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Appendix E: Response to Comments

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Appendix E: Response to Comments

The following are comments from the letters and emails received and our responses to those 

comments. 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: A number of respondents thought that we should not add any more routes due 

to the inability of the Klamath National Forest (KNF) to maintain the current National Forest 

Transportation System (NFTS) [Form Letter (FL) 2, 74, 172, 321-416, FL 418].

Response: Alternatives 2, 4, 5, 6 and 7 add a range of miles of unauthorized routes to the 

National Forest Transportation System (NFTS), ranging from about 7 miles in Alternative 4 

to 92 miles in Alternative 2. Of the road miles added, in most alternatives (Alternatives 5, 6, 

and 7) the majority of roads are short spurs to dispersed recreation sites that need little if any 

active maintenance. The Forest has been able to maintain its maintenance level (ML) 3, 4 and 

5 routes within existing budgets. Maintenance level 1 roads are closed to public use and 

require little maintenance. The majority of KNF roads are ML 2 roads which are roughlygraded and maintained for high clearance vehicles. Most of these roads are maintained as 

needed to support KNF projects or provide access to recreation sites. Decisions are made 

annually about which of the approximately 2,700 miles of ML 2 road need maintenance; not 

all will be maintained each year and some may be left closed by rocks or downed trees. The 

deferred maintenance strategy (described in Appendix C of the FEIS) allows the KNF to 

effectively use its annual maintenance budget to adequately maintain the current road system. 

The routes to be added as motorized trails will be maintained through the Recreation 

program. The KNF expects to secure state funds for part of the maintenance costs for these 

trails. Most of the unauthorized routes proposed for addition to the NFTS are stable and 

require little to no active maintenance to provide protection to KNF resources as discussed in 

the Transportation section of Chapter 3 and Appendix C of the FEIS. Some action alternatives 

will result in reduced annual maintenance costs (Alternatives 3, 4 and 7) as disclosed in the 

Transportation section of Chapter 3 of the FEIS.

Public comment: Some respondents stated that the proposed action and alternatives (2, 5, and 6) 

added too many miles of route to the NFTS [17, 74, 17]; others wanted more miles of routes 

added [20, 203, 417]; and one respondent said Alternative 6 added the correct number of miles 

[178].

Response: There is disagreement among segments of the public about whether routes should 

be added to the NFTS, and the number and types of routes needed. The Forest Supervisor is 
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charged with making decisions regarding an appropriate balance between motorized and nonmotorized recreation, and will do so through this travel management process. There appears 

to be general agreement by various segments of the public that some level of motorized 

access to dispersed recreation sites is appropriate; Alternatives 2, 4, 5, 6 and 7 provide 

different levels of opportunity for this access. At this time, the KNF does not have any 

designated trails for motorized vehicle use, other than for over-snow vehicles. Alternatives 2, 

4, 5, 6 and 7 would provide such trail opportunities. Alternatives 4, 5, 6, and 7 were 

developed using public input to provide different balances between motorized and nonmotorized use. In making a decision on potential additions to the NFTS, the Forest 

Supervisor will consider factors such as safety, law enforcement, costs, user conflicts, public 

opinion and desires, resource impacts, and motorized and non-motorized opportunities. The 

FEIS addresses all of these factors.

Public comment: Several respondents thought that all or most of the unauthorized routes should 

be added to the NFTS [20, 203, 417]; others opposed adding any unauthorized routes to the NFTS 

[173, 321-416, FL 418]; and a number opposed adding routes in specific areas (riparian reserves, 

key watersheds, salmon spawning areas, and other special areas) [FL 2, 46, 171, 172].

Response: All publicly-identified inventoried unauthorized routes (497 miles) were evaluated 

against many different possible resource opportunities and concerns during Steps 1 - 3 of this 

travel management project to determine if they should be added to the NFTS; this is 

discussed in Chapters 1 and 2 of the FEIS. If it was determined that the route would cause 

major environmental impacts to resources that could not be mitigated, the route was not 

proposed for addition to the NFTS in any action alternative. In this case, it was determined 

that the amount of harm caused by its inclusion in the NFTS would outweigh the benefit of 

the addition. Routes that emerged from this screening as potential additions to the NFTS 

were field verified, and some were found to be no longer identifiable on the ground or not 

useable for any motorized access. Detailed route-by-route analysis of the routes that passed 

initial screening is available in the project record for Travel Management, located in the 

Forest Supervisor’s Office in Yreka, CA. 

The displays of where routes were proposed for addition in riparian reserves, near salmonbearing streams, or other special interest areas were not consistently clear in the DEIS. In 

response to public comment, an analysis of proposed additions to the NFTS in key 

watersheds is included in the Hydrology and Fisheries sections of Chapter 3 of the FEIS. The 

FEIS clarifies the proposals as to effects on riparian reserves and key watersheds in the 

Hydrology section of Chapter 3, on salmon-bearing streams in the Fisheries section of 

Chapter 3, and on special interest areas in Geology and Botany sections of Chapter 3. 

Alternative 7 was developed in part to address the concerns expressed in public comment on 

the DEIS to evaluate and remove from consideration those routes that would have a negative 
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effect on salmon spawning. Effects of adding unauthorized routes in action alternatives 2, 4, 

5, 6, and 7 are discussed by the resource area potentially affected in Chapter 3 of the FEIS. 

