Need ................................................................................................................................ 2

Decision ................................................................................................................................................. 4

Development of Alternative 7 in Response to Comments ............................................................. 4

Reasons for My Decision ..................................................................................................................... 8

Compelling Need for Change ......................................................................................................... 8

Balanced Approach ........................................................................................................................ 9

Addressing the Purpose and Need and the Travel Management Regulations ........................... 10

Listening to Public Input ............................................................................................................... 12

Fostering Citizen Stewardship in National Forest Management of Roads and Trails ................. 13

Klamath National Forest Implementation Strategy ......................................................................... 13 

Priorities/Timelines... ......................................................................................................................... 13 

Maps/Brochures .......................................................................................................................... 14 

Signing ................................................................................................................................................. 14

Public Outreach............................................................................................................................ 15

Public Involvement ............................................................................................................................. 15

Scoping for the Notice of Intent .................................................................................................... 16

Draft Environmental Impact Statement Comment Period ............................................................ 17

Identification of Issues ................................................................................................................. 18

Alternatives Considered in Detail but Not Selected........................................................................ 20

Alternative 1 (Noaction) ............................................................................................................... 20

Alternative 2 (Proposed Action) ................................................................................................... 21

Alternative 3 ................................................................................................................................. 21

Alternative 4 ................................................................................................................................. 22

Alternative 5 ................................................................................................................................. 22 

Alternative 6 ................................................................................................................................. 22 

Environmentally Preferable Alternative ........................................................................................ 23

Legal and Regulatory Compliance.................................................................................................... 23

Forest Plan Consistency .............................................................................................................. 24

Travel Management Regulations ................................................................................................. 26

Findings Required by Other Laws and Regulations .................................................................... 30

Special Area Designations ........................................................................................................... 32

Administrative Review or Appeal Opportunities ............................................................................. 32

Implementation Date ......................................................................................................................... 33 

Contact Person ................................................................................................................................... 33 

Motorized Travel Management 

Record of Decision 

Klamath National Forest ROD-1 

Introduction 

This Record of Decision (ROD) documents my decision for the Motorized Travel Management 

(MTM) Project on the Klamath National Forest (KNF). The goal of the Travel Management 

Project is to implement provisions of the 2005 Travel Management Rule (36 CFR Part 212, 

Subpart B) designed to enhance management of National Forest System lands; sustain natural 

resource values through more effective management of motor vehicle use; and provide 

opportunities for motorized recreation experiences on National Forest System lands. The Final 

Environmental Impact Statement (FEIS) published in January 2010 discloses the environmental 

impacts associated with the agency’s original Proposed Action, a No Action alternative, and five 

additional action alternatives developed to meet the purpose and need and respond to issues 

raised by the public. The FEIS also disclosed the environmental impacts of two Land and 

Resource Management Plan (Forest Plan or LRMP) amendments; one is a Forest-wide 

amendment to prohibit cross-country motor vehicle travel on the entire KNF and the other is a 

site-specific amendment to exempt 12.8 miles of road in the Butte Valley National Grassland 

from a seasonal restriction on motor vehicle use during the nesting season for Swainson’s 

hawks. 

Background 

On November 9, 2005, the Forest Service published the Final Travel Management Rule in the 

Federal Register (70 Federal Register 216, Nov. 9, 2005 p. 68264-68291). Subpart B of the 

Final Travel Management Rule requires designation of those roads, trails, and areas that are 

open to motor vehicle use on National Forests (codified in the Code of Federal Regulations 

(CFR), 36 CFR 212.50). Only roads and trails that are part of a National Forest Transportation 

System (NFTS) may be designated for motorized use. Designations are made by class of 

vehicle and, if appropriate, by time of year. Part 261 – Prohibitions, 36 CFR 261.13 Subpart A of 

the final rule, prohibits the use of motor vehicles off designated roads, trails and areas, as well 

as use of motor vehicles on roads and trails that are not consistent with the designations. 

The KNF currently manages and maintains approximately 4,536 miles of NFTS roads and no 

motorized trails. The NFTS was developed over many decades to meet a variety of needs 

including vegetation management, fuel treatment, fire control, public utilities, special uses 

management and public recreation access. Harvesting of special forest products such as 

ornamental greenery, firewood, mushrooms and plants, and access to secluded dispersed 

recreation sites are among the many opportunities afforded by the NFTS. The NFTS is 

managed and maintained to various road standards, ranging from paved highways to roughly 

graded high-clearance roads, depending on the type of access needed. The NFTS is displayed 

on the Forest Transportation Atlas. Details concerning the management of individual roads and 

trails are maintained in the Forest Service Infrastructure database (INFRA). 

In accordance with the Travel Management Rule and following a decision on this 

environmental analysis, the KNF will publish a Motor Vehicle Use Map (MVUM) identifying all 
Motorized Travel Management 

Record of Decision 

ROD- 2 Klamath National Forest 

NFTS roads and trails that are designated for motor vehicle use. The MVUM shall specify the 

classes of vehicles and the times of year for which use is designated. 

The unauthorized routes not included in this decision may be considered in the future either 

for removal from the landscape and restoration to the natural condition or addition to the NFTS 

and designation on the MVUM. Future decisions associated with changes to the NFTS and 

MVUM are dependent on available staff and resources and may trigger the need for additional 

environmental analysis, public involvement and documentation. 

Project Location 

As shown on the Vicinity Map (FEIS, Chapter 1, Figure 1), the KNF is located in northern 

California and southern Oregon, and totals approximately 1.68 million acres in size. The Forest 

is located within two counties: Siskiyou (California) and Jackson (Oregon). Administratively, the 

KNF is divided into four ranger districts: Salmon/Scott, Happy Camp/Oak Knoll, Goosenest, and 

Ukonom (the latter administered by the Six Rivers National Forest). It is bordered by the 

Shasta-Trinity NF to the south, the Modoc National Forest to the east, the Six Rivers National 

Forest to the west, and the Rogue River-Siskiyou National Forest to the north. The project area 

includes all National Forest System (NFS) lands within the KNF boundary. The project area 

does not include any other federal, state, private or tribal lands. 

The KNF includes approximately 381,100 acres of Wilderness within its administrative 

boundary: Marble Mountain Wilderness (223,500 acres); Russian Wilderness (12,600 acres); 

Trinity-Alps Wilderness (74,900 acres); and Siskiyou Wilderness (70,100 acres). There is a very 

small portion of the Red Butte Wilderness (less than 5 acres) within the KNF boundary. Almost 

75,000 acres are in Research Natural Areas, designated and recommended Wild River 

corridors, Backcountry, and a special habitat area for Calochortus persistens habitat as defined 

by the Forest Plan. Excluding Wilderness areas and other management areas that do not permit 

off-highway vehicle use, the size of the project area for this decision is approximately 1.2 million 

acres. 

Purpose and Need 

The following needs have been identified for this proposal: 

1) There is a need for regulation of unmanaged motor vehicle travel by the public. The 

proliferation of unplanned, unauthorized, non-sustainable roads, trails, and areas adversely 

impacts the environment. The 2005 Travel Management Rule, 36 CFR 212, Subpart B, 

provides for a system of NFTS roads, NFTS trails, and areas on NFS lands that are 

designated for motor vehicle use. After roads, trails, and areas are designated, motor 

vehicle use off designated roads and trails and outside designated areas is prohibited by 36 

CFR 261.13 Subpart B. This is intended to prevent resource damage caused by 

unmanaged motor vehicle use by the public. 

2) There is a need for the Klamath Forest Plan to conform to the Travel Management Rule, 36 

CFR 212 Subpart B. A review of the Forest Plan has found that it is not fully consistent with 

the Travel Management Rule, Subpart B. For example, the Klamath Forest Plan EIS states 
Motorized Travel Management 

Record of Decision 

Klamath National Forest ROD-3 

that off-highway vehicle use is allowed where it is not (1) legislatively restricted, (2) causing 

unacceptable resource damage, or (3) in conflict with other activities. The objective is to 

restrict use only where there is a demonstrated need. The Klamath Forest Plan includes 

standards and guidelines that prohibit or restrict off-highway vehicle (OHV) use in certain 

land allocations (e.g. Wilderness, Research Natural Areas, Backcountry areas), but OHV 

use is generally allowed in the other land allocations. About 70 percent of the Forest is open 

to unrestricted OHV use. These Forest Plan standards and guidelines are in conflict with the 

Travel Management Rule, at 36 CFR 212.50 (a) (Motor vehicle use off designated roads and 

trails and outside designated areas is prohibited by 36 CFR 261.13). 

3) There is a need for limited changes to the NFTS to:

a. Provide wheeled motorized access to dispersed recreation opportunities (camping, 

hunting, fishing, hiking, horseback riding, etc.). There is a need to maintain motor vehicle 

access to dispersed recreation activities that historically have been accessed by motor 

vehicles. A portion of known dispersed recreation activities are not located directly 

adjacent to an existing NFTS road. Some dispersed recreation activities depend on foot 

or horseback access, and some depend on motor vehicle access. Those activities 

accessed by motor vehicles consist of short spurs that have been created and 

maintained primarily by the passage of motor vehicles. Many such ‘user-created’ routes 

are not currently part of the NFTS. Without adding them to the NFTS, the regulatory 

changes noted above would make continued use of such routes illegal through the 

prohibition of cross-country travel and would preclude motorized access to many 

dispersed recreation activities. 

b. Provide a diversity of motorized recreation opportunities (4X4 vehicles, motorcycles, allterrain vehicles (ATVs), passenger vehicles, etc.). It is Forest Service policy to provide a 

diversity of road and trail opportunities for experiencing a variety of environments and 

modes of travel consistent with the National Forest recreation role and land capability 

(FSM 2353.03(2)). Implementation of Subpart B of the Travel Management Rule will 

severely reduce motorized recreation opportunities relative to current levels. As a result, 

there is a need to consider limited changes and additions to the type of use permitted on 

existing NFTS roads as well as potential additions to the NFTS. 

4) There is a need for socially compatible use by non-highway-legal vehicles in the vicinity of 

Hawkinsville where trespass, destruction of private property, and other use conflicts 

facilitated by the use of OHVs have become a problem. The KNF Forest Plan specifies 

coordination of road management objectives with private landowners within the KNF (Forest 

Plan Standard and Guideline 20-3). Previous complaints from residents, and comments 

received early in the planning process for this project, focused on needs for management 

changes on all or portions of Forest Roads 40N21, 43N30, 45N03X, 45N28, 45N29, 45N39, 

46N16, and 46N16A. 

In making any limited changes to the NFTS, the KNF will be considering criteria contained in 

Subpart B of the Travel Management Rule, which include the following: 
Motorized Travel Management 

Record of Decision 

ROD- 4 Klamath National Forest 

a. Impacts to natural and cultural resources. 

b. Public safety. 

c. Access to public and private lands. 

d. Availability of additional resources for maintenance and administration needs of roads 

trails and areas if the uses under consideration are designated. 

e. Minimizing damage to soil, watershed, vegetation, and other forest resources. 

f. Minimizing harassment of wildlife and significant disruption of wildlife habitat. 

g. Minimizing conflicts between motor vehicles and existing or proposed recreational uses 

of NFS lands or neighboring federal lands. 

h. Minimizing conflicts among different classes of motor vehicle uses of NFS lands or 

neighboring federal lands. 

i. Compatibility of motor vehicle use with existing conditions in populated areas, taking into 

account sound, emissions, and other factors. 

When making any limited changes to NFTS roads, the KNF will also consider the following: 

a. Speed, volume, composition and distribution of traffic on roads. 

b. Compatibility of vehicle class with road geometry and road surfacing. 

c. Maintaining valid existing rights of use and access (rights-of-way). 

Decision 

Based on the analysis in the Klamath National Forest Motorized Travel Management Project 

FEIS, comments to the FEIS, and the associated project record, I have decided to implement 

Alternative 7 (Selected Alternative). My decision includes some modifications made to 

Alternative 7 in response to comments on the FEIS received from the public. Modifications and 

errata are listed in Appendix A of this Record of Decision. I believe the selection of this 

alternative best meets the purpose and need for the project and responds to the issues of 

access, motorized recreation opportunity, and natural resource protection. 

Development of Alternative 7 in Response to Comments 

After a careful review of the public comments I received in response to the Draft Environmental 

Impact Statement (DEIS), Alternative 7 was developed. This alternative was based on elements 

of Alternative 6, and was developed primarily to respond to comments on that alternative and to 

several omissions discovered after the DEIS was published. 

One omission from the DEIS was inadvertently not proposing adding to the NFTS routes 

traditionally used by highway legal vehicles in the Butte Valley National Grassland. Although 

the effects of adding these unauthorized routes were analyzed in the process of developing 
Motorized Travel Management 

Record of Decision 

Klamath National Forest ROD-5 

alternatives for the DEIS, none of the routes were included in any action alternative. In 

Alternative 7 as modified by changes listed in Appendix A to this ROD: 

 

1. Three unauthorized routes in the Butte Valley National Grassland (totaling 12.8 miles) 

are proposed for designation to the NFTS for highway-legal vehicles; and 

2. An amendment to the LRMP regarding season of use for Swainson’s hawks in the Butte 

Valley National Grassland is proposed so that the three routes will be available for use 

year round so that visitors to the Grassland will be able to continue historic use of 

highway vehicles on these roads during the late spring and early summer. 

 In response to comments on the number of stream crossings identified in the DEIS, and the 

potential effect of these crossings on fish, additional field review was conducted on routes 

identified in the Geographic Information System (GIS) as crossing streams. Field review 

determined that only three routes identified in Alternative 6 actually cross perennial streams. In 

Alternative 7: 

3. Two unauthorized routes with perennial stream crossings were removed from 

consideration, and the one route proposed for addition to the NFTS was closely 

examined by fish biologists from the KNF and from the National Marine Fisheries 

Service to ensure minimum effects on fish. These effects are disclosed in the Fisheries 

section of Chapter 3 of the FEIS and in the Fisheries Biological Assessment for the 

Motorized Travel Management Project (available in the project record). 

 In response to requests for more motorized recreation opportunities for non-highway legal 

vehicles than provided by Alternative 6, in Alternative 7: 

4. Based on the Motorized Mixed Use Analysis (disclosed in the Transportation section of 

Chapter 3 and Appendix C of the FEIS, and corrections listed in Appendix A of this 

ROD,), all or portions of 19 NFTS Maintenance Level 3 (ML3) roads will be converted to 

ML2; and all or portions of 14 ML3 roads will allow use by both highway-legal and nonhighway legal vehicles, for a total of about 264 miles of road that will allow non-highway 

legal vehicle motorized use. 

 In response to requests for more motorized access to dispersed recreation sites than 

provided by Alternative 6, in Alternative 7: 

5. Forty-four routes (totaling 3.7 miles) are proposed for addition as NFTS roads to access 

dispersed recreation sites (these were found to be well-sited on the ground and not 

causing undue resource impacts) and eight routes (totaling 2.5 miles) are removed from 

consideration for motorized access due to resource or administrative conflict issues 
Motorized Travel Management 

Record of Decision 

ROD- 6 Klamath National Forest 

(including one route removed due to potential impacts to Port-Orford-Cedar disease 

spread), totaling thirty-six routes added (1.2 additional miles). 

 In response to requests for more well-sited motorized recreation opportunities than provided 

by Alternative 6 (routes that provide more resource protection as well as providing motorized 

recreation opportunities), in Alternative 7: 

6. Five routes (totaling 3.0 miles) are proposed for addition as NFTS roads to provide 

motorized access to a diversity of recreational opportunities (these were found to be 

well-sited on the ground and not causing undue resource impacts) and two routes 

(totaling 1.65 miles) were removed from consideration due to resource issues (including 

routes crossing streams that were steep and had effects that would be difficult to 

mitigate) for a total of three additional routes (totaling 1.35 additional miles); and 

7. Two routes (totaling 2.4 miles) are proposed for addition as motorized trails that were 

well-sited on the ground and not causing undue resource impacts, and four routes 

(totaling 0.7 miles) were removed from consideration due to resource issues. These 

proposed changes result in a reduction of two trails and one route changed from 

potential use by all trail vehicles to use only by vehicles less than 50” in width. 

These changes are described in more detail in Chapter 2 of the FEIS and the effects 

analyzed and disclosed for each affected resource in Chapter 3 of the FEIS. I have selected 

Alternative 7 as modified because I believe it will enhance recreation opportunities within 

reasonable maintenance budgets while ensuring that safety and natural resource values remain 

intact. I delayed signing the ROD to allow the public to review these changes. Comments 

received during the 30-day public review period, and responses to these comments, are 

summarized in the Final Environmental Impact Statement Comment Period section of this ROD. 

Letters received from governmental agencies after publication of the FEIS are reprinted in 

Apprendix B. 

Amendments to the Forest Plan: Two non-significant amendments to the Forest Plan (1995) 

would be necessary under this alternative. One Forest-wide amendment will modify the Forest 

Plan to restrict motor vehicle use to designated roads, trails and areas per 36 CFR 261.13. A 

site-specific amendment modifies Forest Plan standard 8-37 to allow continued year-round 

highway-legal motor vehicle use of routes in the Butte Valley National Grassland, and exempt 

them from a season of use restriction for Swainson’s hawks. 