Other than routes in the Humbug drainage, proposed additions to the NFTS on the west side 

of the KNF in Riparian Reserves all access dispersed recreation sites (short spurs off NFTS 

roads). About 60 spurs to access dispersed recreation sites are river access points or sites in 

the vicinity of rivers or streams, used primarily by SUVs or 4WD trucks. Effects of proposed 

additions to the NFTS in riparian reserves on both the west and east sides of the KNF are 

disclosed in the Hydrology section of Chapter 3 of the FEIS. The Humbug drainage is 

discussed in the response to the following comments.

Public comment: One respondent stated support for adding areas that have already been heavily 

used by OHVs [74]; another respondent supported the addition of the Humbug open area [199]; a 

respondent representing several organizations questioned the addition of the Humbug area due to 

potential soil erosion [172].

Response: The effects of adding open riding areas are analyzed and disclosed in various 

resource sections of Chapter 3 of the FEIS for action alternatives 2, 5, 6, and 7. Part of the 

area proposed to be designated as open for OHV use in Humbug is a flat created by a mining 

operation in the distant past as discussed in various sections (primarily Transportation, Soils, 

and Hydrology) of Chapter 3 of the FEIS. The flat area is actually physically lower than 

Humbug Creek and separated from it by a road. Any sediment created by use of the flat or the 

hills above will be funneled onto the flat and would not enter the creek. While the flat itself 

is within the boundaries of a riparian reserve, it does not support riparian vegetation. The 

Humbug drainage supports a network of old mining and logging routes that were constructed 

in erodible soils; most of these routes will remain on the landscape whether or not they are 

designated as part of the NFTS. More information on the effects of what is proposed for the 

Humbug drainage, and site-specific mitigations to reduce the effects of adding routes, is 

provided in the Soils section of Chapter 3 of the FEIS.

Public comment: One respondent stated that unauthorized routes should not be added to the 

NFTS because adding them would reward users who had created them illegally [74].

Response: Because 1.2 million acres of the KNF have been open for motorized vehicle use 

under the KNF Forest Plan (LRMP), unauthorized routes on these acres were not created 

illegally. 

Adequacy of Analysis

Public comment: A number of respondents stated that the Forest must do a travel analysis and 

identify the minimum NFTS for the KNF [172, 205, 321- 416, 418].
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Response: Forest Service Manual 7712 (1) states ―...travel analysis is not required to inform 

decisions related to the designation of roads and trails for those administrative units and 

ranger districts that have issued a Proposed Action as of January 8, 2009.‖ Nothing in the 

travel management regulations at 36 CFR 212 requires that travel analysis must be completed 

before roads and trails on National Forest System lands are designated for motor vehicle use 

in accordance with Subpart B of the Travel Management Rule (36 CFR 212.50). The 

requirement for identification of the minimum NFTS for the KNF is discussed further in this 

response to comments under the Alternatives section.

Public comment: Some respondents requested that the KNF provide information on decisions 

made to designate the NFTS [202] including the resource impacts of the NFTS [172].

Response: Implementing Subpart B of the Travel Management Rule does not require the 

review and inventory of all past transportation decisions (36 CFR 212.50. paragraph (b). 

Similarly, the Forest Service Manual 7715.03 – Policy (1) states that the Forest must use 

previous decisions to establish a starting point for proposals to change travel management 

decisions. This process does not address the impacts of the NFTS; that is outside the scope of 

the project.

Public comment: One respondent representing several organizations suggests that no decisions 

should be made until the Forest completes a comprehensive inventory of all roads, trails, 

temporary roads and user created routes [172].

Response: The KNF conducted an extensive effort to inventory the unauthorized routes on 

the Forest that were continuing to receive motor vehicle use, as discussed in Chapter 1 of the 

FEIS. An inventory of NFTS routes and temporary roads is not required for the travel 

management decision to be made under Subpart B of the Travel Management Rule. 

Temporary roads are not public access routes; they are not considered available for motorized 

vehicle use by the public. 

Air Quality

Public comment: Some respondents expressed concern with effects of motorized use on climate 

change, greenhouse gases and asbestos dust in the air [172, 365].

Response: The effect of motorized use on climate change, including the production of 

greenhouse gases, is discussed in the Air Resources section of Chapter 3 of the FEIS. The 

number of vehicle miles traveled annually by Forest users is low, as discussed in the 

Transportation, Recreation, and Society, Culture and Economy sections of Chapter 3 of the 

FEIS, and is not expected to change in any action alternative that prohibits cross-country 

travel and redirects motorized use onto designated routes. Therefore, no change is anticipated 

from this decision that will adversely affect air quality or greenhouse gas emissions. The 
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likelihood of asbestos dust being produced from the mixed use proposed by this analysis is 

discussed in the Geology section of Chapter 3 of the FEIS. The highest potential for 

exposure to asbestos dust would come from traveling at high speeds in an open vehicle on a 

road with asbestos-bearing ultramafic rock. This kind of situation would occur on 

Maintenance Level (ML) 3 roads, which are constructed for higher speeds. All ML 3 roads in 

ultramafic rock that are proposed for mixed use were tested for the presence of asbestos. Test 

results indicate that asbestos levels are within limits established by the State of California; 

asbestos does not constitute a health hazard. Routes to dispersed recreation sites were not 

tested because the low traffic speeds on these short, roughly-surfaced spur roads would not 

generate enough dust to be a problem. 

Alternatives

Public comment: Several respondents requested a new alternative be developed that provides a 

better balance of motorized access, affordability and environmental protection [20, 203].

Response: No information was provided in the comment that would clarify what a ―better 

balance‖ might look like. Alternative 7 was developed in response to comments on the DEIS, 

to provide a balance of types of access being provided, affordability and environmental 

concerns expressed in public comments on the DEIS. Alternative 7 is described in Chapter 2 

of the FEIS. 

Public comment: One respondent requested a display of how the minimum road system was 

identified and used to develop alternatives [205]; another stated that the range of alternatives was 

artificially constrained to avoid looking at the effects of the current NFTS [172].

Response: Identification of the minimum road system is not required under Subpart B of the 

Travel Management Rule, is not a factor in this travel management process, and is not used to 

develop alternatives; doing so is outside the scope of this analysis. The range of action 

alternatives was developed to respond to the purpose and need for action to prohibit crosscountry motorized travel and identify needed changes to the KNF NFTS to provide motorized 

recreation opportunities while protecting KNF resources. See further discussion in the 

response to comments in the purpose and need section. 

Public comment: A number of respondents thought the travel management decision should 

consider road closures on the NFTS to protect resources [FL2, 17, 172, 205], and some 

respondents suggested that decommissioning was the way to accomplish such road closures [FL2, 

17, 172].

Response: The purpose and need for the travel management project is identified in Chapter 1 

of the FEIS. The proposed action (Alternative 2) and action alternatives were developed to 

meet the requirements of Subpart B of the Travel Management Rule. The Rule provides 
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direction for a system of National Forest Transportation System roads, trails, and areas 

designated for motor vehicle use, and the prohibition of motor vehicle use off designated 

roads and trails and outside designated areas. Subpart B is intended to prevent resource 

damage potentially caused by unmanaged motor vehicle travel by the public. Therefore, 

comprehensive change to managed motorized vehicle use on NFTS roads is beyond the scope 

of this analysis. 

Public comment: Several respondents request a reconsideration of Alternative B (an alternative 

eliminated from detailed study) to allow motorized use on some non-motorized trails (the trails 

are specified in one comment) [201, 203]; other respondents do not want motorized use on the 

same specified non-motorized trails [199, 200] or on any non-motorized trails [177, 321-416, FL 

418], and stated that the demand for loop roads and access to high points was adequately satisfied 

by the proposed action [200].

Response: Allowing motorized use on non-motorized trails was discussed in an alternative 

considered but eliminated from detailed study (Alternative B) in Chapter 2 of the FEIS. This 

alternative does not meet the purpose and need for this project, and was eliminated from 

detailed study because of potential user conflicts and safety concerns. Non-motorized trails 

on the KNF were not intended for motorized use and would require engineering review, 

redesign, and potentially substantial reconstruction to accommodate that use. None of the 

alternatives considered but eliminated from detailed study will be selected for 

implementation.

Public comment: Several respondents suggest that, since the KNF has not included alternatives 

that consider road closures on the NFTS, a full range of alternatives has not been evaluated [172, 

205].

Response: The purpose and need for action determines the range of alternatives considered 

in detail in the FEIS. The purpose and need for the current action is to address unmanaged 

cross-country travel and to implement Subpart B of the travel management regulations, while 

maintaining important motorized access and recreational opportunities for the public. The 

purpose and need for action is not to examine the NFTS for potential road closures; that

action is outside the scope of this analysis. 

Aquatics and Fisheries

Public comment: A number of respondents are concerned about the effects of motorized use of 

routes on fish, particularly spawning for Threatened, Endangered and Sensitive (TES) species 

including the salmon [FL 2, 17, 46, 172, 204, 324, and 387].

Response: The effects of motorized use of routes are discussed in detail in the Fisheries 

section of Chapter 3 of the FEIS, and in the Fisheries Biological Assessment and Biological 
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Evaluation (Fish BA/BE). Informal consultation with the National Marine Fisheries Service 

(NOAA-Fish) based on the Fish BA/BE concluded with a ―may affect individuals, is not 

likely to affect populations‖ determination. The results of consultation, and Fish BA/BE, are 

referenced in the Fisheries section of Chapter 3 of the FEIS and are part of the project record 

located in the KNF Supervisor’s Office in Yreka, CA. Clarification of where motorized use 

will be allowed and discussion of the potential effects on fish of routes that are designated 

near or crossing streams is also found in the Fisheries section of Chapter 3 of the FEIS. A 

commitment to monitoring the effects on Middle Fork Humbug Creek of the crossings 

proposed in action alternatives is identified in Chapter 2 of the FEIS. Site-specific 

mitigations to reduce or eliminate negative effects on fish are documented in the Soils section 

of Chapter 3 of the FEIS.

Public comment: Concern was expressed by a respondent representing several organizations 

about how route designation decisions will minimize impacts on hydrological sensitive areas and 

riparian reserves [172].

Response: Effects of route designation decisions on riparian reserves are discussed in the 

Hydrology, Fisheries and Terrestrial Wildlife sections of Chapter 3 of the FEIS. Riparian 

reserves, the term used and defined in the KNF LRMP, is synonymous with the term

―hydrological sensitive areas‖ for the KNF and the travel management project as discussed in 

the Hydrology section of Chapter 3 of the FEIS. See also the discussion of minimizing effect 

in the response to the comment on Executive Orders.

Public comment: A group respondent expressed concern that the KNF has too many problem 

roads that impact fish and stated the group is strongly opposed to KNF adding unauthorized 

routes to the NFTS within or adjacent to riparian reserves or within known or historically 

occupied TES and MIS habitats for Southern Oregon/Northern California Coasts Coho Salmon, 

Upper Klamath-Trinity Rivers Chinook Salmon, Steelhead, and Rainbow Trout [46].