Table ROD-1 displays a summary of the actions proposed in this alternative. A complete list 

of roads and trails to be added into the NFTS, including the vehicle class if applicable, can be 

found in Appendix A of this ROD. 
Motorized Travel Management 

Record of Decision 

Klamath National Forest ROD-7 

Table ROD-1 Alternative 7 as Modified - Summary of Actions 

Action Type Action Proposed 

1. Cross-country Travel 

Status of cross-country travel Prohibited on all 1.7 million acres 

(currently prohibited on 500,000 acres) 

2a. Additions to the NFTS (Routes) Miles 

Trails added 20.4 

Roads added – to access dispersed recreation sites 

Roads added – to provide a diversity of recreation opportunities 

Total mileage of roads added 

25.0 

28.3 

53.3 

2b. Additions to Open Riding Areas Acres 

Open Riding Areas added (2) 48 

3. Changes to the Existing NFTS 

Vehicle Class or Maintenance Level Changes a Miles 

Vehicle Class or 

Maintenance Level 

Changes 

System roads currently closed to motor 

vehicle use by the public that will be 

designated as open to public motorized use 

4.7 

NFTS roads currently open to motorized use 

for all vehicle classes that will be designated 

as open to highway legal vehicles only 

7.7 

Roads currently used by highway legal 

vehicles that will also allow non-highway legal 

vehicle use (change from ML3 to ML2) 

133.0 

Roads currently managed for highway legal 

vehicles that will be managed for both 

highway and non-highway legal vehicles 

(allowing Mixed Use on ML3 roads). 

131.5 

Best Available Science: My decision is based on the best available science. All practicable 

means to avoid or minimize environmental harm have been adopted in the design of the 

Selected Alternative. I have included all of the mitigation measures and monitoring that I believe 

are necessary to avoid, minimize, or rectify impacts on resources affected by implementation of 

the Selected Alternative. My conclusion is based on a review of the record that shows a 

thorough analysis using the best available science. The resource analyses disclosed in Chapter 

3 of the FEIS identify the effects analysis methodologies, reference scientific sources which 

informed the analyses, and disclose limitations of the analyses. 

Mitigations and Monitoring: Mitigations minimize, reduce or eliminate impacts on sensitive 

resources. Specific mitigations listed in Chapter 2, and in the Soils, Recreation, and Cultural 

Resources sections of Chapter 3 of the FEIS, must be completed prior to designation of a route 

for public motorized use on the MVUM. Monitoring, including cultural resource-specific 

monitoring listed in the Cultural Resources section of Chapter 3 of the FEIS, must be conducted 

as described in Chapter 2 of the FEIS.
Motorized Travel Management 

Record of Decision 

ROD- 8 Klamath National Forest 

Reasons for My Decision 

The Klamath National Forest is comprised of outstanding landscapes, with a diversity of 

resource values, and a rich history of human use and visitation. Motorized recreation plays an 

important and pivotal role in how people visit and use the National Forest. 

The KNF provides a spectrum of recreation experiences that include opportunities to 

experience the unique challenges of exploration and discovery, as well as opportunities for quiet 

reflection and solitude. Forest landscapes include large expanses of undeveloped public lands 

that are home to many species of plants, animals and fish, and an array of valuable cultural 

sites. 

With these factors in mind, I did not take this decision lightly. In reaching my decision, I have 

considered the purpose and need for action, the issues, the Forest Plan and associated 

amendments, current policies and regulations, effects on natural and cultural resources, a full 

range of alternatives, public comments received, and comments discovered through 

coordination with local governments and consultation with American Indian tribes. I considered 

the broad range of concerns expressed throughout this process relating to both motorized and 

non-motorized recreation opportunities. 

Although my decision will reduce the number of miles of motorized opportunities available as 

compared to the existing condition, there is a compelling need for change. This decision 

implements a permanent prohibition on cross-country travel to reduce potential detrimental 

effects on natural resource conditions. Importantly, it implements this prohibition while ensuring 

continued public motorized access to recreation opportunities throughout the KNF. 

Compelling Need for Change 

My decision consists of three different components. The first component of the decision 

prohibits cross-country travel off designated routes and outside open riding areas. The second 

component of the decision selects carefully considered routes to add to the existing NFTS. The 

third component of the decision increases opportunities for use by non-highway legal motor 

vehicles by allowing such use on a number of NFTS roads. 

Prohibiting cross-country travel is a preventative action that will ensure motorized travel is 

planned and managed in concert with the resource stewardship responsibilities of the Forest 

Service. 

Adding routes to the NFTS will complement the existing system in terms of providing access 

to historically-used recreation sites, developing loop travel opportunities, and providing 

motorized trails and two designated open riding areas. In developing this aspect of the 

decision, I drew upon local knowledge of both employees and the public to determine which 

unauthorized routes and areas would meet specific recreation requests for motorized trails, 

loops and open riding sites, and provide access to dispersed recreation sites with minimal 

disturbance to natural and cultural resources. 
Motorized Travel Management 

Record of Decision 

Klamath National Forest ROD-9 

Enhancing motorized recreation opportunities on existing NFTS roads implements 

recommendations from the Motorized Mixed Use analysis. This analysis provided information on 

road conditions and motor vehicle use levels, and determined the suitability of various ML3 

roads for either mixed use or downgrading to ML2 status. In both of these cases, highway legal 

vehicles and non-highway legal vehicles would be allowed to use these roads, providing loop 

opportunities and connections between ML2 roads across the KNF. Allowing mixed use on ML3 

roads is not considered to affect maintenance costs or other resources. Downgrading ML3 

roads to ML2 will actually reduce maintenance costs, as disclosed in the Transportation section 

of Chapter 3 of the FEIS. 

Balanced Approach 

The Selected Alternative provides a balanced approach, weighing resource and maintenance 

cost concerns against the need for recreation opportunities. The Selected Alternative provides 

interconnected loops and linkages into backcountry landscapes and maintains access to 

popular dispersed recreation opportunities. While some members of the public wanted all 

unauthorized routes to be added and cross-county travel to continue, such an action would not 

adequately protect areas containing sensitive cultural sites or soils, or habitats for threatened, 

endangered, or sensitive plants, animals, and fish. Adding all unauthorized routes to the NFTS 

would not provide additional areas of quiet use for recreationists. My decision is the result of 

responsible stewardship that limits the additions of unauthorized routes to those that would 

create the best recreation opportunity while considering the magnitude of the existing Klamath 

NFTS and the costs associated with maintaining it. This alternative provides ample access to 

NFS lands through a manageable system of roads, trails and areas for local residents and 

Forest visitors to use. Additional routes are proposed to be added with the intent of addressing 

recreation needs where resource concerns do not exist or can be successfully mitigated. 

Careful consideration was given to creating loop opportunities in locations that were popular 

with OHV users and insuring that the routes that were added provided adequate access to 

identified dispersed recreation areas. 

I believe that the Selected Alternative strikes the best balance in providing motorized 

recreation access, while also protecting cultural and natural resources. By prohibiting crosscountry motorized travel, the Forest enhances protection of more than 2,000 cultural resource 

sites. Also considered and addressed in the Selected Alternative were habitat protections for 

endangered species, such as the Federally-listed Threatened fish species Southern 

Oregon/Northern California Coastal coho salmon (Oncorhynchus kisutch), the Federally-listed 

Threatened Northern spotted owl (Strix occidentalis caurina), the candidate mammal species, 

Pacific fisher (Martes pennanti pacifica), and the candidate plant species, Siskiyou mariposa-lily 

(Calochortus persistens). The KNF carefully limited the addition of unauthorized routes that 

might affect these species and included mitigations that must be completed prior to designating 

each route on the MVUM to minimize negative effects. The Selected Alternative protects these 

species and includes essential monitoring to ensure impacts to these species will be identified. 
Motorized Travel Management 

Record of Decision 

ROD- 10 Klamath National Forest 

For example, the Selected Alternative provides access to the Forest while substantially reducing 

impacts from vehicle traffic on aquatic resources. It does this by limiting the number of routes 

that cross perennial streams, and by implementing mitigation measures specifically aimed at 

reducing sedimentation into water sources. For further explanation see the Legal and 

Regulatory Compliance Section of the Record of Decision that outlines in more detail the 

various natural resources and the Forest’s efforts to protect them.

Addressing the Purpose and Need and the Travel 

Management Regulations 

My decision has been carefully designed to respond to the purpose and need identified in the 

Motorized Travel Management FEIS and to implement the provisions of Subpart B of the Travel 

Management regulations (36 CFR 212). 

The first part of the purpose and need, to regulate public motor vehicle travel, is 

accomplished through a permanent prohibition on cross-country travel that prevents future route 

proliferation. Implementation of this permanent prohibition of motor vehicle travel on 1.7 million 

acres of the KNF will benefit natural resources (such as fish and wildlife, and soil and water 

conditions) and cultural resources across the Forest. 

Some measureable achievements through implementing the Selected Alternative are: the 

elimination of motor vehicle impacts to approximately 47 miles of unauthorized routes in riparian 

reserves; reduction of the amount of sediment entering stream channels by eliminating 13 

perennial stream crossings; diminishment of the amount of sediment contributed to perennial 

streams by prohibiting cross country travel, including motor vehicle use on 423 miles of 

unauthorized routes; and improving more than 12 miles of routes proposed for addition to the 

NFTS that currently have some documented soil erosion. Three threatened, endangered and 

sensitive aquatic species will benefit from these protections. No routes would be added to the 

NFTS in inventoried roadless areas, helping to protect the roadless characteristics of these 

areas. 

The second part of the purpose and need, to assure compliance of this decision with the 

Forest Plan, is accomplished through the two LRMP non-significant amendments described 

above. Compliance with the Forest Plan is also assured through disclosure of the consistency of 

the Selected Alternative with the standards and guidelines of the Forest Plan in each resource 

section of Chapter 3 of the FEIS. 

The two components of the third part of the purpose and need, to provide motor vehicle 

access to dispersed recreation opportunities and to provide a diversity of motorized recreation 

opportunities, are accomplished through carefully selected additions to the NFTS. 

The fourth part of the purpose and need, to provide socially compatible use by non-highwaylegal vehicles in the vicinity of Hawkinsville, is accomplished by allowing non-highway-legal 

vehicle use on existing NFTS roads in some areas but prohibiting such use on the NFTS roads 

in the Hawkinsville area on which such use is currently allowed and is considered a problem by 

local residents. 
Motorized Travel Management 

Record of Decision 

Klamath National Forest ROD-11 

Some comments received on the DEIS suggest that the existing NFTS, currently comprised 

of 4,536 miles of road, should meet the Purpose and Need for providing a diversity of motorized 

recreation opportunities by providing access to all dispersed recreation opportunities that 

historically have been accessed by motor vehicles. The existing NFTS provides access to 

developed recreation sites, as well as access to areas subject to management activities. For 

many years, most roads on the KNF were added to the transportation system based on 

management needs for vegetation management, fuel treatment, fire control, public utilities, 

special uses management, and developed recreation access. Access to dispersed recreation 

sites was not a consideration when adding these roads. As a result, many important dispersed 

recreation opportunities are not accessible by the present NFTS. The Selected Alternative 

addresses this need by adding 25 miles of road to the NFTS to maintain access to traditional 

dispersed recreational use areas on the Forest. These added 25 miles consist of 191 individual 

previously unauthorized routes that access dispersed camping opportunities or river access 

points. With this action, the NFTS will provide access to sites that are important to Forest users 

for camping, backpacking, hiking, rafting, sightseeing, exploring, fishing, and hunting, among 

other activities. 

The Selected Alternative provides diverse recreation opportunities by providing access to a 

variety of riding experiences through loop opportunities created through a combination of 

additions to the NFTS and changes to the NFTS to allow use by both non-highway legal and 

highway legal vehicles (mixed use and maintenance level changes). The Selected Alternative 

provides about 264 miles of additional road-related recreation opportunities for non-highway 

legal vehicle riders, as well as 20 miles of motorized trail riding opportunities, as described in 

the Recreation and Transportation sections of the FEIS. 

The Selected Alternative provides additional access while considering the cost of these 

additions to the NFTS (the cost of maintaining the NFTS was identified as a significant issue in 

the scoping process). I have considered the availability of resources for maintenance and 

administration of the roads and trails added to the NFTS in this decision as directed by the 

Travel Management Rule (36 CFR 212.55 (a) 6). This decision is cumulatively an economical 

decision in terms of annual maintenance due to conversion of 133 miles of ML3 road to ML2. 

Adding motorized recreational opportunities has an initial implementation cost of $121,500 but 

cumulative savings in annual maintenance costs would be at least $24,610 and may be as high 

as $56,410 (see analysis in the Transportation section of Chapter 3 of the FEIS). Maintenance 

level 2 roads are designed to be passable by high clearance vehicles and are not maintained for 

passenger cars. Higher maintenance levels (ML3, 4, and 5) are associated with significantly 

higher maintenance costs. Implementation costs have been secured for the current fiscal year. 

I believe we will be able to secure adequate funding to complete needed maintenance of the 

transportation system over the long-term. We may need to pursue grant funding more 

aggressively in the future, further prioritize needed maintenance, continue to look for 

opportunities to reduce costs, and explore creative solutions such as road maintenance 

agreements or volunteer trail adoption programs. We will maintain roads and trails to 

management objectives to protect KNF resources. 
Motorized Travel Management 

Record of Decision 

ROD- 12 Klamath National Forest 

Subpart B of the Travel Management regulations implements the Executive Orders that 

direct Federal agencies to ensure the use of OHVs on public lands will be controlled and 

directed so as to protect the resources of those lands, to promote the safety of all users of those 

lands, and to minimize conflicts among the various uses of those lands. The Travel 

Management regulations implement those orders by requiring designation of roads, trails, and 

areas for motor vehicle use and prohibiting motor vehicle use off the designated system. The 

Selected Alternative, Alternative 7, fully implements this direction. Publication of an MVUM will 

complete the designation process by identifying the roads, trails, and areas designated for 

public motorized use. Site-specific Forest Orders regarding cross-country motorized travel will 

be superseded, and the prohibition of motor vehicle use off the designated system will take 

effect permanently, once the MVUM is published. For more about the criteria used to make this 

decision compliant with the Travel Management regulations, see the Legal and Regulatory 

Compliance section, Travel Management Regulations below. 

Listening to Public Input 

My goal throughout this effort was to work with the full range of stakeholders and interests to 

find an alternative that would sustain resources while providing a diverse set of recreation 

opportunities that satisfies the needs of the public. Despite apparent differences in opinion, the 

public, through their comments, revealed a strong connection with public lands on the Klamath 

National Forest, connections based on generations of use and exploration as well as traditions 

still in the making. Comments that I received provided helpful information on important areas 

and routes of public interest. Public input helped clarify the need for addition of some of these 

routes in order to provide access to important recreation opportunities and experiences. I also 

heard about valuable KNF resources in need of additional protection or mitigation. 

Each local community maintains a unique set of characteristics, values, and beliefs that 

shapes its relationship with the forest and its resources. The ability of these distinct civic entities 

to continue to thrive economically, physically, and spiritually through their connection with the 

KNF cannot be overstated. The public has the right to use their Federal public lands in 

responsible and sustainable ways–ways that do not diminish the current or future uses of the 

National Forest for others. There were many who brought much needed information and 

thoughtful insight into this process. Their comments were greatly appreciated and were helpful 

in working towards this decision. 

I heard from many individuals and groups with particular goals for the types of recreation and 

uses they consider to be appropriate on National Forest System lands. Some feel all existing 

unauthorized routes are valuable and important and should remain available for motorized use. 

For them, the freedom to choose where to go and how to get there is important. Some 

expressed concern that motor vehicles degrade the quality of their recreation experience. 

Others asserted protection of natural resource values such as roadless area character, water 

quality, or fish and wildlife habitat should take precedence over other needs. They believed that 

more restrictions on motorized travel should be in place. 
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Klamath National Forest ROD-13 

Lastly, some have questioned the long-term sustainability of local social, cultural and 

economic ways of life as a result of perceived effects of my decision. Some believe 

implementation of any of the action alternatives will harm small businesses, recreation users, 

the tourism industry, local governments, local economies, low-income residents, families with 

children, and people with disabilities by reducing public access to federal lands. I respectfully 

disagree. I believe the Selected Alternative provides a quality network of roads, trails, and areas 

available for public motorized use. More importantly, I believe my decision offers better 

opportunities for quality, long-term recreational motor vehicle use and better social, cultural and 

economic opportunities for individuals and communities than either the existing network of 

NFTS and unauthorized routes or the other action alternatives. Both the opportunity to access 

and enjoy the KNF for motorized recreation and the natural and cultural resources that draw 

people to this special place are protected with this decision. 

Fostering Citizen Stewardship in National Forest 

Management of Roads and Trails 

The successful implementation of this decision will, in large part, be based on local community 

members, visitors, and land managers working together to sign routes, implement mitigation 

measures, and encourage compliance with regulations. I am grateful that many individuals and 

groups from many viewpoints have already indicated their willingness to work together towards 

developing community-based solutions for future on-the-ground work. 

It is important that people know that I listened intently to their input even if all of their wishes 

are not directly reflected in the Selected Alternative. We received many articulate and heartfelt 

requests for routes to be added or dropped based on a wealth of knowledge from local citizens 

and visitors. I personally read many of your letters and I was greatly impressed by the quality of 

the comments. As work progressed on the FEIS, I met several times with our resource 

specialists and engineers to look for solutions to some of the more puzzling dilemmas. After 

looking at all of the issues surrounding the request for motorized access for big game retrieval, 

as summarized in the discussion of Alternative E (an alternative considered but eliminated from 

detailed analysis) in Chapter 2 of the FEIS, I decided that it would not be possible to both 

prohibit cross-country travel and allow motorized access for retrieving big game. This in no way 

should be taken as a dismissal of the importance of this issue. It is my intent to continue to work 

with others to look for reasonable solutions to this issue. 

Klamath National Forest Implementation Strategy 

The Forest Service developed the following management strategies to be used as part of all of 

the action alternatives to improve implementation of the designated route system. 
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Record of Decision 

ROD- 14 Klamath National Forest 

Priorities/Timelines 

A number of follow-up actions are needed to implement this decision for the disposition of all 

routes to be completed and for the MVUM to fully reflect the travel management goals inherent 

in the decision. To better understand the timeframes associated with these follow-up activities, 

they have been grouped into the following three stages of implementation. 