Response: Threats to fisheries from cross-country motorized travel would be eliminated for 

the KNF with the prohibition of such travel, as stated in the Fisheries section of Chapter 3 of 

the FEIS and the Fish BA/BE. Motor vehicle use levels on the KNF are very low and 

impacts are dispersed across the landscape. It is unlikely that effects of off-road use or use of 

additional roads added in action alternatives 2, 4, 5, 6, or 7 will be measurable or discernable 

from the multiple natural and human-induced changes that occur over the landscape on the 

KNF. Most of the roads being proposed for addition to the NFTS in riparian reserves are short 

spurs accessing dispersed recreation sites that have little or no impact on fish. The majority of 

the unauthorized routes in riparian reserves are being closed to motorized vehicle travel in all 

action alternatives (from 66% to 100%). See also the response to the first comment in this

section of responses. 
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Public comment: On respondent representing a number of organization states that the Forest 

Service must manage public lands in an ecologically sustainable manner that protects fish and 

wildlife. 36 CFR 219.27(a)(4)(1982). The agency must also show how it is protecting these 

resources [172]. 

Response: As discussed in the Fisheries section of Chapter 3 of the FEIS, all of the action 

alternatives represent substantial reductions in road mileage in riparian reserves. Reductions 

in road density would occur in most watersheds for all action alternatives as disclosed in the 

Hydrology section of Chapter 3 of the FEIS. Compliance with law, regulation and policy is 

also disclosed in the Fisheries and Hydrology sections of Chapter 3 of the FEIS. The 

Fisheries section of Chapter 3 of the FEIS and the Fish BA/BE emphasize the ways in which 

fish are being protected in action alternatives, and site-specific mitigations listed in the 

Recreation and Soils sections provide additional protections.

Public comment: One respondent representing several organization states that the KNF has 

elected not to address and mitigate the harmful impacts detailed in the Trombulak and Frissell 

(2000) article [172]. 

Response: The information provided in the Trombulak and Frissell (2000) article was used as 

part of the analysis of project effects on fisheries resources, and is referenced in the Fisheries 

section of Chapter 3 of the FEIS. All action alternatives address the issues raised by 

Trombulak and Frissel by reducing the number of miles and acres available for motorized use 

on the KNF.

Public comment: One respondent representing several organization states that proposals in 

action alternatives that add motorized use routes to the NFTS within SONCC habitat, and add 

stream crossings on these routes, run afoul of the KNF LRMP at MA 10-22, MA 10-45, and MA 

10-55. Furthermore, the comment states the decision to encourage riparian ORV use in SONCC 

habitat may result in ―take‖ violating the ESA, and that the ―Not likely to adversely affect‖ 

(NLAA) determination on page 151 of the DEIS is directly refuted by numerous findings 

contained in the document [172].

Response: In the DEIS, a number of perennial stream crossings were identified in action 

alternatives (0 to 18 depending on the alternative) by overlaying the proposed routes with the 

special status fish species distribution layer in GIS. Field verification of these crossings 

between DEIS and FEIS found the actual numbers were 0 to 3 for action alternatives; the 

Fisheries section of Chapter 3 of the FEIS has been modified to include the results of the field 

verification and site-specific mitigations added to reduce or eliminate effects have been added 

to the Soils section of Chapter 3 of the FEIS. In informal consultation concerning effects of 

this project on fisheries, the determination was made that implementation of any action 

alternative ―may affect, but is not likely to adversely affect‖ SONCC Coho Salmon (see the 
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Determinations for Special Status Species in the Fisheries section of Chapter 3 of the FEIS). 

Action alternatives are in compliance with the KNF LRMP including the standards cited in 

the comment. See also the response to the first comment in this section of responses.

Public comment: On respondent representing several organizations states that the proposal at 

page 133 of the DEIS to add motorized roads and trails directly adjacent to anadromous fish 

habitat in six 7th field watersheds constitutes a violation of the ESA, CWA, NWFP and the KNF 

LRMP. The organizations are perplexed by the willingness of the KNF to sacrifice anadromous 

fish habitat to facilitate the 1.1% of forest users for whom ORV use constitutes their primary 

activity on public lands [172]. 

Response: All action alternatives propose closing most of the unauthorized routes (from 66% 

to 100%) in riparian reserves as discussed in the Hydrology and Fisheries sections of Chapter 

3 of the FEIS. Most of the added routes in anadromous fish habitat are short spurs to 

dispersed recreation sites, as discussed in the Fisheries section of Chapter 3 of the FEIS. 

Aquatic Conservation Strategy objectives are met and the action alternatives all are in 

compliance with the CWA and KNF LRMP in this regard as discussed in the expanded 

Hydrology section of Chapter 3 of the FEIS. The contribution to sediment loading from these 

routes is considered minimal, and is immeasurable at the watershed scale, as noted in the 

Fisheries section of Chapter 3 of the FEIS.

Baseline

Public comment: One group of respondents suggests that the Forest Service has not provided 

adequate or reliable documentation for what they consider to be the "baseline" of the current 

transportation system. The Forest has not provided decision notices, records of decision, NEPA 

documentation, road management objectives, or funding allocation data for system routes in its 

jurisdiction [172].

Response: This project does not analyze the impacts of the current transportation system. 

That analysis is outside the purpose and need for this project, and outside its scope. The 

Pacific Southwest Regional Forester has committed to begin addressing Subpart A of the 

Travel Management Rule within the next 18 months; that process will provide 

information needed to identify the baseline transportation system for management of the 

KNF. 

Public comment: One respondent representing several organizations stated that relying on the 

No Action Alternative as a proxy for conducting the analysis of cumulative impacts of past travel 

management action is misplaced. For instance, the cumulative impacts of the 1996 flood event are 

largely absent from the DEIS [172].
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Response: Cumulative impacts of past events are expressed in the potentially affected 

environment as part of the current condition. For example, the effects of a flood from 13 

years ago are encompassed in the description of the current condition of the stream channels 

and the condition of their riparian vegetation as discussed in the Hydrology and Fisheries 

sections of Chapter 3 of the FEIS. 

Big-Game Retrieval

Public comment: Several respondents requested that big game retrieval using motorized vehicles 

be allowed [20, 179, and 417]. One group was concerned that not allowing motorized vehicle use 

for retrieving game animals was unfair to the elderly and disabled hunters [179]. There was also a 

suggestion to clarify the direction in the FEIS regarding use of motorized vehicles to retrieve 

game animals [417].

Response: Forest Service Manual 7715.74 (3) states ―[t]o promote consistency, the Regional 

Forester should coordinate designations pursuant to Forest Service Manual 7715.74, 

paragraph 1, within states and among adjoining administrative units.‖ The Regional Forester 

for the Pacific Southwest Region (California) has determined that Forests in the region shall 

not allow cross-country use of motorized vehicles to retrieve game animals. Therefore, the 

environmental impact of cross-country motorized vehicle travel to retrieve game is not 

considered in the FEIS. Big game retrieval can still occur without the use of motorized 

vehicles throughout the KNF wherever hunting of game is allowed by the states of California 

and Oregon. Denying motorized access to the disabled and elderly is not considered 

discriminatory under the Americans with Disabilities Act or the Older Americans Act as long 

as this denial applies to all others.

Botanical Resources

Public comment: One respondent requested that the Forest Service responsibly limit where 

OHV use takes place when such use causes negative impacts to plants [74]; others requested 

protection for threatened, endangered and sensitive plant species [321-416, FL 418]. One 

respondent representing several organizations expressed concerns that a substantial number of 

unauthorized routes were proposed for addition to the NFTS in habitat for sensitive plant species, 

and that studies strongly suggest that designation of additional system roads near sensitive plant 

habitat via the MVUM will result in foreseeable direct, indirect and cumulative impacts to rare 

botanical resources that are not disclosed or analyzed in the DEIS [172]; and one respondent 

stated that Alternative 6 protected plants well [178].

Response: As disclosed in the Botanical Resources section of Chapter 3 of the FEIS, all 

action alternatives have been designed to limit where OHV use takes place to minimize 

impacts to sensitive plant species. Implementation of any action alternative would prohibit 

cross-country motorized travel, considerably reducing the area available for OHV use and 
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thus reducing potential impacts to plants. The number of sensitive plant sites within 100 feet 

of unauthorized route proposed for addition to the NFTS in any action alternative varies from 

zero to two. None of the sites is directly adjacent to a route; disturbance actually creates 

habitat for one of these species and the effects on the other species were evaluated and found 

to not be affected by the use of the route. Direct, indirect and cumulative effects to rare 

botanical resources were analyzed and disclosed in the Botanical Resources section of 

Chapter 3 of the FEIS. It is not clear what studies are being referenced by the comment or 

which effects were not disclosed. No information is available that leads the KNF to the 

conclusion that impacts are not disclosed or analyzed. A Biological Assessment and 

Evaluation (Plant BA/BE) was prepared and all action alternatives were found to benefit plant 

species. This information is available in the project record located at the KNF Supervisor’s 

Office in Yreka, CA.

Public comment: One respondent representing several organizations expressed concern that the 

harmful impacts of travel management detailed in the Trombulak and Frissell (2000) article are 

not addressed and mitigated [172].

Response: The information provided in the Trombulak and Frissell (2000) article was used as 

part of the analysis of project effects on botanical resources, and is referenced in the 

Botanical Resources section of Chapter 3 of the FEIS and in the Plant BA/BE. All action 

alternatives address the issues raised by Trombulak and Frissel by reducing the number of 

miles and area available for motorized use on the KNF.

Public comment: One respondent representing several organizations noted that the Forest 

Service must manage public lands in an ecologically sustainable manner that protects the 

diversity of plant communities and must show how it is protecting these resources [172].

Response: Managing for diversity is part of the KNF LRMP standards and guidelines. All 

travel management alternatives will be compliant with the KNF LRMP as amended, as stated 

in the Botanical Resources section of Chapter 3 of the FEIS.

Public comment: One respondent representing several organizations expressed concern that the 

DEIS did not analyze or disclose the potential for increased OHV abuse of serpentine sites due to 

the addition of unauthorized routes to the NFTS; this concern is that the destruction of rare plants 

by motor vehicles is a direct impact that cannot be mitigated and may contribute to the need for 

ESA listing, that ruts, rills and gullies persist in serpentine areas for decades (in violation of the 

ACS) and prevent re-establishment of desired rare species via permanent soil damage [172].

Response: As noted in the Botany section of Chapter 3 of the FEIS, only one sensitive plant 

on serpentine soil exists within 100 feet of a route proposed for addition to the NFTS and that 

plant (Klamath Mountain buckwheat) occurs more than 100 feet from a short (0.04 mile) 
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 E-12 Klamath National Forest

access route to a dispersed recreation site. It is unlikely the plant has been or will be affected 

by the use of this access route. Prohibition of cross-country motorized travel will eliminate 

the other impacts mentioned in the comment.

Public comment: One respondent representing several organizations is concerned with the 

statement that one plant (Meesia uliginsoa) is not likely to be disturbed if vehicles remain on 

designated routes and avoid wet fens because a sizeable portion of OHV users seek out and 

recreate in wet meadows and fens [172].