First, prior to publication of the first MVUM, all necessary road and safety signing will be put 

in place. The first MVUM will designate: (1) the routes listed in Appendix A of the FEIS that do 

not require mitigation, or for which mitigation has been completed, as open to motorized travel; 

(2) the mixed use segments of ML3 roads as open to mixed use; and (3) the NFTS ML3 roads 

that are changed from ML3 to ML2 status as open to non-highway legal vehicles. 

Second, routes listed in Appendix A of the FEIS as requiring mitigation, and for which 

mitigation has not yet been completed, will be identified in a second MVUM as open to public 

motorized travel as soon as mitigation is complete. 

Third, there are routes or re-routes that the public asked to be considered for motor vehicle 

use that cannot be added through this process without conducting additional site-specific 

analysis. These proposals will require consideration in separate environmental analyses. The 

KNF will work with motorized recreation users and other interested parties to prioritize these 

routes for future consideration of their potential for addition to the MVUM. Future decisions may 

also be made to remove routes from the MVUM if resource concerns arise that cannot be 

mitigated or if alternative routes are found that better meet the need for motor vehicle use. 

Maps/Brochures 

Based on the selected alternative, the KNF will produce a primary MVUM following NFS 

standards that indicates which routes are designated open to the public by type of vehicle per 

route. The MVUM will be used as an information and education tool, and for law enforcement 

purposes. This map will be made available to the public free of charge. Route and open riding 

area designations, use restrictions, and operating conditions will be revised in future decisions 

as needed to meet changing conditions or management strategies. A KNF brochure will be 

developed as a companion document to the MVUM with clear and simple explanations of the 

rules and restrictions, and examples of signs on the ground. 

Signing 

The Forest will supplement the MVUM by signing NFTS roads and trails that are open to public 

motor vehicle use on the ground with a road or trail number and applicable regulatory 

information. Clear, consistent, and adequate signs will be installed to identify trails designated 
Motorized Travel Management 

Record of Decision 

Klamath National Forest ROD-15 

open by type of vehicle per route corresponding to the public MVUM. Signing of dead-end 

routes leading to or stopping at private land or rivers, streams, and other sensitive resources will 

be a priority to help protect private land and KNF resources.

Public Outreach 

Successful implementation of this decision will require an extensive program of public education 

and outreach. The following components have been identified as key elements of this program: 

1) Development of a public education strategy to help KNF visitors understand about the 

designated route system, to assist with reading and understanding the MVUM and local 

travel map, and to discuss how the public can help with implementation of the designated 

system by volunteering for maintenance activities, enforcement of the rules, and sharing 

knowledge with other visitors. 

2) Continuing collaborating with groups interested in the addition, modification, or management 

of NFTS roads, trails, and areas on the KNF in order to build additional stewardship 

opportunities for the public and improve our transportation system. The activities of these 

groups could include, but are not limited to: 

a) Developing a public volunteer strategy to identify opportunities for the public to help 

implement, enforce, maintain, and fund the designated route system. 

b) Expanding a core of dedicated volunteers capable of supporting ongoing resource 

protection efforts, expanding the dissemination of public information, ensuring the 

effectiveness of resource monitoring, and maintaining the NFTS infrastructure (including 

signs, kiosks, roads, trails, and restoration efforts). 

c) Developing a public education strategy to share information with Forest visitors about 

the designated route system, how to read the public MVUM and use best practices for 

minimizing impacts potentially resulting from motorized travel activities. 

d) Assisting with the implementation of actions included in this decision such as disguising 

unauthorized route entrances. 

3) Continue the examination of the adequacy of the designated system of routes and 

recommend modifications or adjustments to the system to be addressed in subsequent 

environmental analysis and decisions. 

Public Involvement 

Public involvement for Motorized Travel Management (formerly Motorized Route Designation) 

on the KNF began in 2004. Public involvement occurred during the public collaboration process 

that began with several meetings with recreational users of the KNF in California and Oregon, 

continued during the public scoping period for the Notice of Intent (NOI) to prepare an EIS, and 

included meetings with public groups to explore issues raised during the scoping period. 

The Responsible Official and Interdisciplinary Team (IDT) relied on public involvement to 

ensure that a full range of alternatives, representing a broad array of perspectives, would be 
Motorized Travel Management 

Record of Decision 

ROD- 16 Klamath National Forest 

analyzed. Public workshops held at Yreka, Greenview, Happy Camp and Macdoel in May 2005 

were designed to introduce the route designation process and ask the public to identify 

motorized routes and areas they were currently using. Discussion topics at these workshops 

included an overview of the Travel Management Rule and national, regional and local direction 

to implement this Rule; why the KNF was undertaking this effort; what route designation is, the 

5-step route designation process, and the time each step was likely to take; and when and how 

the public could be involved. The public was asked to provide maps of routes and areas being 

used by the end of August, 2005. Routes and areas on these maps became the initial list of 

publicly-identified routes to be considered in the process. At additional public meetings in 

February and March of 2007, in Yreka, Fort Jones, Happy Camp, and Macdoel, the KNF shared 

the maps, and asked for user assessments of the recreational value of identified routes and 

areas; this input was requested by the end of August of 2007. During this time, presentations 

were also made to numerous civic organizations, environmental groups, and recreational user 

clubs as well as to the Siskiyou County Board of Supervisors to inform them of the travel 

management process. The KNF also provided travel management information and consulted 

with American Indian tribes, including the Hoopa Tribe, Karuk Tribe, Klamath Tribes, Yurok 

Tribe, Pit River Tribes, Confederated Tribes of Grand Ronde Community, and Confederated 

Tribes of Siletz Indians, Quartz Valley Reservation, Shasta Indian Nation, and Shasta Tribe, Inc. 

By autumn of 2007, the KNF had identified and evaluated resource issues and concerns with 

the identified routes and areas, and produced maps of preliminary resource screening of routes. 

In March 2008, public workshops were held again at Yreka, Fort Jones, Happy Camp, 

Orleans, and Mcdoel. The purpose of these workshops was to share the conceptual plan based 

on analysis and resource evaluations of unauthorized routes and areas; to present preliminary 

maps of routes that had passed the resource screening and would be analyzed further; and to 

provide an opportunity to comment on any routes that were missed. The public identified almost 

500 miles of unauthorized routes and two areas they wanted to have considered for addition to 

the NFTS. The Motorized Travel Management project was posted on the Schedule of Proposed 

Actions for the Klamath National Forest in July 2008. 

Scoping for the Notice of Intent 

On October 7, 2008, the “Proposed Action and NOI to Prepare an Environmental Impact 

Statement” was published in the Federal Register (Volume 73, Number 195). A legal notice of 

the proposed action in the newspaper of record, the Siskiyou Daily News, on the same date 

initiated the scoping period that began that day and was scheduled to end on November 6, 

2008. An extension was requested by a number of individuals and organizations, and the 

scoping period was extended 30 days, ending on December 6, 2008. Presentations to a variety 

of groups, phone calls, news releases, website postings, and e-mails were used to alert the 

public of the initiation of scoping and extension of the scoping period. Open houses were held in 

Happy Camp, Ft. Jones, Macdoel and Yreka to explain the Proposed Action. The agency 
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Record of Decision 

Klamath National Forest ROD-17 

received scoping comments from 72 individuals, agencies, tribes and organizations (including 

letters, e-mails, and hand-delivered documents). All of this is summarized in the Scoping Report 

and the Content Analysis Report, Klamath National Forest, Travel Management Plan NOI, 

hereby incorporated by reference and found in the Project Record. Using the comments from 

the public, other agencies and governments, tribes, and agency resource specialists, the IDT 

developed a list of issues to address. 

Siskiyou and Jackson County officials were informed of the KNF’s plans and intent 

throughout this process. Another presentation was done to the Siskiyou County Board of 

Supervisors in 2008 to present the Proposed Action and answer questions about the process. 

The KNF shared the NOI with officials of Siskiyou County and worked with them to develop 

alternative ways to manage motorized travel that incorporated interests of the County. In 2008, 

the KNF also shared the motorized mixed-use analysis with Siskiyou County to coordinate the 

designation of NFTS roads. In 2009, the KNF provided a briefing to the Jackson County 

Commissioners. The mixed-use analysis was submitted to the local California Highway Patrol 

office for concurrence on the safety aspects of designating ML3 roads less than 3 miles in 

length for non-highway legal motorized use, and to share information on downgrading some 

ML3 roads to ML2 to accomplish the same purpose and save annual maintenance costs. 

Draft Environmental Impact Statement Comment Period

Following more than 5 years of work and many public workshops, tribal consultations, meetings 

with local government officials, and presentations to a wide variety of interest groups, the Draft 

Environmental Impact Statement (DEIS) was released for public comment. Interested parties, 

tribes and reviewing agencies were sent a letter (via email or by mail) announcing the 

availability of the DEIS. The DEIS and maps were posted on the KNF website the same day. 

Hard copies and/or compact discs (CDs) of the DEIS were sent to tribes, reviewing agencies 

and any individuals or organizations that requested such documents. All agencies, tribes and 

individuals received a summary and website location for downloading documents and maps. 

The notice of availability was published by the Environmental Protection Agency in the Federal 

Register on June 5, 2009, and a legal notice was published in the Siskiyou Daily News on the 

same date which initiated the 45-day comment period. Public open houses were held in June 

2009 in Fort Jones, Happy Camp, Macdoel and Yreka to provide the public with an opportunity 

to comment and to ask questions regarding the DEIS. 

The KNF received several comments requesting an extension to the comment period. I 

decided to extend the comment period for an additional 15 days. On July 9, 2009, a legal notice 

explaining the extension was published in the Siskiyou Daily News. A letter was also sent to 

interested parties, reviewing agencies and tribes on noting the extended comment period. The 

Environmental Protection Agency published an amended notice in the Federal Register 

extending the comment period on July 24, 2009. 
Motorized Travel Management 

Record of Decision 

ROD- 18 Klamath National Forest 

The KNF received 418 total responses to the DEIS, including 22 original responses and 396 

form letters or modifications of form letters. A summary of the comments, and KNF responses to 

comments, appears in Appendix E of the FEIS. 

Final Environmental Impact Statement Comment Period

A Notice of Availability for the Final Environmental Impact Statement was printed in the Federal 

Register on January 29, 2010, and a legal notice in the Siskiyou Daily News on the same date. 

The latter initiated a 30-day comment period on the FEIS, ending March 1, 2010. Hard copies 

and/or CDs of the FEIS were sent to tribes, reviewing agencies, and any individuals or 

organizations that requested such documents. All who had participated in scoping or made 

comments on the DEIS received a summary and website location for downloading documents 

and maps. The letters summarizing the FEIS included a notation that public comments made on 

the DEIS did not need to be resubmitted on the FEIS. Public open houses were held in 

February 2010 in Happy Camp, Macdoel, Etna, and Yreka to provide an opportunity to comment 

on and ask questions concerning the FEIS. Comments were received from 34 individuals, 

agencies and organizations. All comments received were considered in my decision. 

Comments specific to the FEIS, and KNF responses to these comments, are addressed in 

Appendix B of this Record of Decision. 

Identification of Issues 

Comments from the public, other agencies, local government and tribes were used to formulate 

issues concerning the Proposed Action. An issue is a matter of public concern regarding the 

Proposed Action and its environmental impacts. The Forest Service separated these issues into 

two groups: significant issues and non-significant issues. Significant issues were defined as 

those directly or indirectly caused by implementing the Proposed Action. Non-significant issues 

were identified as those: 1) outside the scope of the Proposed Action; 2) already decided by 

law, regulation, Forest Plan, or other higher-level decision; 3) irrelevant to the decision to be 

made; or 4) conjectural without supporting scientific or factual evidence. The Council on 

Environmental Quality (CEQ) NEPA regulations explain this delineation in Section 1501.7, 

“...identify and eliminate from detailed study the issues which are not significant or which have 

been covered by prior environmental review (Sec. 1506.3)... ” A summary of issues, comments, 

questions, and suggested alternatives is located in the Scoping Report, which is incorporated by 

reference in the Project Record. 

The KNF identified the following significant issues during scoping: 

Issue 1: The original Proposed Action (in the NOI) unreasonably restricts motorized recreation 

use by prohibiting cross-country travel. The proposed addition of only 92 miles of unauthorized 

routes (78 miles of NFTS roads and 14 miles of NFTS trails) to the NFTS does not provide 
Motorized Travel Management 

Record of Decision 

Klamath National Forest ROD-19 

enough motorized public access or diversity of motorized recreational opportunity to KNF lands 

including loops, connecting scenic destinations, campgrounds, local services, watersheds, and 

low and high elevation areas. 

Issue 2: The KNF NFTS is too large to provide adequate maintenance and administration given 

the current maintenance backlog. No new roads should be created as existing roads are largely 

unmaintained. 

Issue 3: Some roads proposed for addition to the NFTS are in close proximity to wilderness or 

inventoried roadless areas (IRAs). The designation of unauthorized routes near these areas 

would encourage incursion of motorized use into wilderness and impact the ability of people to 

enjoy a quiet recreation experience. 

Issue 4: Many of the unauthorized routes proposed for addition to the NFTS are poorly located 

and will cause adverse impacts to plants, wildlife, water quality, soils, riparian areas, and other 

natural resources. 

How Issues were Addressed in the DEIS and FEIS 

Issue 1 was addressed in the DEIS in Alternatives 5 and 6. Although neither proposed adding 

more miles of roads to the NFTS than were proposed for addition in the Proposed Action, 

Alternative 5 proposed adding 22 miles of motorized trail and Alternative 6 proposed 18 miles of 

motorized trails, compared to the Proposed Action which proposed adding 14 miles. Alternative 

5 also proposed adding mixed use to 272 miles of existing NFTS roads, and Alternative 6 

proposed 105 miles of mixed use, compared to the Proposed Action which proposed 119 miles. 

In the FEIS, Alternative 7 addressed Issue 1 by increasing the number of miles of use by nonhighway legal motor vehicles on ML3 roads by 131.5 miles, and by downgrading 133 miles of 

ML3 road to ML2 to allow motorized use by non-highway legal vehicles. Although the total 

number of miles of route proposed for addition to the NFTS is decreased from 78 in the 

Proposed Action to 53 in Alternative 7, the number of miles of motor vehicle trails being added 

to the NFTS increases by 6 miles over the Proposed Action. 

Issue 2 was addressed in the DEIS in Alternative 3 by not adding any routes to the NFTS, 

thus limiting the costs associated with new route additions. Alternative 4 addressed this issue as 

well, by adding 7 miles of roads and trails to the NFTS. In the FEIS, Alternative 7 addressed 

this issue by changing the objective maintenance level on 133 miles of ML 3 roads, thus 

decreasing annual maintenance costs.

Issue 3 was addressed in the DEIS in Alternative 3 by not adding any routes to the NFTS, 

and in Alternative 4 by not adding any routes in close proximity to wilderness. In the FEIS, 

Alternative 7 proposes the addition to the NFTS of 21 short routes (totaling 1.5 miles) to access 
Motorized Travel Management 

Record of Decision 

ROD- 20 Klamath National Forest 

dispersed recreation sites within 1⁄2 mile of wilderness boundaries (Recreation section of 

Chapter 3 of the FEIS). Mitigation for all action alternatives includes signing on routes within 1⁄4 

mile of a wilderness boundary to improve voluntary compliance with restrictions on motor 

vehicle use in wilderness (Chapter 2 of the FEIS). None of the action alternatives propose 

adding unauthorized routes to the NFTS within Inventoried Roadless Areas. 

Issue 4 is addressed in the DEIS through mitigation and monitoring applicable to all action 

alternatives as disclosed in Chapter 2 of the DEIS. In the FEIS, Alternative 7 addresses this 

issue by proposing addition to the NFTS of only unauthorized routes that are well-sited, thereby 

reducing any adverse impacts to plants, wildlife, water quality, soils, riparian areas, and other 

natural resources, as well as through mitigation and monitoring displayed in Chapter 2 of the 

FEIS. 

Alternatives Considered in Detail but Not Selected 

In addition to the Selected Alternative, I considered six other alternatives, analyzed in detail in 

the FEIS, which are summarized below. A more detailed comparison of these alternatives, and 

the alternatives considered but eliminated from detailed study, can be found in Chapter 2 of the 

FEIS. 

Alternative 1 (No Action) 

This alternative serves as a baseline for comparison among the alternatives, and is required by 

the implementing regulations of the National Environmental Policy Act (NEPA). The No Action 

Alternative represents the continuation of cross-country travel. Under the No Action Alternative, 

no changes would be made to the NFTS and there would be no prohibition of cross-country 

travel. Current management plans would continue to guide project area management. The 

Travel Management Rule would not be implemented, and no Motor Vehicle Use Map (MVUM) 

would be published. Motor vehicle travel by the public would not be limited to designated routes. 

Unauthorized routes would continue to have no status or authorization as NFTS facilities. 

There are a number of reasons I did not select this alternative. It does not implement the 

Travel Management Rule and does not meet the need for regulation of unmanaged motor 

vehicle travel as required by the Rule because cross-country travel, with the potential of 

continued route proliferation, could cause continued adverse resource impacts. This alternative 

has the most potential for negative effects on natural and cultural resources, conflicts with 

adjacent landowners and impacts on non-motorized or quiet recreation activities of any of the 

alternatives. It does not allow non-highway legal motor vehicle use to occur on any of the ML3 

roads. Continued use of 497 miles of unauthorized routes, and potential future proliferation of 

routes, could lead to negative resource impacts. 
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Record of Decision 

Klamath National Forest ROD-21 

Alternative 2 (Proposed Action) 

The Proposed Action, as described in the NOI published in the Federal Register, includes the 

following: prohibition of cross-country motorized travel, proposed changes to the existing NFTS 

(adding mixed use on 119 miles), and additions to the NFTS (adding 24 miles of unauthorized 

routes to access dispersed recreation sites, 54 miles as roads for a diversity of recreation 

experiences, 14 miles as motorized trails, and 65 acres in two open riding areas). This 

alternative was developed during the course of more than a year’s worth of public meetings, 

including workshops where the public identified important routes for addition. The focus of this 

alternative was to meet motorized recreation needs by adding some unauthorized routes to the 

NFTS and providing for some mixed use opportunities 

Alternative 2 represents a starting point for the development of Alternatives 4, 5, and 6. It 

regulates unmanaged motor vehicle use and provides access to 258 dispersed recreation sites 

but no reduction of annual maintenance costs by lowering maintenance levels on NFTS roads. 