Response: As stated in Chapter 1 of the FEIS, this project proposes to clarify where 

motorized use may occur on the KNF and where it is prohibited. The MVUM, educational 

materials, and law enforcement will be used to encourage motorized user to remain on 

authorized NFTS routes and areas. Illegal use may damage resources but such use in 

unpredictable and cannot be assumed; monitoring the effects of the travel management 

decision will allow mitigation to be employed as detailed in Chapter 2 of the FEIS. Most 

OHV users are law-abiding and will comply with rules and regulations. 

Public comment: One respondent representing several organizations requests that the BMPs 

developed by the Wild Utah Project be adopted in the KNF travel planning effort; if these 

recommendations are not used, explain why not [172].

Response: The document ―Best Management Practices for Off-Road Vehicle Use on 

Forestlands (Wild Utah Project 2008) outlines recommendations for location and 

management of routes open to OHV use. The document is comprehensive, covering Soils, 

Vegetation, Wildlife, Special Ecosystems, and Use Conflicts. The KNF travel management 

project has incorporated many of the suggestions from this document in its process. Many of 

the Planning and Decision-making Best Management Practices (BMPs) were used in the 

original screening of routes for suitability for inclusion in the NFTS. Almost 350 miles of 

routes were not considered in an action alternative because they were found to have resource 

conflicts that could not be adequately mitigated, as disclosed in Chapter 1 of the FEIS. Many 

of the BMPs for Soils, Vegetation, Wildlife and Special Ecosystems were applied to this 

project. The extensive recommendations for monitoring and those for restoration of disturbed 

lands were not incorporated because they are outside the scope of this project. While the Utah 

Wild document provides excellent guidance, it is not considered direction for National Forest 

management and there is no requirement to use it in its entirety to guide the KNF travel 

management process.

Public comment: One respondent representing several organizations is concerned that reliance 

on monitoring and mitigating damage after it occurs will not achieve the KNF LRMP and NFMA 

goals to maintain viability [172].
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

_______________________________________________________________________ 

Klamath National Forest E-13

Response: As stated in the Botanical Resources section of Chapter 3 of the FEIS, action 

alternatives were designed to avoid effects to sensitive plant species occurrences. Monitoring 

and mitigation are to ensure that, if the situation changes in the future, changes can be made 

to protect these species. Compliance with LRMP and NFMA goals are disclosed in the 

Botanical Resources section of Chapter 3 of the FEIS.

Public comment: One respondent representing several organizations states the Forest Service is 

required to conduct a botanical investigation and prepare ―Species Management Guides‖ for 

sensitive species, prioritized based on threats due to management activities, before the impacts of 

the travel management actions can be accurately assessed (FSM 2670.22 and 2672.4) [172].

Response: No ―Species Management Guides‖ are required by FSH 2670.22 and 2672.4. To 

respond to the requirements of these directives, the Pacific Southwest Region (Region 5) of 

the Forest Service and the KNF have developed management practices and management 

objectives to maintain populations of native plant populations and to ensure species do not 

become threatened or endangered because of Forest Service actions. Effects to all sensitive 

species are analyzed in a biological evaluation per direction in FSH 2672.4. A Plant BA/BE 

has been prepared for this project and is in the project record located at the KNF Supervisor’s 

Office in Yreka, CA. The determination is that effects from the action alternatives are 

beneficial to all species due to the prohibition of cross-country motor vehicle travel. In 

relation to botanical investigations, the Region 5 Threatened and Endangered Plants Program 

Handbook states that the Regional Sensitive Plant Program is the basis for implementation of 

the Forest Service TES program in this Region. It requires a three-phased approach to the 

conservation of each listed or sensitive species: inventory, interim management, and recovery 

management. Most sensitive species are in the interim management phase, which does not 

require recovery plans but does requirement biological investigations, field reconnaissance, 

impact evaluations and other protective actions. These actions have been performed and are 

documented in the Botanical Resources section of the FEIS and the Plant BA/BE.

Public comment: One respondent representing several organizations indicates that the FS

Threatened and Endangered Plants Program Handbook requires recovery plans to be made for 

sensitive plant species, aimed at achieving the goal of removing the species from 

sensitive/threatened status as soon as possible. Activities near populations of these rare plants 

should therefore be devised in order to improve and enhance their habitat, not to destroy them. 

Lacking substantive biological information about the trends, status, and threats to these species on 

federal and private lands, the FS is simply guessing at the possible impacts from this project 

[172]. 

Response: Developing recovery plans for federally listed species is the responsibility of the 

USFWS. Federally listed species considered on the KNF are addressed in the Botanical 
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

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 E-14 Klamath National Forest

Resources section of Chapter 3 of the FEIS and in the Plant BA/BE which is part of the 

project file located in the KNF Supervisor’s Office in Yreka, CA. There are no unauthorized 

routes proposed for addition to the NFTS within 100 feet of any of the four federally listed 

species. One candidate for federal listing occurs on the KNF within 100 feet of unauthorized 

routes currently being used by motorized vehicles. Those routes are not proposed for 

addition to the NFTS under any of the action alternatives. Federal regulations do not require 

recovery plans for sensitive species. 

Climate Change

Public comment: One group suggests that the DEIS violates NEPA by failing to analyze the 

impacts of climate change [172]. Another respondent asks that the FEIS include a discussion of 

climate change and its potential effects on the Forest as it relates to the route designation decision 

and the National Forest Transportation System [205].

Response: This action is focused on managing where motor vehicles travel. This action does 

not regulate the number of vehicles on NFS lands. The regulation of emissions is not within 

the jurisdiction of this agency. The KNF acknowledges that climate change has the potential 

to affect resources on the forest. These effects are discussed in Chapter 3 of the FEIS, in the 

Botanical Resources, and the Air Resources sections. 