After the development of Alternative 2, it was determined that some of the unauthorized routes 

proposed for addition to the NFTS were not well-sited to protect cultural and natural resources 

(for instance, 2 routes crossed perennial streams) and some were not locatable on the ground. I 

did not choose Alternative 2 for these reasons. This alternative also did not include almost 13 

miles of unauthorized route traditionally used by highway legal vehicles in the Butte Valley 

National Grassland, and did propose adding to the NFTS one route to a dispersed campsite that 

is in an area in which Port-Orford-Cedar root disease might spread. 

Alternative 3 

Alternative 3 meets the objective of prohibiting cross-country motorized travel, but proposes no 

additions or changes to the NFTS. This alternative provides a baseline for comparing the 

impacts of other alternatives that propose changes to the NFTS. None of the currently 

unauthorized routes would be added to the NFTS under this alternative and motorized access 

beyond existing NFTS routes would be prohibited except as allowed by permit or other 

authorization. No maintenance levels would be changed on system roads and mixed use would 

not be allowed on any ML3 roads. This alternative responds to the issue of cost by not adding 

any new facilities to the NFTS, but does not realize savings from changes in maintenance levels 

as proposed in Alternative 7. 

There are a number of reasons that I did not select this alternative. Although this alternative 

meets the need to regulate unmanaged motor vehicle use, the diversity of motor vehicle 

recreation opportunities and access to dispersed recreation are all confined to the existing 

NFTS. This alternative does not incorporate routes suggested by the public that provide 

additional important dispersed recreation opportunities. Alternative 3 is the environmentally 

preferable alternative if only biological and physical factors are considered in that unauthorized 

routes are no longer available for travel and resource-related damage caused by continued use 

or proliferation of unauthorized routes would not occur. This alternative was not chosen because 
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Record of Decision 

ROD- 22 Klamath National Forest 

it does not provide a diversity of motorized recreation opportunities or access to dispersed 

recreation sites. This alternative also did not include almost 13 miles of unauthorized route 

traditionally used by highway legal vehicles in the Butte Valley National Grassland. 

Alternative 4 

Alternative 4 addresses access, economics and natural resource protection. This alternative 

meets the need of providing diverse motor vehicle riding opportunities by improving riding 

opportunities for non-highway legal vehicles on 119 miles of NFTS roads, and adds 7 miles of 

additional routes. Under this alternative a combination of vehicle class changes and minimal 

addition of unauthorized routes to the NFTS are used to address concerns about both dispersed 

recreation access and riding opportunities for non-highway legal vehicles, while constraining the 

resource and economic impacts from addition of many routes. This alternative would not create 

motor vehicle riding opportunities in open riding areas. This alternative provides the most 

opportunity for quiet recreation of all the action alternatives other than Alternative 3. 

Although this alternative regulates unmanaged motor vehicle travel, provides a diversity of 

recreation opportunities and riding experiences in the context of the existing NFTS, and 

contains costs by adding just 7 miles to the NFTS, it was not chosen because it does not 

provide the quality and quantity of recreation diversity and access to dispersed recreation that 

are offered by the Selected Alternative. This alternative also did not include almost 13 miles of 

unauthorized route traditionally used by highway legal vehicles in the Butte Valley National 

Grassland. 

Alternative 5 

Alternative 5 addresses access to dispersed recreation sites and a diversity of motorized 

recreation opportunities through adding 69 miles of unauthorized routes, and 2 open riding 

areas totaling 53 acres, to the NFTS. It also would allow non-highway legal motor vehicles on 

278 miles of existing ML3 roads and one ML4 road. In this way, the alternative meets the needs 

of access to dispersed recreation and diverse riding opportunities. This alternative would be 

relatively expensive to implement and would have higher annual maintenance costs because no 

ML3 roads would be downgraded to ML2. 

 I did not select this alternative because I was concerned about the locations of some of the 

routes proposed for addition to the NFTS, three of which would have crossed perennial streams. 

This alternative also did not include almost 13 miles of unauthorized route traditionally used by 

highway legal vehicles in the Butte Valley National Grassland, and did propose adding to the 

NFTS one route to a dispersed campsite that is in an area in which Port-Orford-Cedar root 

disease might spread. 
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Record of Decision 

Klamath National Forest ROD-23 

Alternative 6 

Alternative 6 addresses access to dispersed recreation sites and a diversity of motorized 

recreation opportunities through adding 59 miles of unauthorized routes, and 2 open riding 

areas totaling 53 acres, to the NFTS. It also would allow non-highway legal motor vehicles on 

105 miles of existing ML3 roads. In this way, the alternative meets the needs of access to 

dispersed recreation and diverse riding opportunities. This alternative would have been 

somewhat expensive to implement and would have high annual maintenance cost in that none 

of the ML3 roads would be downgraded to ML2. 

 I did not select this alternative because I was concerned about the locations of some of the 

routes proposed for addition to the NFTS, three of which would have crossed perennial streams. 

This alternative also did not include almost 13 miles of unauthorized route traditionally used by 

highway legal vehicles in the Butte Valley National Grassland, and did propose adding to the 

NFTS one route to a dispersed recreation area in a location in which Port-Orford-Cedar root 

disease might spread. 

Environmentally Preferable Alternative 

The environmentally preferable alternative is often interpreted as the alternative that causes the 

least damage to the biological and physical environment, but other factors relevant to this 

determination are provided in Section 101 of NEPA. These include fulfilling the responsibilities 

of each generation as a trustee of the environment for succeeding generations; assuring safe, 

healthful, productive, and aesthetically and culturally pleasing surroundings for all Americans; 

and achieving a balance between population and resource use which will permit high standards 

of living and a wide sharing of life’s amenities. If I take into account only the physical and 

biological effects, I would consider Alternative 3 to be the environmentally preferable alternative 

because it prohibits cross-country travel on the entire KNF, and adds no unauthorized routes or 

open riding areas to the NFTS. Based on my consideration of all these factors and the effects 

disclosed in the FEIS, however, I consider Alternative 4 to be the environmentally preferable 

alternative because it prohibits cross-country travel on the entire KNF, adds no open riding 

areas and just 7 miles of roads and trails to the NFTS, and provides additional motorized 

recreation opportunities for non-highway legal vehicles on 119 miles of existing NFTS roads 

while restricting motor vehicle use to highway legal vehicles on about 8 miles of route leading to 

private land. My reasons for not selecting Alternatives 3 or 4 are provided above. 

Legal and Regulatory Compliance 

My decision complies with the laws, policies, and executive orders listed below and described in 

Chapter 2 and 3 of the FEIS. 
Motorized Travel Management 

Record of Decision 

ROD- 24 Klamath National Forest 

Forest Plan Consistency 

My decision includes one Forest-wide amendment to the management direction contained in the 

Forest Plan as well as one site-specific amendment to the LRMP. 

Non-significant Forest-wide Plan Amendment: This is a Forest-wide Forest Plan 

amendment to prohibit motor vehicle travel off designated roads, trails, and outside open riding 

areas where such motor vehicle use is currently permitted (on approximately 1.2 million acres of 

the KNF). 

Non-significant Site-specific Forest Plan Amendment: This is a site-specific plan 

amendment to exempt approximately 12.8 miles of added road in the Butte Valley National 

Grassland from a season of use restriction due to Swainson’s hawk nesting. 

Evaluation of Significance 

The National Forest Management Act (NFMA) requires evaluation of whether proposed forest 

plan amendments would constitute a significant change in the long-term goods, outputs and 

services projected for the National Forest. The following criteria are used to determine the 

significance of Forest Plan amendments (FSM 1926.51-52). 

FSM 1926.51 - Changes to the Forest Plan that are Not Significant. 

Changes to the Forest Plan that are not significant and can result from: 

1) Actions that do not significantly alter the multiple-use goals and objectives for longterm land and resource management 

The Forest-wide amendment prohibiting cross-country travel, and the site-specific 

amendment to allow traditional use of highway legal vehicles on the Butte Valley National 

Grassland during the nesting season for Swainson’s hawks (which the project biologist 

found to be habituated to highway vehicle use and not disturbed by traffic during nesting), 

are both consistent with the Forest Plan goals to provide recreation opportunities while 

protecting natural and cultural resources. 

2) Adjustments of management area boundaries or management prescriptions resulting 

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

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

There are no boundary adjustments in either Forest Plan amendment. Management 

prescriptions adjusted in amendments do not cause significant changes in the multiple-use 

goals and objectives of providing recreation opportunities while protecting resource values. 

3) Minor changes in standards and guidelines; and, 

These Forest Plan amendments would necessitate minor changes in the standard and 

guidelines for the Butte Valley National Grassland and other management areas that now 

allow cross-country motorized travel. 

4) Opportunities for additional management practices that will contribute to 

achievement of the management prescription. 
Motorized Travel Management 

Record of Decision 

Klamath National Forest ROD-25 

The Forest-wide amendment would allow added management practices that contribute to 

management prescriptions that protect natural and cultural resources. The site-specific 

amendment would allow traditional recreation use to continue. 

FSM 1926.52 - Changes to the Land Management Plan that are Significant. 

The following examples indicate circumstances that may cause a significant change to a land 

management plan: 

1) Changes that would significantly alter the long-term relationship between levels of 

multiple-use goods and services originally projected [section 219.10(e) of the 

planning regulations in effect before November 9, 2000 (36 CFR parts 200 to 299, 

revised as of July 1, 2000)]

Neither Forest Plan amendment would alter the long-term relationships between the levels 

of goods and services projected in the Forest Plan. 

2) Changes that may have an important effect on the entire land management plan or 

affect land and resources throughout a large portion of the planning area during the 

planning period

The Forest-wide amendment would have an effect on a large portion of the planning area 

during the planning period but this effect would not be important to the entire Forest Plan. 

The effect on the land and resources of the KNF would be beneficial. The site-specific 

Forest Plan amendment does not have implications for the entire Forest Plan, or the land 

and resources over a large portion of the planning area. 

Conclusions 

I have determined that the Forest Plan amendments included in my decision: 

a. Do not significantly alter the multiple-use goals and objectives for long-term land and 

resource management. 

b. Do not cause significant changes in the multiple-use goals and objectives for long-term 

land and resource management. 

c. Represent minor changes in Standards and Guidelines. 

d. Provide opportunities for additional management practices that contribute to 

achievement of the management prescription. 

e. Do not alter the long-term relationships between the levels of goods and services 

projected in the Forest Plan. 

f. Do not change land allocations or management direction for other elements of the Forest 

Plan. 

Based on consideration of the factors above, and the analysis contained in the FEIS, I 

determined that neither the forest-wide nor the site-specific Forest Plan amendment is 

significant in the context of NFMA. I hereby amend the Forest Plan with the non-significant 

amendments discussed above. 
Motorized Travel Management 

Record of Decision 

ROD- 26 Klamath National Forest 

Travel Management Regulations 

The Travel Management regulations require that certain criteria be considered when 

designating routes for motor vehicle use (36 CFR 212.55(a) through (e)). These criteria have 

been considered at all stages of this process beginning with the development of the underlying 

Purpose and Need, development of the alternatives, analysis of effects (as documented in the 

‘Compliance with the Forest Plan and Other Direction’ sections of each resource section in 

Chapter 3 of the FEIS), and ultimately my selection of Alternative 7. Throughout the ROD and 

the FEIS, there are many specific examples of how I considered the Travel Management Rule 

criteria in making this decision. The criteria for designation of NFTS roads, trails and areas from 

Subpart B of the travel management regulations (36 CFR 212.55) are outlined in two sections, 

212.55 (a & b). I considered these criteria in my decision: 

Impacts to natural and cultural resources

My decision will not adversely affect cultural resources (Cultural Resources section of Chapter 3 

of the FEIS). For sites where the FEIS discloses uncertainty regarding effects, this decision 

includes monitoring of these sites per the stipulations in the Motorized Recreation Programmatic 

Agreement. Further, this decision is in full compliance with Programmatic Agreements with the 

State of California. The State Historic Preservation Office of Oregon has been consulted and 

has determined that this undertaking will have no effect on cultural resources on the part of the 

KNF in Oregon. 

For information on impacts to natural resources see Travel Rule 212.55 (b) 1 and 2 below. 

Public safety 

Public safety has been my top priority when considering whether to allow non-highway legal 

motor vehicle use on ML3 roads. The Selected Alternative authorizes non-highway legal motor 

vehicle use on only those ML3 roads that have been determined to be generally safe 

(Transportation section of Chapter 3 and Appendix C of the FEIS). 

Safety from exposure to naturally occurring asbestos has also been a top priority. None of 

the unauthorized routes proposed for addition to the NFTS are underlain by ultramafic rock (a 

source for naturally-occurring asbestos) except for 27 short spurs to dispersed recreation sites. 

As discussed in the Geology section of Chapter 3 of the FEIS, it is unlikely that motor vehicles 

could reach speeds sufficient to generate dust on these short spurs. However, to provide 

additional margins of safety, these short routes have been sampled and tested. None of the 

sampled routes showed evidence of naturally occurring asbestos using the California Air 

Resource Board standard of 0.25% as discussed in the Geology section of Chapter 3 of the 

FEIS. These routes are considered to be safe for public use and will be added to the NFTS. 

Provide for recreational opportunities. 

I carefully considered diversity of recreational opportunities and access to dispersed recreation 

in adding selected unauthorized routes to be added to the NFTS by this decision. Although the 

existing NFTS generally provides access to major developed recreation areas and for KNF 

management activities, it does not contain some routes that are important for accessing long-
Motorized Travel Management 

Record of Decision 

Klamath National Forest ROD-27 

used dispersed recreation opportunities. The Selected Alternative addresses this need by 

adding 25 miles of roads to user-identified dispersed recreation areas and 28 miles for diverse 

riding opportunities. Among these 25 miles to dispersed areas, there are at least 191 individual 

routes with known dispersed campsites or river access points. The enhanced transportation 

system in the Selected Alternative will provide access to sites and routes that are important to 

Forest users for camping, backpacking, hiking, sightseeing, exploring, fishing, and hunting, 

among other activities. 

The Selected Alternative also provides diverse recreation opportunities by providing access 

to a variety of riding experiences through creating additional OHV loop riding opportunities that 

include a combination of additions to the NFTS and changes to the NFTS (mixed use and 

lowering of maintenance levels on some roads). The Selected Alternative provides more than 

20 miles of motor vehicle trails. This alternative also downgrades objective maintenance levels 

from ML 3 to ML 2 on 133 miles of NFTS roads and changes maintenance level on more than 

131 miles of ML3 roads to allow safe use by both highway legal and non-highway legal vehicles. 

Access to public and private lands 

When identifying trails to add to the NFTS, I focused on meeting the needs of the public by 

providing access to the most desired trails and roads on the Forest. In addition, my decision will 

not impact access to private lands, as this project does not designate roads or trails through 

private lands where the Forest Service does not have right-of-way, nor will it change existing 

rights-of-way for adjacent private landowners. Private landowners that need to use one of the 

unauthorized routes that were not added through this effort can work with the KNF on an 

individual basis to obtain special use permits that will grant them the needed access. 

Conflicts among uses of National Forest System lands

When developing the alternatives to the proposed action, the issue of use conflicts was 

addressed by seasonally separating use on 32 NFTS roads by over-snow vehicles and vehicles 

other than those that travel over-snow in order to avoid user conflicts. 

Need for maintenance and administration of roads, trails and areas that would 

arise if the uses under consideration are designated

The Forest currently has a deferred maintenance backlog for roads of approximately $20 million 

(see Appendix C of FEIS). This alternative carefully considers the availability of resources for 

maintenance and administration of roads, trails and areas given a combination of additions and 

changes to the existing NFTS maintenance levels. As stated previously, the additions proposed 

in Alternative 7 would result in an implementation cost of approximately $121,500 

(Transportation section of Chapter 3 of the FEIS). Annual maintenance costs would decrease 

by at least $25,000 to $50,000 from the $3 million needed to maintain the existing NFTS. I have 

determined that the Forest would have sufficient resources to administer and maintain the 

additional NFTS within the Selected Alternative. 
Motorized Travel Management 

Record of Decision 

ROD- 28 Klamath National Forest 

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

Routes added to the NFTS as part of my decision are expected to maintain and improve water 

quality and satisfy all federal and state water quality requirements. Only one route addition to 

the NFTS crosses a perennial stream channel; this route has been carefully examined by 

fisheries biologists from both the KNF and National Marine Fisheries Service, will be rocked to 

mitigate any effects to fish, and will be monitored for at least 5 years as stated in the Fisheries 

section of Chapter 3 of the FEIS and the Fish Biological Assessment. My decision minimizes 

impacts to both soil and water resources, including riparian and aquatic habitats, by only adding 

routes where adverse impacts could be either avoided or mitigated to acceptable levels. This 

decision adds 20 miles to the NFTS that go through riparian reserves; however, less than 1 mile 

is located within riparian habitats (affecting about 1.2 acres). These routes were carefully 

considered and will not negatively impact water quality or fish. The full analysis displaying these 

effects can be found in the Hydrology section of Chapter 3 of the FEIS. 