Coordination with other governmental agencies

Public comment: One respondent requests that the KNF add more motorized mixed use routes to 

make loop opportunities if Siskiyou County sets policy that would allow non-highway legal 

vehicles on non-paved County roads [59]; a respondent representing Siskiyou County explains 

the County’s lack of formal policy to this date, and expresses the desire for continued 

coordination between the KNF and the County [417].

Response: Coordination with Siskiyou County concerning travel management is ongoing and 

will continue as discussed in the Transportation section of Chapter 3 of the FEIS. The KNF 

will continue to look for additional loop opportunities and consider modifications to the travel 

management decision based on appropriate environmental analysis and disclosure as 

discussed in Chapter 2 of the FEIS. One loop opportunity considered in this project is 

opening the loop around Doe Peak to public motorized use.

Cross-Country Travel

Public comment: One respondent states that cross-country travel should be allowed on the KNF 

because negative effects are minimal and families enjoy it [59]; another respondent says crosscountry travel should be prohibited only where erosion occurs [171]. Other respondents support 

the prohibition of cross-country travel [17, 74, 177, 321-416, and FL 418].
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

_______________________________________________________________________ 

Klamath National Forest E-15

Response: Across the nation, unmanaged motor vehicle use, particularly OHV use, has 

resulted in unplanned roads and trails, erosion, watershed and habitat degradation, and 

impacts to cultural resource sites. Compaction and erosion are the primary effects of motor 

vehicle use on soils. Riparian areas and aquatic-dependent species are particularly vulnerable 

to damage from motor vehicle use. Unmanaged recreation, including impacts from OHVs, is 

one of ―Four Key Threats Facing the Nation’s Forests and Grasslands‖ (USDA Forest 

Service, June 2004).

On November 9, 2005, the Forest Service published final travel management regulations in 

the Federal Register (FR Vol. 70, No. 216-Nov. 9, 2005, pp 68264-68291). This final Travel 

Management Rule requires designation of those roads, trails, and areas that are open to motor 

vehicle use on national Forests. Only roads and areas 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. The final rule prohibits the use of 

motor vehicles off designated NFTS roads, trails and areas. No National Forest, including the 

KNF, is exempt from this rule.

The FEIS for the KNF analyzes effects of the proposed action and alternatives on resources, 

including soils and soil erosion, in various sections of Chapter 3 of the FEIS.

Public Comment: One respondent indicates that prohibition of cross-country travel will 

concentrate use on routes, increase maintenance costs, and reduce rider satisfaction, and suggests 

that the impacts on motorized vehicle users should be analyzed in the FEIS [201]. 

Response: As discussed in the section on Society, Culture and the Economy of Chapter 3 of 

the FEIS, the population size of Siskiyou County has been relatively stable for many years. 

Most recreation use on the KNF is by local residents of the county, and most OHV use is 

concentrated on NFTS native-surfaced (ML 2) roads. In addition, traffic volumes on the 

NFTS are low. While some routes that are proposed for addition to the NFTS may 

experience slightly higher use after the MVUM is published, large increases in the number of 

vehicles on the KNF are not expected. The FEIS analyzes the impacts on motorized vehicle 

users and rider satisfaction in the Recreation and Society, Culture and the Economy sections 

of Chapter 3; the cost of maintenance, concentration and amount of motorized vehicle use are 

discussed in the Transportation section of Chapter 3 and Appendix C of the FEIS. 

Cultural Resources

Public Comment: One respondent representing several organizations expressed concern that 

surveys of 33 of the 43 ―at risk‖ cultural resource sites had been deferred; therefore, information 

on these sites could not be used to develop alternatives [172].
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

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 E-16 Klamath National Forest

Response: As noted in the Cultural Resources section of Chapter 3 of the DEIS, cultural 

resource inventory of all high priority sites had occurred before the proposed action and 

alternatives were developed for the KNF travel management project. As required by the 

Programmatic Agreement Among the USDA Forest Service, Pacific Southwest Region, 

USDA Forest Service Intermountain Region’s Humboldt-Toiyabe National Forest, California 

State Historic Preservation Officer, and the 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 (Motorized Recreation PA) condition and effects assessments 

were conducted at sites determined to be ―at risk.‖ For those sites where no physical damage 

was noted or the effects were ambiguous, monitoring was prescribed. Appropriate mitigation 

measures as allowed under the Motorized Recreation PA were prescribed for those sites 

determined to have received some level of effect. This information was used to analyze 

alternatives in the FEIS. 

Public Comment: One respondent representing several organizations stated that the reliance on 

monitoring and mitigation of harm to cultural resources is misplaced. Post-hoc monitoring and 

mitigation are not an adequate substitute for avoidance and protection informed by timely surveys 

and analysis. Without mitigation the proposed alternatives ―could possibly compromise the 

LRMP cultural resources standards and guidelines‖ [172]. 

Response: At the time the DEIS was published, effects of this project were unknown on 33 

cultural resource sites. All 43 sites have been visited, but evaluations have not been 

completed. The KNF is treating these sites as ―unevaluated‖ for National Register of Historic 

Properties (NRHP) eligibility. Under the Motorized Recreation PA, NRHP evaluation can be 

deferred for historic properties where there has been no physical damage or effects are 

ambiguous, or when Standard Resource Protection Measures (SPRMs) can be prescribed. 