Botanical Resources 

The analysis contained within the Botanical Resources section of Chapter 3 of the FEIS 

determined that my decision is not likely to result in a trend toward federal listing or loss of 

viability for any sensitive plant species. The project includes species-specific mitigation to 

reduce or avoid potential impacts to rare plants, including monitoring of the one higher risk route 

to ensure rare plants are protected. My decision includes mitigation to control high priority weed 

occurrences adjacent to designated routes and direction to clean road maintenance equipment 

to prevent further weed spread (Non-native Invasive Species section of Chapter 3 of the FEIS). 

Harassment of wildlife and significant disruption of wildlife habitat

I considered whether there would be harassment of wildlife or significant disruption to wildlife in 

this decision. The terrestrial wildlife analyses indicate that such effects, if they occur, would be 

minor. 

Aquatic Resources 

I considered whether there would be direct effects to Federally-listed Southern Oregon Northern 

California Coastal (SONCC) coho salmon or significant disruption to fish habitat for this species 

in this decision. I also considered possible effects to Chinook salmon or steelhead trout 

sensitive fish species and their habitat. This decision adds only one route that would directly 

cross a perennial stream that provides habitat for federally listed or sensitive aquatic species. 

For all Federally-listed and Forest Service sensitive aquatic species, it was determined that the 

Selected Alternative may affect species and habitat but would not result in a trend towards 

Federal listing or a loss of viability (Fisheries section of Chapter 3 of the FEIS and Fish 

Biological Assessment and Evaluation, located in the process records). 

Conflicts between motor vehicles and existing or proposed recreational uses of 

NFS lands or neighboring Federal lands

This decision does not add any routes in Wilderness Areas, “Wild” portions of the Wild and 

Scenic Rivers, Inventoried Roadless Areas, or within Primitive or Semi-primitive Non-motorized 
Motorized Travel Management 

Record of Decision 

Klamath National Forest ROD-29 

Recreation Opportunity Spectrum classes (Recreation and Inventoried Roadless Area sections 

of Chapter 3 of the FEIS). It addresses route conflicts between recreationists, both on the 

existing NFTS and on new additions connected to the existing NFTS, by adding trails for motor 

vehicle use and not allowing motor vehicles to use other KNF trails (Alternatives Considered but 

Eliminated from Detailed Study section of Chapter 2, and Recreation and Society, Culture and 

Economy sections of Chapter 3 of FEIS). 

Conflicts among different classes of motor vehicle uses on NFS lands or 

neighboring Federal lands 

My decision minimizes the potential for conflicts between different classes of vehicles by 

designating some routes specifically for certain vehicle classes, and by separating season of 

use by wheeled vehicles and snowmobiles. 

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

taking into account sound, emissions, and other factors

Most of the routes added to the NFTS are located far from populated areas. The Selected 

Alternative adds no routes within 1/2 mile of communities, areas with higher densities of 

residences, or commercial buildings (Recreation section of Chapter 3 of the FEIS). 

Speed, volume, composition and distribution of traffic on roads 

I have determined that the terrain, sight distance, and condition of the road surface of the 73 

miles of unauthorized routes being added to the NFTS makes them suitable as low standard 

roads or motorized trails rather than higher standard roads. The number of roads and trails 

added in the Selected Alternative coupled with the existing road and trail system are expected 

to continue to support low traffic densities on most of the NFTS. Signs to warn drivers of the 

class of vehicles authorized and expected on particular routes will be posted as part of the 

implementation of the route designation process. Maintenance Level 3 NFTS routes designated 

for mixed use will be signed appropriately to warn drivers of mixed use (Ch. 2 Mitigation 

Measures). 

Compatibility of vehicle class with road geometry and road surfacing

Routes added to the NFTS will be designated as either Maintenance Level 2 roads or motorized 

trails based on vehicle compatibility considerations and the need to provide a range of different 

recreational opportunities. The analysis of each Maintenance Level 3 road proposed for 

motorized mixed use considered the compatibility of each vehicle class with the road geometry 

and surfacing based on an assessment of the type and size of vehicle in conjunction with the 

driver’s level of skill. 

Maintaining valid existing rights of use and access (rights-of-way)

When identifying routes to add to the NFTS, I focused on meeting the needs of the public by 

providing access to the most desired trails and roads on the KNF. In addition, my decision will 

not impact access to private lands, as this project does not designate roads or trails through 

private lands where the Forest Service does not have right-of-way, nor will it change existing 

rights-of-way for adjacent private landowners. Private landowners that need to use one of the 
Motorized Travel Management 

Record of Decision 

ROD- 30 Klamath National Forest 

unauthorized routes that were not added through this effort can work with the Forest on an 

individual basis to obtain special use permits that will grant them the needed access. 

Findings Required by Other Laws and Regulations 

The National Environmental Policy Act at 40 CFR 1502.25(a) directs “to the fullest extent 

possible, agencies shall prepare draft EIS concurrently with and integrated with ...other 

environmental review laws and executive orders.” Each resource section in the FEIS includes a 

list of applicable laws, regulations, policies and Executive Orders that are relevant to that 

resource. Surveys, analyses, and findings required by those laws are specifically addressed in 

Chapter 3 of the FEIS. These laws include: 

National Forest Management Act. With the proposed Forest Plan amendments, 

consistency with the National Forest Management Act is addressed in the Forest Plan 

Consistency section. The decision for the MTM project is also compliant with the 2001 Record 

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

Protection Buffers, and Other Mitigation Measures Standards and Guidelines (2001-ROD) with 

updates from annual species reviews. Pertinent information from annual species reviews was 

considered part of the best available information in developing the FEIS for the MTM project. I 

used the results of an analysis that considered the potential for significant negative impacts to 

the habitats, life cycles, microclimates, or life support requirements of Survey and Manage 

species to determine the need for pre-disturbance surveys for the species per direction in the 

Standard and Guidelines Section (page 22) of the 2001-ROD. The analysis results are available 

in a process paper entitled Survey and Manage Species Analysis (Ford, J., Perrochet, J., and 

Knight, M., May 21, 2010) in the project record for the MTM FEIS at my office in Yreka, CA. 

Clean Water Act. Compliance with the Clean Water Act is achieved through implementation 

of the Total Maximum Daily Load (TMDL) action plans for the Scott and Salmon Rivers, and will 

be achieved through implementation of the TMDL action plan for the Klamath River when the 

plan is finalized. The Selected Alternative would help to achieve TMDL requirements by 

reducing road density, reducing vehicle-generated sediment, and reducing the potential for 

sediment delivery to streams by subjecting designated routes to improvement and maintenance 

of running surfaces. This project constitutes a control of sediment waste discharge as required 

under the Memorandum of Understanding between the Regional Water Quality Control Board 

and the U.S. Forest Service. Clean Water Act compliance is also achieved by implementing the 

1981 management agency agreement with the Water Board and the State of California that 

requires use of State-approved and Environmental Protection Agency certified Best 

Management Practices. 

Endangered Species Act. All Federally-listed Threatened and Endangered plant, wildlife 

and aquatic species under the jurisdiction of the US Fish and Wildlife Service (USFWS) were 
Motorized Travel Management 

Record of Decision 

Klamath National Forest ROD-31 

analyzed considering the existing regional programmatic consultation completed for route 

designation (USDA FS PSW Region 2006; USDI FWS 2006). A separate Biological Assessment 

(BA) was prepared for the northern spotted owl and marbled murrelet, including critical habitat. 

The determination for these species was May Affect, Not Likely to Adversely Affect with 

Beneficial Effects, and No Effect on critical habitat (see letter of concurrence from USFWS 

dated January 19, 2010). The BA for plants indicated No Effect to listed or candidate species; 

therefore, no further consultation with the USFWS was needed. The potential effects of 

implementing the Selected Alternative were analyzed for Federally-listed anadromous fish which 

are under the jurisdiction of the NMFS. The determination from the Fish BA was May Affect, 

Not Likely to Adversely Affect (see agreed upon Biological Assessment of January 19, 2010, 

and letter of concurrence dated April 5, 2010). 

Executive Order 13112 Invasive Species 64 FR 6183 (February 8, 1999). Consistent with 

this Order, this project has incorporated feasible and prudent mitigation measures in the 

Selected Alternative to minimize risk of harm caused by invasive species. All routes that have 

known high priority weeds within 100 feet will be monitored (and treated as practicable) in the 

early stages of project implementation as discussed in the Non-native Invasive Species section 

of Chapter 3 of the FEIS. Required weed treatment mitigations are listed in Appendix A of this 

ROD. 

National Historic Preservation Act. This project was designed to meet this act in California 

by following the Programmatic Agreement among the U.S.D.A. Forest Service, Pacific 

Southwest Region, California State Historic Preservation Officer and Advisory Council on 

Historic Preservation Regarding the Process for Compliance with Section 106 of the National 

Historic Preservation Act for Designating Motor Vehicle Routes and Managing Motorized 

Recreation on the National Forests in California (2005). The State Historic Preservation Office 

of Oregon has been consulted as disclosed in the FEIS, and this travel management 

undertaking was determined to have no effect on cultural resources on the part of the KNF in 

Oregon. 

Migratory Bird Treaty Act. Within the National Forests, conservation of migratory birds 

focuses on providing a diversity of habitat conditions at multiple spatial scales and ensuring that 

bird conservation is addressed when planning for land management activities. As part of the 

Travel Management process, the Klamath National Forest has conducted an assessment of 

unauthorized roads and trails within Forest boundaries. Any new construction, reconstruction 

and maintenance of system roads or trails will be conducted under a separate NEPA analysis 

and decision. Because current travel management efforts are directed at identifying which 

existing unauthorized routes will be formally added to the NFTS while prohibiting cross-country 

travel, and because there is no expectation of new construction or development, no changes in 

the distribution or abundance of habitats available to migratory birds are anticipated. Changes in 

authorization are not anticipated to contribute to measurable increase in use levels, but the 
Motorized Travel Management 

Record of Decision 

ROD- 32 Klamath National Forest 

prohibition of cross-country travel is expected to result in less use across the landscape. 

Therefore, habitat functionality is expected to remain similar or improve, and levels of 

disturbance related to use are expected to remain similar to or decline, from pre-decision levels. 

Special Area Designations 

I have determined that the Selected Alternative complies with laws, regulations, and policies 

that pertain to the following special areas. In addition, I believe that this decision enhances the 

values that make these special areas unique. 

Research Natural Areas. No routes are added to the NFTS for motor vehicle use within any 

of the Research Natural Areas. 

Special Interest Areas. No routes are added to the NFTS for motor vehicle use within any of 

the Special Interest Areas. 

Inventoried Roadless Areas. No routes are added to the NFTS for motor vehicle use within 

any of the Inventoried Roadless Areas (IRAs). Roadless characteristics will be maintained in all 

IRAs by the prohibition of motorized cross country travel which will help prevent the creation of 

unauthorized routes. 

Wilderness Areas. No routes are added to the NFTS for motor vehicle use within

Wilderness. 

Wild and Scenic Rivers. The Selected Alternative would add 12 short spurs (totaling 3.4 

miles) to the NFTS as roads within corridors of rivers classified as “Recreational” within the Wild 

and Scenic River system to access river launch points and dispersed camping sites. The 

Recreational classification allows development along shorelines. The Hydrology and Fisheries 

analyses have determined that the additions would meet requirements of the Aquatic 

Conservation Strategy and the Clean Water Act sufficient to protect the outstandingly 

remarkable values of the Wild and Scenic Rivers 

Administrative Review or Appeal Opportunities 

This decision is subject to appeal pursuant to 36 CFR 215. In accordance with the April 24, 

2006 order issued by the U. S. District Court for the Missoula Division of the District of Montana 

in Case No. CV 03-119-M-DWM, only those individuals and organizations who provided 

comments during the comment period are eligible to appeal [36 CFR 215.11(a), 1993 version]. 

Appeals must be filed within 45 days from the publication date of the legal notice in the Siskiyou 

Daily News. Notices of appeal must meet the specific content requirements of 36 CFR 215.14. 

An appeal, including attachments, must be filed (regular mail, fax, e-mail, hand-delivery, 
Motorized Travel Management 

Record of Decision 

Klamath National Forest ROD-33 

express delivery, or messenger service) with the appropriate Appeal Deciding Officer [36 CFR 

215.8] within 45 days following the publication date of the legal notice. The publication date of 

the legal notice is the exclusive means for calculating the time period to file an appeal [36 CFR 

215.15 (a)]. Those wishing to appeal should not rely upon dates or timeframe information 

provided by any other source. 

Appeals must be submitted to the Regional Forester, USDA Forest Service, 1323 Club 

Drive, Vallejo, CA 94592. Appeals may be submitted by FAX [(707) 562-9091] or by handdelivery to the Regional Office, at the address shown above, during normal business hours 

(Monday-Friday 8:00am to 4:00pm). Electronic appeals, in acceptable [plain text (.txt), rich text 

(.rtf) or Word (.doc or .docx)] formats, may be submitted to appeals-pacificsouthwest-regionaloffice@fs.fed.us with Subject: Klamath Motorized Travel Management. 

For electronically mailed appeals, the sender should normally receive an automated 

electronic acknowledgment from the agency as confirmation of receipt. If the sender does not 

receive an automated acknowledgment of the receipt of the appeal, it is the sender’s 

responsibility to ensure timely receipt by other means [36 CFR 215.6(a)(4)(iii)]. 

Implementation Date 

If no appeals are filed within the 45-day appeal period, implementation of the decision may 

occur on, but not before, five business days from the close of the appeal filing period. When 

appeals are filed, implementation may occur on, but not before, the 15th business day following 

the date of the last appeal disposition. 

Contact Person 

The FEIS and supporting documents are available for public review at the Klamath National 

Forest Supervisor’s Office, 1312 Fairlane Road, CA 96097. For further information on this 

decision, contact Togan Capozza, Recreation Officer at (530) 841-4467. 

Signature and Date 

/s/ Patricia A. Grantham 7/29/2010 

PATRICIA A. GRANTHAM Date

Forest Supervisor, Klamath National Forest 

Yreka, CA 

 
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Motorized Travel Management Record of Decision 

Appendix A: Modifications and Errata 

Klamath National Forest A-1 

Appendix A – Modifications of Alternative 7, Errata, and 

Route and Area Monitoring and Mitigation 

The following modifications to Alternative 7 are included in the Selected Alternative: 

• Season of use for the Humbug open riding area and trails in the Humbug drainage is 

changed from 5/1 through 10/31 to open year round based on new information from the 

California Department of Fish and Game (CDFG). The KNF had included a season of use

in the FEIS based on a verbal recommendation from CDFG. The CDFG subsequently 

concluded that closing this section of the KNF from 11/1 through 4/30 was not needed to 

protect deer using this portion of the designated winter range. The CDFG concluded that 

the overall effect of the Motorized Travel Management Preferred Alternative is to reduce 

disturbance to deer winter range. There is currently no seasonal restriction on motor 

vehicle travel on NFTS or Siskiyou County roads in the Humbug drainage so not 

imposing a seasonal restriction is not a significant change. An analysis of the effects of 

this modification, “Deer Disturbance in the Humbug Drainage” is included in the process 

record for this project. 

• Route 43N69 is changed from maintenance level 3 (ML 3) to ML 2 correcting an error in 

the FEIS. 

• Route 51-11a (also known as 47N22.Y1 in the Horse Heli project ROD) is scheduled to 

be decommissioned and will not be added to the NFTS. 

• Route 7J031.5A is removed from the routes to be added to the NFTS as motorized use 

was found to conflict with resource protection in a way that could not be mitigated. 

• Routes 43012001 and 45N88.2 are changed from requiring mitigation to requiring no 

mitigation, correcting an error in the FEIS. 

• Routes 7J031.5, 46083401 and 46083301 require mitigation to protect resources. The 

best way to provide these mitigations may require re-routing that is not included in the 

analysis of this FEIS. If so, the re-routing will be analyzed in a separate environmental 

analysis. These routes will not be added to the MVUM until mitigations are complete. 

• The citation in the FEIS for the Recovery Plan for Arabis macdonaldiana var. Eastwood

is corrected to omit var. Eastwood. 

• The title on the final row of Table NNIS-3 is corrected to omit “# of Sites with High” and 

read “Risk of Spread.”

• Table IRA-4 is corrected to 7 routes in the “SUBTOTAL” row for the Trinity Alps, in 

Alt. 5, 6, and 7, and mileage in Alt. 6 is corrected to 0.42 miles. Routes 54-58 and 54-59 

are removed from Alt. 6. The “TOTAL-ALL” row is corrected to 23 routes for Alt. 5, 19 

for Alt. 6, and 21 for Alt. 7.

• Table IRA-5 is corrected for the “Miles of routes added to NFTS within CIRAs” for Alt. 

2 (3.9), Alt. 5 (2.8), Alt. 6 (2.7) and Alt. 7 (2.5).
Motorized Travel Management Record of Decision 

Appendix A: Modifications and Errata 

A-2 Klamath National Forest 

• Methodology for IRA analysis is corrected to indicate that miles of route were multiplied 

by 640 acres (rather than 320 acres) representing a 1⁄2 mile buffer on either side of the 

route.

• The total acreage of citizen inventoried roadless areas in Table IRA-3 is corrected to 

355,227.

• Letters from federal, state and local governments (omitted from the FEIS) are attached.

The following tables include the routes that will be added to the NFTS in the Selected 

Alternative, or for which use will be changed. Monitoring and mitigation requirements 

applicable to all routes are not noted in these tables. Instead, only route-specific monitoring and 

mitigation are displayed. 

Table A-1 Routes Added as Roads 

Route ID Vehicle Class Length 

(miles) 

Monitor Mitigation Measure 

45N53.3 All 0.11 Erosion Improve drainage/establish tread 

46N24.1 All 0.06 

7H002.2 All 0.16 

Sedimentation 

Improve drainage/establish tread; 

improve stream crossing by rocking 

& shaping approach 

7J002.6 All 0.35 

6.1 All 0.18 

6.4 All 0.74 

77.5 All 0.44 

43N20.B1 All 1.00 

43N35.1 All 0.37 

43N67.2 All 0.31 

44N06Y.3 All 0.39 

44N08.7 All 1.08 

44N16.1 All 0.14 

44N27Y.2 All 0.52 

44N68.2 All 0.57 

44N75C.1 All 0.42 

44N83.1 All 0.09 

44N84.1 All 0.84 

44N89.1 All 1.83 

44N90A.1 All 0.27 

45N22Y.2 All 0.81 

46N04.6 All 0.22 
Motorized Travel Management Record of Decision 

Appendix A: Modifications and Errata 

Klamath National Forest A-3 

Route ID Vehicle Class Length 

(miles) 

Monitor Mitigation Measure 

5Q002.6 All 1.82 

6.4A All 0.57 

6P01.2 All 0.34 

6P01.3 All 0.11 

6P01.4 All 0.38 

8Q002.2 All 0.51 

8Q01.3 All 0.90 

8Q020.1 HLO 4.80 

S-97.2 HLO 7.00 

S-97.2A HLO 1.00 

Table A-2 Routes Added as Trails 

Route ID Vehicle Class Length

(miles) 

Monitor Mitigation Measure 

43012001 All Trail Vehicles 0.44 

45N88.2 All Trail Vehicles 3.00 

45080101 Vehicles < 50” 0.45 Improve drainage/establish tread 

45080104 Vehicles < 50” 0.23 Improve drainage/establish tread; 

delineate through signing, 

barriers, or brush to camouflage 

takeoffs of other routes 

45080205 Vehicles < 50” 0.74 Improve drainage/establish tread; 

delineate through signing, 

barriers, or brush to camouflage 

takeoffs of other routes 

45080207 Vehicles < 50” 0.65 Improve drainage/establish tread 

45080301 Vehicles < 50” 0.43 Improve drainage/establish tread 

46082601 Vehicles < 50” 0.38 Improve drainage/establish tread 

46082701 Vehicles < 50” 2.46 Improve drainage/establish tread 

46083301 Motorcycles only 1.13 Improve drainage/establish tread; 

delineate through signing, 

barriers, or brush to camouflage 

takeoffs of other routes 

46083401 Motorcycles only 2.43 Improve drainage/establish tread; 

delineate through signing, 

barriers, or brush to camouflage 

takeoffs of other routes 
Motorized Travel Management Record of Decision 

Appendix A: Modifications and Errata 

A-4 Klamath National Forest 

Route ID Vehicle Class Length

(miles) 

Monitor Mitigation Measure 

46083501 Vehicles < 50” 0.57 Improve drainage/establish tread 

46083502 Vehicles < 50” 0.94 Improve drainage/establish tread; 

delineate through signing, 

barriers, or brush to camouflage 

takeoffs of other routes 

46083503 Vehicles < 50” 0.57 Improve drainage/establish tread; 

delineate through signing, 

barriers, or brush to camouflage 

takeoffs of other routes 

46N24.2 Vehicles < 50” 0.12 

46N24.4 Vehicles < 50” 1.88 

46N24.4A Vehicles < 50” 0.20 Delineate through signing, 

barriers, or brush to camouflage 

takeoffs of other routes 

46N24.4B Vehicles < 50” 0.27 

46N24.5 Vehicles < 50” 0.77 Improve drainage/establish tread 

46N24.6 Vehicles < 50” 0.76 

46N30.9 Vehicles < 50” 0.18 Improve drainage/establish tread 

7J001.11 Vehicles < 50” 0.29 Improve drainage/establish tread; 

delineate through signing, 

barriers, or brush to camouflage 

takeoffs of other routes 

7J001.11A Vehicles < 50” 0.41 Improve drainage/establish tread; 

delineate through signing, 

barriers, or brush to camouflage 

takeoffs of other routes 

7J001.9 Vehicles < 50” 0.84 Improve drainage/establish tread 

7J031.5 Motorcycles only 0.05 Improve drainage/establish tread; 

delineate through signing, 

barriers, or brush to camouflage 

takeoffs of other routes 

8J002.3 Vehicles < 50” 0.24 Improve drainage/establish tread 

8J002.3C Vehicles < 50” 0.14 Improve drainage/establish tread 
Motorized Travel Management Record of Decision 

Appendix A: Modifications and Errata 

Klamath National Forest A-5 

Table A-3 Routes Added as Roads to Dispersed Recreation 

Sites 

Route ID Vehicle Class Length 

(miles) 

Monitor Mitigation Measure 

51-03 All Vehicles 0.02 

51-03a All Vehicles 0.18 

51-05 All Vehicles 0.02 

51-05a All Vehicles 0.03 

51-11 All Vehicles 0.10 

51-11a All Vehicles 0.13 

51-12 All Vehicles 0.34 

51-14 All Vehicles 0.05 

51-15 All Vehicles 0.12 

51-18 All Vehicles 0.19 

51-22 All Vehicles 0.09 

51-25 All Vehicles 0.16 

51-28 All Vehicles 0.11 

51-28a All Vehicles 0.03 

51-29 All Vehicles 0.03 

51-31 All Vehicles 0.07 

51-33 Hwy Legal 

Vehicles Only 

0.65 

 

51-34 Hwy Legal 

Vehicles Only 

0.03 

 

51-38 All Vehicles 0.02 

51-39a All Vehicles 0.07 

51-41 All Vehicles 0.02 

51-41a All Vehicles 0.26 

51-41b All Vehicles 0.04 

51-42 All Vehicles 0.02 

51-43 All Vehicles 0.02 

51-46 All Vehicles 0.18 

51-47 All Vehicles 0.02 

52-04 All Vehicles 0.25 

52-05 All Vehicles 0.09 

52-05a All Vehicles 0.54 

52-06 All Vehicles 0.28 

52-07 All Vehicles 0.11 

52-09 All Vehicles 0.16 

52-09b All Vehicles 0.06 

52-10 All Vehicles 1.41 

52-10b All Vehicles 0.08 

52-12 All Vehicles 0.04 
Motorized Travel Management Record of Decision 

Appendix A: Modifications and Errata 

A-6 Klamath National Forest 

Route ID Vehicle Class Length 

(miles) 

Monitor Mitigation Measure 

52-13 All Vehicles 0.09 

52-15 All Vehicles 0.08 

52-16 All Vehicles 0.23 

52-17 All Vehicles 0.08 

52-18 All Vehicles 0.17 

52-20a All Vehicles 0.03 

52-23 All Vehicles 0.06 

52-23a All Vehicles 0.16 

52-BB Hwy Legal 

Vehicles Only 

0.10 

 

54-05 All Vehicles 0.09 

54-08 All Vehicles 0.09 

54-09 All Vehicles 0.18 

54-10 All Vehicles 0.14 

54-11 All Vehicles 0.61 

54-12 All Vehicles 0.10 

54-13 All Vehicles 0.05 

54-13a All Vehicles 0.14 

54-17 All Vehicles 0.06 

54-18 All Vehicles 0.44 

54-24 All Vehicles 0.05 

54-25a All Vehicles 0.02 

54-28 All Vehicles 0.38 

54-29 All Vehicles 0.17 

54-30 All Vehicles 0.05 

54-31 All Vehicles 0.07 

54-32a All Vehicles 0.02 

54-32b All Vehicles 0.12 

54-36 All Vehicles 0.01 

54-37 All Vehicles 0.03 

54-39 All Vehicles 0.26 

54-40 All Vehicles 0.01 

54-40a All Vehicles 0.08 

54-43 All Vehicles 0.10 

54-43a All Vehicles 0.04 

54-44 All Vehicles 0.04 

54-46a All Vehicles 0.05 

54-47 All Vehicles 0.33 

54-48 All Vehicles 0.10 

54-49 All Vehicles 0.04 

54-52 All Vehicles 0.03 
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Appendix A: Modifications and Errata 

Klamath National Forest A-7 

Route ID Vehicle Class Length 

(miles) 

Monitor Mitigation Measure 

54-53 All Vehicles 0.10 

54-54 All Vehicles 0.06 

54-55 All Vehicles 0.22 

54-56 All Vehicles 0.02 

54-57 All Vehicles 0.13 

54-62 All Vehicles 0.08 

55-01a All Vehicles 0.04 

55-06a All Vehicles 0.17 

55-13 All Vehicles 0.50 

55-14 All Vehicles 0.64 

55-15 All Vehicles 0.15 

55-15a All Vehicles 0.03 

55-15b All Vehicles 0.02 

55-17a All Vehicles 0.02 

55-18 All Vehicles 0.38 

55-19a All Vehicles 0.19 

55-23 All Vehicles 0.18 

55-24 All Vehicles 0.03 

55-25 All Vehicles 0.04 

55-26 All Vehicles 0.04 

55-27 All Vehicles 0.02 

55-28 All Vehicles 0.03 

55-44 All Vehicles 0.22 

55-46 All Vehicles 0.06 

55-54 All Vehicles 0.03 

55-56 All Vehicles 0.38 

55-57 All Vehicles 0.08 

55-57a All Vehicles 0.07 

55-59 All Vehicles 0.06 

55-60 All Vehicles 0.04 

55-61 All Vehicles 0.01 

55-61a All Vehicles 0.03 

55-62 All Vehicles 0.10 

55-63 All Vehicles 0.06 

55-64 All Vehicles 0.04 

55-65 All Vehicles 0.41 

55-66 All Vehicles 0.33 

55-67 All Vehicles 0.11 

55-72 All Vehicles 0.06 

55-75 All Vehicles 0.02 

55-77 All Vehicles 0.04 
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Appendix A: Modifications and Errata 

A-8 Klamath National Forest 

Route ID Vehicle Class Length 

(miles) 

Monitor Mitigation Measure 

55-77b All Vehicles 0.01 

55-77c All Vehicles 0.01 

55-78a All Vehicles 0.01 

55-79 All Vehicles 0.04 

55-80 All Vehicles 0.01 

55-81 All Vehicles 0.03 

55-83 All Vehicles 0.05 

57-01 All Vehicles 0.07 

57-03 All Vehicles 0.44 

57-09 All Vehicles 0.17 

57-13 All Vehicles 0.12 

57-13a All Vehicles 0.04 

57-16 All Vehicles 0.04 

57-16a All Vehicles 0.06 

57-19 All Vehicles 0.03 

57-20a All Vehicles 0.04 

57-21 All Vehicles 0.05 

57-26a All Vehicles 0.04 

57-31 All Vehicles 0.04 

57-32 All Vehicles 0.38 

57-35 All Vehicles 0.48 

57-37 All Vehicles 0.06 

57-41 All Vehicles 0.03 

57-41a All Vehicles 0.03 

57-42 All Vehicles 0.20 

57-43 All Vehicles 0.06 

57-47 All Vehicles 0.03 

57-51 All Vehicles 0.03 

57-52 All Vehicles 0.13 

57-53 All Vehicles 0.05 

57-53a All Vehicles 0.06 

57-54 All Vehicles 0.08 

57-55 All Vehicles 0.36 

57-56 All Vehicles 0.24 

57-57 All Vehicles 0.17 

57-60 All Vehicles 0.70 

57-61 All Vehicles 0.15 

57-66 All Vehicles 0.25 

57-67 All Vehicles 0.44 

57-68 All Vehicles 0.11 

57-69 All Vehicles 0.09 
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Appendix A: Modifications and Errata 

Klamath National Forest A-9 

Route ID Vehicle Class Length 

(miles) 

Monitor Mitigation Measure 

57-69a All Vehicles 0.04 

57-70 All Vehicles 0.04 

57-70a All Vehicles 0.22 

57-71 All Vehicles 0.40 

57-72 All Vehicles 0.12 

57-73 All Vehicles 0.16 

57-75 All Vehicles 0.21 

57-80 All Vehicles 0.13 

57-81 All Vehicles 0.03 

57-82 All Vehicles 0.41 

57-82a All Vehicles 0.09 

57-83 All Vehicles 0.03 

57-84 All Vehicles 0.01 

57-84a All Vehicles 0.03 

57-85 All Vehicles 0.18 

57-89 All Vehicles 0.16 

57-91 All Vehicles 0.03 

57-92 All Vehicles 0.14 

57-93 All Vehicles 0.07 

57-94 All Vehicles 0.09 

57-95 All Vehicles 0.02 

57-95a All Vehicles 0.02 

57-96 All Vehicles 0.05 

57-96a All Vehicles 0.02 

57-97 All Vehicles 0.34 

57-98 All Vehicles 0.05 

57-99 All Vehicles 0.02 

57-99a All Vehicles 0.04 

57-100 All Vehicles 0.02 

57-101 All Vehicles 0.07 

57-102 All Vehicles 0.03 

57-103 All Vehicles 0.10 
Motorized Travel Management Record of Decision 

Appendix A: Modifications and Errata 

A-10 Klamath National Forest 

Table A-4 Roads Selected for Added Use by Non-highway 

Legal and Highway Legal Vehicles 

Road ID Length 

(miles) 

Old Maintenance Level New Maintenance Level 

12 22.69 3 3 

20 13.09 3 2 

40S15 7.23 3 2 

40S16 6.40 3 2 

45N28 12.00 3 2 

46N42 1.34 3 3 

46N50 9.80 3 3 

47N69 4.17 3 2 

15N19 5.12 3 3 

17N11 7.60 3 2 

17N16 16.56 3 2 

45N85 4.44 3 2 

46N03 1.13 3 3 

39 32.07 3 3 

10N04 18.69 3 2 

38N27 9.86 3 2 

39N23 13.29 3 3 

39N41 0.32 3 3 

39N60 2.33 3 3 

40N08 13.21 3 3 

6 2.66 3 3 

43N02 1.90 3 2 

43N03 2.24 3 2 

43N37 0.71 3 2 

43N69 2.68 3 2 

44N03 8.82 3 2 

44N23 4.93 3 2 

44N25 0.71 3 2 

46N09 2.12 3 3 

47N05 2.34 3 2 

47N13 8.46 3 2 

13N11 11.77 3 3 

15N17 13.60 3 3 
Motorized Travel Management Record of Decision 

Appendix A: Modifications and Errata 

Klamath National Forest A-11 

Table A-5 Roads Selected for Use by Highway Legal Vehicles 

Only 

Road ID Length 

(miles) 

45N03X 0.50 

45N39 0.99 

46N16 2.25 

40N21 2.22 

45N28 0.28 

46N16A 1.20 

43N30 0.54 

Table A-6 Road Opened for Motorized Use 

Road ID Length 

(miles) 

41S10 4.66 

Table A-7 Open Riding Areas 

Name Size 

(acres) 

Monitor Mitigation Measure 

Humbug 5.00 At a minimum, 

monitor every other 

year to identify 

effects on soil and 

cultural resources 

adjacent to the area. 

Define perimeter with signs, 

fencing or other barriers; install 

kiosk with rules, regulations 

and tread lightly information. 

Juniper Flat 48.00 At a minimum, 

monitor every other 

year to identify 

effects on soil and 

cultural resources 

adjacent to the area. 

Define perimeter with signs, 

fencing or other barriers; install 

kiosk with rules, regulations 

and tread lightly information. 

Do not provide access to caves 
Motorized Travel Management Record of Decision 

Appendix A: Modifications and Errata 

A-12 Klamath National Forest 

Comments on the DEIS from Agencies and Elected Officials 

The following comments received from agencies and elected officials in response to the DEIS 

were inadvertently omitted from the FEIS. They are reprinted on the following pages. 

 
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Appendix B: Response to Comments 

Klamath National Forest B-1 

Appendix B: Response to Comments on FEIS 

This appendix provides the Klamath National Forest response to comments received during the 

30-day review period between release of the FEIS on January 29, 2010, and March 1, 2010. This 

review period was provided to the public to provide an opportunity to comment on the Preferred 

Alternative (Alternative 7) which, although similar to Alternative 6, differed somewhat in the 

number of roads added and the method of achieving mixed use. Alternative 7 was developed to 

respond to comments on the DEIS. In order to allow the public an opportunity to review the 

changes made in the FEIS, especially in the Preferred Alternative 7, signing of the Record of 

Decision (ROD) was delayed. Comments received during this review period were considered in 

making the decision to choose Alternative 7, with minor modifications, as the Selected 

Alternative for Motorized Travel Management (MTM) on the Klamath National Forest. 

During the 30-day review period on the FEIS, four open houses were held in Yreka, Etna, Happy 

Camp and Macdoel to share information about the changes made in the document and maps 

between DEIS and FEIS, and to receive feedback on these changes. Members of the public made 

comments in writing on feedback forms; others sent letters and emails. Some of the comments 

received during the 30-day comment period are repetitions of comments made on the DEIS. 

These are summarized below and references are made to the KNF responses to those comments 

in Appendix E of the FEIS. 

Comments on the FEIS that are the same as those received on the DEIS include requests to: 

• Complete Subpart A of the Travel Management Rule, including travel analysis and 

identifying a minimum road system, before completing Subpart B (FEIS Appendix E, 

pages E-3-4, E-5, E-9, E-18 and E-24). As indicated in Appendix E, travel analysis and 

identification of a minimum road system are not required to inform decisions related to 

the designation of roads, trails, and areas for those administrative units and ranger 

districts that had issued a proposed action as of January 8, 2009. The KNF issued a 

proposed action through a Notice of Intent to Prepare an Environmental Impact Statement 

on October 7, 2008, and is exempt from a requirement to use a travel analysis to inform 

the current MTM decision. 

• Consider the affordability of maintenance for routes included in the MTM decision (see 

page E-1 and the expanded affordability analysis in the Transportation section of Chapter 

3 of the FEIS, especially pages 92-93 and105-107) and need to disclose cumulative and 

direct environmental impacts of the proposal to add roads to a system “that it cannot 

afford to maintain to standard” (see also the purposes of maintenance in the 

Transportation section of Chapter 3 and Appendix C of the FEIS, and the commitment to 

taking steps to prevent resource damage in the monitoring section of Chapter 2, page 19 

and E-23). A strategy to maintain the NFTS within current allocations is discussed in the 

Travel Management section of Chapter 3. 

• Comply with Forest-wide Standard 20-1 in the LRMP that “non-system roads not needed 

for future management shall be ‘put to bed’ ” (see page 89 of FEIS for complete wording

of Standard 20-1 and page E-41 for response to revegetation of unneeded unauthorized 

routes), and decommission routes that are not added to the NFTS (beyond the scope of 

the MTM project as stated on pages E-5, E-6, E-24, E-31- and E-32). The complete 

wording of Standard 20-1 includes direction to “place needed non-system [now called 
Motorized Travel Management Record of Decision 

Appendix B: Response to Comments 

B-2 Klamath National Forest 

unauthorized] roads in the Forest road system.” The unauthorized routes being proposed 

for addition to the National Forest Transportation System (NFTS) in Alternative 7 are 

determined to be needed for motor vehicle use in the MTM decision. The term “put to 

bed” is defined in the LRMP as “roads are obliterated or decommissioned and are no 

longer part of the transportation system.” Unauthorized routes (or non-system roads) 

were never part of the transportation system so there is some confusion about applying 

this definition to unauthorized routes. The MTM FEIS is in compliance with this standard 

in the LRMP by not allowing motor vehicle use on unauthorized roads that are not added 

to the NFTS and thus allowing them to revegetate and become “obliterated.” A strategy 

for treating unneeded roads, outside the scope of this MTM decision, is described on 

pages 6 and 98 of the FEIS. The non-motorized use of unauthorized routes and motorized 

use relating to mining and authorized special uses are outside the scope of the MTM 

FEIS. These uses would need to be considered in any proposal to actively obliterate 

routes or restore them by decommissioning, and any such proposal would require 

additional environmental analysis and disclosure. 

• Minimize the adverse impacts of the current transportation system (see page E-24; the 

response to this comment should have said the FEIS does not analyze the effects of the 

current transportation system other than as part of the current situation). Minimizing the 

adverse impacts of the current NFTS is outside the scope of the MTM FEIS and decision. 

The effects of the current NFTS are included as part of the effects of the existing situation 

in the resource sections of Chapter 3 of the FEIS, and the cumulative impacts of MTM

alternatives plus the current NFTS and reasonably foreseeable future actions are 

addressed for each appropriate resource. In particular, the effects of the road density of 

the current NFTS plus the proposed additions are disclosed on pages 256-257 in the 

Hydrology section and page 292 in the Fisheries section and in the effects on relevant 

wildlife species in the Terrestrial Wildlife section (pages 315-316, 337-338, 346) of 

Chapter 3 of the FEIS. 

• Make the MTM project consistent with laws, regulation, policy and the LRMP (see

Chapter 3 of the FEIS for the consistency with laws, regulation, policy and the LRMP) 

and with the watershed analyses and the Forest-wide Roads Analysis (see pages E-31 and 

E-32). Watershed Analyses (WAs) and other assessments provide information but are not 

decision documents and do not set policy. While recommendations made in WAs are 

considered in project analyses on the KNF, decisions are not required to be consistent 

with WA recommendations. Decisions made outside the MTM FEIS may focus on 

decommissioning routes recommended in WAs or roads analyses. The Forest-wide Roads 

Analysis focused on maintenance level 3, 4 and 5 roads; the MTM focuses primarily on 

adding unauthorized routes as maintenance level 2 roads, on downgrading some roads to 

maintenance level 2 and on allowing mixed use on appropriate maintenance level 3 roads. 

• Avoid adding unauthorized routes on which the Erosion Hazard Rating (EHR) is 

determined to be High or Very High, especially in the Humbug drainage (see discussion 

of EHRs on pages 228-230 of the FEIS, disclosure of the effects of Alternative 7 on 

pages 235-236, and response to comments on pages E-36, E-37, and E-38). As noted in 

the FEIS, the lands on the KNF are 65% in High and Very High EHRs, unauthorized 

routes are 46% in High and Very High EHRs, and of the unauthorized routes proposed to 

be added to the NFTS in the Preferred Alternative (7) 40% are in High and Very High 
Motorized Travel Management Record of Decision 

Appendix B: Response to Comments 

Klamath National Forest B-3 

EHRs. A total of 30 miles of unauthorized route would be added to the NFTS in High and 

Very High EHRs, and motorized use on 240 miles of unauthorized routes in these EHR 

categories would be prohibited. Mitigation to minimize the effects of adding routes on 

soil erosion and potential sedimentation are included in all action alternatives as noted on 

page 236 of the FEIS. 

Comments on the FEIS 

The following KNF responses address comments on the FEIS that were not the same as those 

received on the DEIS, or not made by the same respondents. Many of the comments on the FEIS 

focused on Alternative 7. Comments are grouped by topic. The bracketed numbers following

each comment indicate who made the comment based on the list attached at the end of this 

appendix. 

Adding Routes and Areas 

Public comment: Some of those who commented on the FEIS thought that the Preferred 

Alternative should add more unauthorized routes and areas to the National Forest Transportation 

System (NFTS) and allow mixed use on more roads [12, 13]; others indicated the KNF should 

not add as many unauthorized routes to the NFTS as are proposed in Alternative 7 [9]. 

Response: Alternative 7 seeks a balance between providing motorized access to the KNF 

and protecting resources as required by the Travel Management Rule. Alternative 7 is 

based on Alternative 6 with modifications in adding 12.8 miles of unauthorized route to 

the NFTS in the Butte Valley National Grasslands (BVNG) for only highway legal 

vehicles to maintain traditional motorized access to the BVNG. This proposal is 

described in Chapter 2 of the FEIS and the effects are analyzed in resource sections of 

Chapter 3. Two unauthorized routes that cross perennial streams that were proposed for 

addition to the NFTS in Alternative 6 are not proposed for addition to the NFTS in 

Alternative 7, leaving only one unauthorized route crossing a perennial stream in 

Alternative 7. The effects of this stream crossing are disclosed in the Fisheries section of 

Chapter 3 of the FEIS. More routes to dispersed recreation sites are added in Alternative 

7 to address needs for access to these sites. The one unauthorized route proposed for 

addition to the NFTS in Alternative 6 that was found to be in Port-Orford-Cedar habitat is 

removed from addition to the NFTS in Alternative 7 to prevent the spread of the 

Phythophthora lateralis (Port-Orford-Cedar root disease). Other modifications between 

DEIS and FEIS are listed in Chapter 2 of the FEIS. In response to comments on the FEIS, 

maintenance levels have been modified on several NFTS roads; these are listed in the 

Modifications and Errata Appendix A of this Record of Decision and in the Routespecific section of this Response to Comments on the FEIS. 

One additional route to a dispersed site, discovered to be an unauthorized route slated for 

decommissioning in an earlier project decision, was removed from the Selected 

Alternative. Another route was removed when a previously unidentified conflict with 

resource protections was discovered. Several mapping errors were highlighted by the 

public; these are listed in the Modifications and Errata Appendix A of this Record of 
Motorized Travel Management Record of Decision 

Appendix B: Response to Comments 

B-4 Klamath National Forest 

Decision and will be corrected on the Motor Vehicle Use Map (MVUM) to be published 

as implementation of the decision on this project. 

Public comment: One group of organizations expressed concerns that the number of miles of 

unauthorized routes proposed for addition to the NFTS in Riparian Reserves and Key 

Watersheds in Alternative 7 was greater than in Alternative 6 [9]. 

Response: Alternative 7 proposes adding 20 miles of unauthorized route to the NFTS 

within or adjacent to Riparian Reserves (compared to 18 in Alternative 6), and 6.7 miles 

(compared to 6.2 miles in Alternative 6) in Key Watersheds as defined in the KNF 

LRMP. The effects of these additions are disclosed in the Hydrology and Fisheries 

sections of Chapter 3 of the FEIS. As disclosed in the FEIS, effects are found to be 

minimal (pages 254-255, 288-289) and the project was determined to be in compliance 

with LRMP standards, including the Aquatic Conservation Strategy which includes

Riparian Reserves and Key Watersheds (FEIS, pages 257-259, 294). Also, as noted in the 

FEIS, a discussion of the effects on Key Watersheds was added to address comments on 

the DEIS from this group of organizations; all routes being added to the NFTS in Key 

Watersheds are short spurs to dispersed recreation sites on which travel speed will be low 

and effects of use minimal. Also, as discussed in the Key Watersheds process paper

(available in the project record) and in the Travel Management section of Chapter 1 of 

the FEIS, the KNF has been implementing the LRMP for 15 years, during which it is 

estimated that 100 miles of roads and 58 miles of unauthorized routes have been 

decommissioned in Key Watersheds. In addition, 15 miles of roads are scheduled for 

decommissioning in ongoing and reasonably foreseeable future actions. There is no 

requirement that each project decision that implements the LRMP in Key Watersheds 

contain actions to decommission roads, only that new road construction mileage is offset 

with road decommissioning miles overall in projects implementing the LRMP. The 

LRMP Standard 6-24 that directs no net increase in the amount of roads in Key 

Watersheds includes both NFTS and unauthorized routes. Alternative 7 includes turning 

6.7 miles of unauthorized route into NFTS roads. This does not increase the amount of 

roads in Key Watersheds but just moves 6.7 miles of routes from being unauthorized to 

being part of the NFTS. 

Public comment: One group of organizations expressed concern that the number of miles of 

unauthorized routes proposed for addition to the NFTS on unstable lands, and on soils with high 

or very high erosion risk, in Alternative 7 was contrary to findings and recommendations in the 

Lower South Fork Salmon Roads Analysis and Forest-wide Late Successional Reserve 

Assessment [9]. 

Response: The Motorized Travel Management FEIS analyzed and disclosed the effects 

of adding 6 miles of unauthorized routes on unstable lands (Geology section of Chapter 

3) and 31 miles on high and very high erosion risk lands (Soils section of Chapter 3) to 

the NFTS in Alternative 7. Some effects of adding unauthorized routes to the NFTS on 

these lands are expected, but these are disclosed to be minimal for all resources in 

Chapter 3 of the FEIS. The Motorized Travel Management project considered the 

findings and recommendations in previous analysis and assessment documents on the 
Motorized Travel Management Record of Decision 

Appendix B: Response to Comments 

Klamath National Forest B-5 

KNF; however, these are not decision documents and their recommendations do not set 

policy for the KNF. 

Botanical Resources 

Public comment: One group of organizations states that the “KNF’s reliance on the 2007 

Survey and Manage ROD that illegally eliminated that mitigation measure of the NWFP 

[Northwest Forest Plan] is misplaced...the KNF LRMP, every watershed analysis pertaining to 

the project area, the KNF LSRA [Late-Successional Reserve Assessment] and the NWFP all 

assumed that the agency would implement the Survey and Manage program prior to authorizing 

activities in the habitat for rare species...the FEIS makes no mention of the fact that on 12/17/10 

[sic] Federal District Court Judge John Coughenour ruled in our favor regarding our claims 

against the illegal 2007 ROD to which the FEIS tiers.” [9] 

Response: The Motorized Travel Management (MTM) FEIS, prepared for publication 

before the KNF was notified of Judge Coughenour’s 12/17/09 decision on survey and 

manage species, discloses that such botanical species are addressed in the section on 

sensitive species if they were so designated and as other species of interest if they were 

not designated as USFS sensitive species (Botanical section of Chapter 3 of FEIS, page 

381). Judge Coughenour’s decision specified that the Record of Decision and Standards 

and Guidelines for Amendments to the Survey and Manage, Protection Buffers, and 

Other Mitigation Measures Standards and Guidelines (2001) should be followed in 

analysis of effects on species. On page 22 of the 2001 Survey and Manage ROD it is 

stated that surveys for these species must occur if “habitat-disturbing activities” will 

occur in a project. Habitat-disturbing activities are defined as those disturbances likely to 

have a significant negative impact on the species’ habitat, its life cycle, microclimate, or 

life support requirements. As indicated in the effects section of action alternatives in the 

Botanical Resources and Terrestrial Wildlife sections of Chapter 3 of the FEIS, 

prohibition of cross-country travel will prevent habitat disturbance to botanical and 

several Survey and Manage wildlife species. Wildlife species not specifically addressed 

in the Terrestrial Wildlife section are addressed in the Survey and Manage Species 

Analysis (located in the project record for MTM). No habitat for any Survey and Manage 

species exists in the open riding areas. No activities proposed for any action alternatives 

are likely to have a significant negative impact on the habitat of any Survey and Manage 

species as described in Chapter 3 of the FEIS and in the Survey and Manage Species 

Analysis process paper (Ford, J.A., Perrochet, J., and Knight, M., May 2010). Based on 

this information, the ROD for the MTM decision states that this decision is in compliance 

with the 2001 Survey and Manage ROD. 

Cultural Resources 

Public comment: One group of organizations expresses concern that Alternative 7 “will 

potential [sic] impact up to 40 historical/cultural sites, 35 of which have already been damaged 

by the agency’s reluctance to manage motorized use.” [9] 
Motorized Travel Management Record of Decision 

Appendix B: Response to Comments 

B-6 Klamath National Forest 

Response: The Travel Management rule requires that the effects on cultural resources be 

considered, with the objective of minimizing damage, when designating roads, trails, and 

areas for motor vehicle use. The implementation of Alternative 7 would comply with 

LRMP standards, with the requirements of the Motorized Recreation Programmatic 

Agreement (PA) with the California State Historic Preservation Office (SHPO), and with 

requirements of the Oregon Office of Historic Preservation. The severity of effects are 

defined on page 145 of the Cultural Resources section of Chapter 3 of the FEIS; 

negligible effects are defined as no measurable effects with no mitigation measures 

prescribed and minor effects are defined as perhaps needing monitoring to ensure that the 

minor degree of disturbance does not increase over time. The FEIS discloses that 35 

cultural resource sites are currently receiving negligible to minor effects; these are not 

considered to be “damaged.” Four sites are not currently affected and do not need any 

mitigation. One cultural resource site has been determined to be receiving moderate 

effects. No sites are receiving major effects. The moderate determination requires 

mitigation. Mitigation of effects on this site will include defining the route that will avoid 

negative impacts on the site with barriers and signing, and monitoring the future effects 

to the site. These mitigations are listed on page 157 of the MTM FEIS and have 

concurrence from the California SHPO (letter of 1/19/2010 in MTM process record with 

confidential information redacted). 

Environmental Effects of Maintenance 

Public comment: Concern was expressed that the environmental effects on water quality of 

lowering road maintenance levels on existing routes from maintenance level 3 to 2 were not 

adequately analyzed and disclosed in the FEIS. Recommendations were made to use the draft 

TMDLs that are currently out for public review in planning this MTM project and to maintain 

roads in all “impaired watersheds, especially riparian reserves, in order to comply with Total 

Maximum Daily Load (TMDL) requirements.” [32] 

Response: The objectives of road maintenance levels are related to the type of vehicle 

expected to use the road. Maintenance level 3 roads are maintained for safe passage of 

passenger vehicles; maintenance level 2 roads are maintained for high clearance vehicles. 

The KNF travel management strategy includes downgrading maintenance levels only 

where this is possible without compromising user needs or resource protection (FEIS, 

Appendix C, p. C-11). Maintenance to protect resources would continue regardless of the 

maintenance level of a road; maintenance to provide relatively smooth surfaces for 

passenger cars would no longer take place if roads are downgraded from maintenance 

level 3 to maintenance level 2.The effects of this decision on social and economic factors 

are discussed in the Transportation, Recreation, and Society, Culture and Economy 

sections of Chapter 3 of the FEIS. 

As discussed in the FEIS (pages 257-258), all “action alternatives in the Klamath Travel 

Management project would help to achieve TMDL requirements by reducing road 

density, reducing vehicle-generated sediment, and reducing the potential for sediment 

delivery to streams by subjecting designated routes to improvement and maintenance of 

running surfaces.” Because there is no final Klamath River TMDL, the MTM project 

cannot state that it is in compliance with TMDL requirements; however, the measures 
Motorized Travel Management Record of Decision 

Appendix B: Response to Comments 

Klamath National Forest B-7 

noted on pages 257-258 of the Hydrology section of Chapter 3 of the FEIS are expected 

to meet the final TMDL requirements. If it is necessary to modify the decision on the 

MTM project to meet final TMDLs, this can be undertaken in a separate decision with 

environmental analysis and disclosure of effects. 

Environmental Effects of Road Closures 

Public comment: The FEIS failed to use studies cited in comments to the DEIS on the effects of 

various ways to close roads to prevent environmental damage and avoid illegal use. [9]

Response: Studies, letters and testimony cited by the public were considered along with 

other comments in developing the FEIS. Most of these were related to illegal use and 

ways to prevent illegal use. The FEIS focused on the effects of legal use of the KNF. 

Implementation strategies to encourage legal use and discourage illegal use are included 

in the FEIS but no analysis was undertaken on the effects of illegal use. The MTM 

project decision is focused on prohibiting cross-country motor vehicle use, amending the

LRMP to adopt standards to include this prohibition, and designating roads, trails and 

areas where motorized use may legally occur. Analyzing and disclosing the effects of 

illegal use is beyond the scope of this decision. 

Impacts of increased Motorized Use on the spread of 

Noxious Weeds 

Public comment: There is concern that the KNF makes no attempt to quantify or analyze the 

foreseeable change in motorized use patterns that will result from publication of the MVUM, nor 

what this increased use on designated roads, trails or area will do to the spread of noxious weeds. 

[9] 

Response: As noted in the Recreation and Society, Culture and Economy sections of 

Chapter 3 of the FEIS and on page E-26, most use of the KNF is from the local 

population, population size in the local area is low and population growth in the analysis 

area for the MTM project has been slow, and future increases in motorized use are likely 

to be minimal. It is possible that there will be some increase in such use on existing 

roads and added roads and trails due to the prohibition of cross-country travel but there is

no reliable way to predict the size of this increase, were it to occur. Monitoring of such 

use will occur in the future through the National Visitor Use Monitoring program (as 

stated in Chapter 2 of the FEIS). Based on monitoring data, effects of use may be 

evaluated and used in future decisions about travel management on the KNF. 

Public comment: There is concern that the “KNF appears ready to cede the Humbug drainage to 

yellow star thistle because it is difficult to control” which is not in line with Executive Order 

13112 which requires the agency to take all “feasible and prudent measures to minimize risk of 

harm” to resources from management decisions that may influence the spread of invasive 

species. [9] 

Response: As noted on page 419 of the FEIS, lower elevations on the KNF, such as the 

Humbug drainage, contain major state or county roads which are heavily-used entry 
Motorized Travel Management Record of Decision 

Appendix B: Response to Comments 

B-8 Klamath National Forest 

points for weeds moving into the less-invaded parts of the KNF. The KNF has an active

manual weed treatment program, but some widespread species such as star thistle cannot 

be effectively treated using hand methods on a large scale. Feasible and prudent 

measures to minimize risk of harm from the spread of star thistle that will be

implemented include treating high priority locations to minimize the risk of spread into 

protected and weed-free areas as noted on page E-27 of the FEIS. 

General Comments 

Public comment: General lack of support for the MTM project on the KNF was provided in 

several comments, and support for continued traditional use of motor vehicles throughout the

KNF was stated. [27, 28, 29, 30] Comments supported the use of ATVs as a good way to pass 

time and have fun without causing trouble [17] and indicated ATV and motorcycle use are a 

tourist attraction and leisure activity for family and friends. [21] One comment linked motorized 

use of the KNF to support for tourism and economic well-being of communities. [31] 

Response: These comments were submitted by respondents other than those who 

commented on the DEIS. They are similar in content to comments received on the DEIS

that are addressed in Appendix E of the FEIS, specifically on pages E-2, E-3, E-6, E-14, 

E-15, E-18, E-19, E-20, E-24, E-25, E-28, E-29, E-30, E-31, E-34, E-35, E-36 and E-37. 

As noted in Appendix E of the FEIS, these comments are specifically addressed in the

Recreation, and Society, Culture and Economy sections of Chapter 3 of the MTM FEIS. 

Mitigation 

Public comment: There are concerns with how the KNF reconciles site-specific mitigations with 

the direction in the NWFP “not [to] use mitigations or planned restoration as a substitute for 

preventing habitat degradation.” [9] 

Response: The KNF Forest Plan incorporates the direction of the NWFP and repeats the 

referenced standard for managing Riparian Reserves as MA 10-12. Mitigation measures 

included in the MTM FEIS (pages 20-21) are built into the project design of action 

alternatives to minimize impacts over time, or to prevent the impacts from reaching a 

threshold where ACS standards are not met. They are not used as substitutes for 

preventing habitat degradation. 

Public comment: The KNF failed to analyze the effectiveness of proposed route closure 

mitigation measures. [9] 

Response: Mitigation measures in the FEIS do not include year-round route closures. 

The seasonal closures proposed in the FEIS to protect deer winter range have been 

removed from the selected Alternative 7 based on new information from the California 

Department of Fish and Game. The only remaining route closures are those to eliminate 

conflicts between over-snow vehicles and other motor vehicles. Forest Orders 

designating seasons of use to eliminate conflicts between over-snow vehicles and other 

motor vehicles have been in place for a number of years and have been successful in 

separating the two types of use. 
Motorized Travel Management Record of Decision 

Appendix B: Response to Comments 

Klamath National Forest B-9 

Mixed Use 

Public comment: The KNF should re-analyze all cooperatively maintained roads that connect 

with maintenance level 2 roads for mixed use. [13] 

Response: Cooperatively maintained roads that cross private land may or may not have 

public access rights-of-way (ROWs) negotiated by the KNF with private landowners. If 

these roads do not have public access ROWs, the KNF cannot assure public motorized 

access across the private land. In future, if public access ROWs are secured on 

cooperatively-managed roads, these roads may be analyzed for mixed use on a case-bycase basis. 

Season of Use 

Public comment: The California Department of Fish and Game (DFG) submitted a letter of 

clarification indicating that it appeared that incomplete information was exchanged in early 

consultations with the KNF that resulted in recommendations by DFG for a seasonal restriction 

for motorized travel in the Humbug Drainage. After further review of the FEIS, the CFG stated 

that this restriction is unwarranted due to its limited scale. [33] 

Response: Restrictions on the season of use in the Humbug drainage had been 

developed by the KNF to protect deer on winter range based on early verbal consultations 

with the California DFG. Based on additional information provided by DFG that a 

seasonal restriction is not needed for deer winter range in the Humbug drainage, the 

season of use is changed to year-round. The FEIS had included qualitative analysis of the 

effects of seasonal restrictions. After receiving the written response from DFG, the KNF 

analyzed the number of acres of deer winter range that might be affected by a decision to 

drop seasonal restrictions. This analysis is available in the process records for the MTM 

decision. In summary, it indicates that the acreage of deer winter range currently affected 

by the county roads and NFTS roads in the Humbug drainage is approximately 3,200 

acres. The acreage that would be affected if no routes were added to the NFTS is about 

2,100 (Alternative 3). The acreage that would be affected by adding routes as indicated in 

the Selected Alternative would be about 2,900 acres. This difference, about 800 acres, is 

considered limited in scale compared to the 220,000 acres of deer winter range affected 

by prohibiting cross country travel in this decision. 

Public comment: One group requested that the season of use on the Humbug open riding area 

and trails in the Humbug drainage be changed to 4/1 through 11/15 (from 5/1 through 10/31) to 

match the season of use on existing roads on the KNF. [12] 

Response: Restrictions on the season of use in the Humbug drainage were developed to 

protect deer on winter range designated by the California Department of Fish and Game 

(CFG). Based on additional information provided by CFG that a seasonal restriction is 

not needed for deer winter range in the Humbug drainage, the season of use is changed to 

year-round. 
Motorized Travel Management Record of Decision 

Appendix B: Response to Comments 

B-10 Klamath National Forest 

Public comment: One organization questioned the magnitude of the impact on deer habitat 

affected by the seasonal closure of the Humbug open riding area and trails in the Humbug 

drainage. [13] 

Response: CFG used (1) the relatively small scale of the area affected by the season of 

use; (2) improvements in habitat capability achieved by a reduction in open road density; 

and (3) the fact that adjacent NFTS and County roads would remain open year-round, as 

the basis for their determination that a seasonal restriction is not needed in the Humbug 

drainage. 

Rehabilitation of unauthorized routes not included in NFTS 

Public comment: A concern is raised that the KNF is not proposing any hydrological 

rehabilitation of unauthorized routes that are not added to the NFTS and that there is no peerreviewed literature indicating that closed routes will no longer intercept and concentrate 

precipitation and groundwater flow into surface [sic] without active rehabilitation. [9] 

Response: Most unauthorized routes not designated as part of the NFTS will be allowed to 

revegetate naturally in all action alternatives (FEIS page E-41); however, some limited 

physical restoration and naturalization treatments may be needed to address resource or 

visitor conflict concerns. No peer-reviewed literature was found to indicate how long it 

would take for closed routes to no longer intercept and concentrate precipitation and 

groundwater flow. All known literature focuses on the time required for restoration after 

construction of roads; none discusses restoration of existing unauthorized routes. For this 

project, air and ground photos and specialist knowledge of site-specific conditions (Laurent 

2009, personal communication) were used to document time required for passive restoration 

(FEIS page 242). 

Route-specific Comments 

Public comment: One comment requested including mixed use on Route 48N06 from Route 96 

to Bullion Mountain. [12] 

Response: Road 48 N06 was not analyzed for mixed use in the MTM FEIS because 

most of the route is on private land and there is no possible staging area on NFS land; 

therefore, mixed use on this route cannot be included in the MTM decision. This does 

not preclude analysis in the future as discussed on page 5 of Chapter 1 of the FEIS. 

Public comment: One organization repeats the request made in their comments on the DEIS for 

specific route additions, adds that Preferred Alternative 7 fails to adequate address the issues and 

concerns of the local off road user groups, and asks that all routes identified for addition in their 

DEIS comment be added with new emphasis on 7H002.2, 8J002.3C segments 1 and 3. The 

comment stated that these routes are regularly used, all but one being old roads, and they tie the 

Humbug open riding area to Road 45N22. [13] 

Response: Appendix E of the FEIS (pp. E-33 and E-34) responds to this request. Route 

7H002.2 is a short route between a county road and an NFTS road and is included in 

Alternative 7. Routes 8J002.3 and 8J002.3C are also included in Alternative 7. One short 
Motorized Travel Management Record of Decision 

Appendix B: Response to Comments 

Klamath National Forest B-11 

segment of 8J002.3C that connected to Forest Road 46N22 was not selected for addition 

to the NFTS because adding it would not provide a recreation experience that is not 

offered on other trails in the Humbug area. 

Public comment: Several comments requested that existing roads 15N10, 17N16, 17N11, 

45N85F, 18N33, 18N30, 18N28 be available for use by non-highway legal vehicles [16, 18, 19, 

20, 22, and 31] and some requested the same for existing road 19N01. [19, 20, 22, and 31] 

Response: None of these roads were analyzed for mixed use in action alternatives in the 

FEIS because they were not publicly identified as being desired for mixed use until after 

the FEIS was published. These roads will be examined further to determine whether the 

current ML3 objective is reasonable, or whether they should be considered for 

downgrading to ML 2. If the examination shows that maintenance levels on these roads 

can be downgraded, a decision to change the maintenance level of these roads can be 

made outside this MTM FEIS without further environmental analysis. If they cannot 

reasonably be downgraded to ML2, additional environmental analysis and disclosure 

would be needed to consider them for mixed use. 

Public comment: A request was made to allow the road below Indian Scotty campground to the 

Box Canyon/Paradise Lake trailhead road to be open for non-highway legal vehicles. [4] 

Response: The NFTS road (44N41) from the end of the county road known as the 

Canyon Creek Road (6E002) to Box Canyon Saddle will be open to all motor vehicles as 

it is currently. The MTM decision will not affect this road. 

Trails 

Public comment: A request was made to create more motorized trails or use existing closed 

roads and skid trails as motorized trails. [12] 

Response: Skid trails are developed for specific project uses and are not designed for 

use by the public. They cannot be added to the NFTS as system as roads or trails without 

determining whether they could safely accommodate vehicle traffic, and whether they 

confer access for recreation or other resource uses. This action would require further 

environmental analysis and disclosure of effects. The National Forest Management Act 

(NFMA) mandates that surplus roads constructed in support of a contract, permit or lease 

are to be closed and revegetated “within ten years after the termination of the contract, 

permit, or lease ... [u]nless the necessity for a permanent road is set forth in the forest 

development road system plan” 16 U.S.C. § 1608(b). No additional motorized trail 

opportunities, beyond those unauthorized routes analyzed in the MTM FEIS, were 

considered in the FEIS. This does not preclude analysis of the potential for using closed 

roads for motorized trails in the future as discussed on page 5 of Chapter 1 of the FEIS. 

Public comment: A request was made to expand the proposed Juniper Flat open riding area into 

2 additional adjacent Sections, and to add several trails west of the riding area to the NFTS. [12] 

Response: The only unauthorized route near the proposed Juniper Flat open riding area 

that was analyzed for potential addition to the NFTS was one that went from County 

Road A12 to an area of the KNF that includes caves and cultural resource sites. This 

route was not selected for inclusion in the NFTS in any action alternative as discussed in 
Motorized Travel Management Record of Decision 

Appendix B: Response to Comments 

B-12 Klamath National Forest 

an alternative considered but eliminated for detailed study (Alternative F). If there are 

other routes that would provide trail riding opportunities outside the Juniper Flat open 

riding area, they may be considered for addition to the NFTS through a separate decision 

based on additional analysis and disclosure of effects. 

Public comment: One organization repeated the request contained in its comments on the DEIS 

that Siphon Lake Trail be designated as for motor vehicle use, adding that access to a trail 

historically used by motor vehicles should be considered first before a closure is enacted. [13] 

Response: This comment was addressed in Appendix E of the FEIS (p. E-33). Routes 

that followed existing equestrian or foot trails that were part of the KNF trail system were 

eliminated from consideration as motorized trails (FEIS, Chapter 1, p. 18). This was 

discussed further in an alternative considered but eliminated from detailed study 

(Alternative B), which mentions Siphon Lake trail specifically. The reasons given for 

eliminating this alternative from detailed study include that the alternative does not meet 

the purpose and need of the MTM project, and that adding motorized use to equestrian 

and foot trails would create conflicts between motor vehicles and existing recreational 

uses of NFS land, and create safety issues associated with those conflicts. For these 

reasons, allowing motorized use on the Siphon Lake Trail was not analyzed in detail in 

any of the action alternatives or in the no action alternative. Routes not analyzed in detail 

cannot be added to the NFTS without further environmental analysis and disclosure of 

effects. This does not preclude further analysis of this proposal in a separate planning 

document. 

Water quality/sediment 

Public comment: One group of organizations cites concerns that dust clouds created by use of 

the Humbug open riding area will place sediment into Humbug Creek. [9] 

Response: Off-road travel in the proposed open riding area will generate some dust. 

Dust has not been identified by either the Environmental Protection Agency or the North 

Coast Water Quality Control Board as a concern for water quality. The proposed Klamath 

River Total Maximum Daily Load does not identify dust as an issue. The Klamath 

National Forest will be conducting stream monitoring in the Humbug drainage for at least 

5 years after the Travel Management project is approved. Monitoring processes will be 

consistent with requirements set by the North Coast Board and should indicate whether 

stream condition is adversely affected by activities taking place in the drainage, including 

activities in the open riding area. 
Motorized Travel Management Record of Decision 

Appendix B: Response to Comments 

Klamath National Forest B-13 

Names and Addresses of parties commenting on the FEIS 

The following individuals and groups commented on the FEIS during the 30-day review period 

following publication of the FEIS. 

1 Carl Schwarzenberg 7800 French Creek Rd., Etna, CA 

2 Wayne Linn 899 Hillview Dr., Ashland, OR 97520 

3 Yvette Rooker 

4 Frank Wittington 8727 Far Away Pl., Fort Jones, CA 96032 

5 Iginio Fontana 

6 Michael and Lisa Kisell 3477 Heron Lake Lane, Elk Grove, CA 95758 

7 Fred Walker 

8&12 Dave Shaw P.O.Box 462, Yrkea, CA 96097 

9 George Sexton, Cons. Dir. P.O. Box 102, Ashland, OR 97520 

 Klamath Siskiyou Wildlands Center 

10 James Clemons P.O.Box 854,, Fort Jones, CA 96032 

11 Tom Hamilton P.O. Box 145, Dorris, CA 96023 

13 Jim Lipke, President P.O.Box 1925, Yreka, CA 96097 

 Siskiyou County Off Road Riders (SCORR) 

14 Mike Irvine 

15 R. Cameron 

16 Stuart Love 

17 Laszlo Pethes 

18 James Manley 

19 Jimmy Dewberry 

20 Rita King 

 Happy Camp Chamber of Commerce 

21 Maylissa Quenn 

22&23 Denver Lantow 

24 Duane Armbruster P.O.Box 54, Happy Camp, CA 96039 

25 Ellen Johnson P.O.Box 262, Happy Camp, CA 96039 

26 Greg Sherburn 

27 Robert Spence P.O.Box 713, Happy Camp, CA 96039 

28 Robert Goodwin P.O.Box 1043, Happy Camp, CA 96039 

29 Sara Spence P.O.Box 713, Happy Camp, CA 96039 
Motorized Travel Management Record of Decision 

Appendix B: Response to Comments 

B-14 Klamath National Forest 

30 Chelle Albonico P.O.Box 961, Happy Camp, CA 96039 

31 Gary King 

32 Kathleen Goforth, Mgr. 75 Hawthorne St., San Francsisco, CA 94105 

 Environmental Review Office, U.S. Environmental Protection Agency 

33 Karen Kovacs 601 Locust Street, Redding, CA 96001 

 Wildlife Program Supervisor, Northern Region, CA Department of Fish and Game 

The following individuals provided comment on the FEIS after the 30-day review period was

concluded. 

34 Derek Gendvil 9030 W. Sahara Ave., #360, Las Vegas, NV 89117 

35 Jonathan J. Rhodes P.O.Box 15286, Portland, OR 97293-5286 

 Hydrologist, Planeto Azul Hydrology 

Comments on FEIS from Agencies and Elected Officials 

Copies of comments received in response to the FEIS are reprinted on the following pages. 

 
Motorized Travel Management Record of Decision 

Appendix B: Response to Comments 

Klamath National Forest B-15 

 
Motorized Travel Management Record of Decision 

Appendix B: Response to Comments 

B-16 Klamath National Forest 

 
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Appendix B: Response to Comments 

Klamath National Forest B-17 

 
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Appendix B: Response to Comments 

B-18 Klamath National Forest 

 
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Klamath National Forest B-19 

 
Motorized Travel Management Record of Decision 

Appendix B: Response to Comments 

B-20 Klamath National Forest 

 
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Appendix B: Response to Comments 

Klamath National Forest B-21 

 
Motorized Travel Management Record of Decision 

Appendix B: Response to Comments 

B-22 Klamath National Forest 
Motorized Travel Management Record of Decision 

Appendix B: Response to Comments 

Klamath National Forest B-23 
Motorized Travel Management Record of Decision 

Appendix B: Response to Comments 

B-24 Klamath National Forest 
Motorized Travel Management Record of Decision 

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Klamath National Forest B-25 

 
Motorized Travel Management Record of Decision 

Appendix B: Response to Comments 

B-26 Klamath National Forest