Each cultural resource site will be protected as if it was eligible until a determination of 

eligibility can be made. Protection measures are displayed in the Cultural Resources section 

of Chapter 3 of the FEIS. The purpose of an effects analysis is to determine the effects of the 

project activities on the resource. Using the best available science and available information, 

an analysis of the effects of each alternative was completed and results displayed. With the 

information available for the DEIS, the statement was made that ―Alternative 3 would 

comply with all LRMP standards and guidelines. Given the current data available, the 

selections of alternatives 2, 4, 5, or 6, without mitigations, could possibly compromise the 

LRMP cultural resources standards and guidelines. However, given the small site density 

[number of sites] . . . involved, all mitigations measures could be met very easily.‖ 

Alternative 1 (the ―no action‖ alternative) is the only alternative that would not comply with 

LRMP standards and guidelines. Monitoring and phased mitigation are permitted in the 

Motorized Recreation PA, and in the LRMP, and will be implemented for all action 
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

_______________________________________________________________________ 

Klamath National Forest E-17

alternatives. This gives the KNF an opportunity to assess future effects, determine eligibility, 

and implement appropriate mitigation measures that continue to protect the site’s integrity. 

Public Comment: One respondent representing several organizations stated that the Forest 

Service's perfunctory description of potential mitigating measures is inconsistent with the "hard 

look" it is required to render under NEPA. Merely listing mitigation measures, without any 

discussion as to their efficacy must be held illegal under NEPA. There is absolutely no discussion 

in the DEIS (or in any other document) of mitigation measures' implementation, use, efficacy or 

anything at all beyond their mere existence [172]. 

Response: As outlined in the Cultural Resources section of Chapter 3 of the DEIS, each 

cultural resource is considered on a site by site basis. Mitigation measures, when deemed 

necessary, are developed to ensure the site maintains its integrity if it is considered eligible or 

unevaluated for the NRHP. An in-depth analysis for each site would be beyond the scope of 

this document. Mitigation measures covered by the Motorized Recreation PA are discussed in 

that document and are highlighted in the Cultural Resources section of Chapter 3 of the 

DEIS; these include the use of signage, barriers, or even complete removal of a route from 

designation. Where conflicts with cultural resources existed that could not be mitigations, 

routes were removed from consideration. Furthermore, mitigation measures are efficient and 

based on the best available science, as noted in the modified Cultural Resources section of 

Chapter 3 of the FEIS.

Public Comment: One respondent representing several organizations stated that the Forest 

Service has not fully complied with the provisions of the Historic Preservation Act 16 USC §470 

sec. 106 or with Executive Order 11593 §2(a)(b) to conduct an archaeological reconnaissance 

[172]. 

Response: As outlined on page 234 of the DEIS, Executive Order 11593 highlights that 

Federal agencies ―use due caution until the inventory and nomination processes are 

complete.‖ The KNF has proposed monitoring and mitigations that exercise due caution until 

the full effects of impacts are assessed. Based on Programmatic agreements (36CFR 

800.14(b)), all action alternatives in the travel management document are in compliance with 

the Section 106 of the NHPA and the Advisory Council on Historic Preservation’s

implementing regulations by being in compliance with the Motorized Recreation PA as stated 

in the Cultural Resources section of Chapter 3 of the FEIS. Cultural resource inventories and 

site assessments were completed prior to the FEIS following the provisions of the Motorized 

Recreation PA. Therefore, the KNF is in compliance with Section 106 of the NHPA. Section 

106 states that the Federal agency will take into account the effect of the undertaking on any 

district, site, building, structure, or object that is included in, or eligible for inclusion in, the 

National Register. The KNF has done this for this travel management project. Compliance 
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

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 E-18 Klamath National Forest

with EO 11593 is implied when the provisions of 36 CFR 800 (in this instance, a 

programmatic agreement) are followed.

Cumulative Impacts

Public Comment: One respondent representing several organizations suggested that by not using 

travel analysis to analyze the entire NFTS, the assessment of cumulative impacts is deficient 

under NEPA [172].

Response: Cumulative effects of all alternatives are identified and described in Chapter 3 of 

the FEIS; these are clarified and expanded from the analysis and disclosure in the DEIS for 

most sections of Chapter 3. The impacts of the current NFTS are included as part of the 

current condition of the affected environment. The cumulative effects on each resource 

consider the present situation of most of the KNF being open to cross-country motorized use, 

and add ongoing and reasonably foreseeable road actions, to determine the cumulative effects 

of the no action alternative. The cumulative effects of the action alternatives consider the 

change from the present situation in miles of unauthorized route closed to motorized vehicle 

use, miles of route and acres of open riding area proposed for addition to the NFTS, and 

ongoing and reasonably foreseeable actions, to determine the cumulative effects of actions on 

resources. A separate analysis of the impacts of the current NFTS is outside the purpose and 

need for this project. 

Dispersed Camping, Parking and Access

Public comment: One respondent did not want the Forest to limit parking to one vehicle length 

or 30 feet from a road [201]; other respondents want motorized access to all dispersed camping 

sites (in addition to historic use sites analyzed in the DEIS) to be permitted within 100 feet of a 

designated road [20, 417]. One government agency requests identification of more areas on 

which to pull off routes with no adverse effects to resources [417], while another respondent says 

the DEIS unfairly limits access to camp, park and hunt, and should extend the area to at least 300 

feet [179].

Response: Forest Service direction does not mandate a specific distance from a designated 

road for parking; however, the Regional Forester for the Pacific Southwest Region has 

recommended either 30 feet from the center line of a designated route or one vehicle length 

from the side of the route as the appropriate length for driving and parking motorized 

vehicles. Forest Service Manual 7715.74 (1) states ―the Responsible Official may include in a 

designation the limited use of motor vehicles within a specified distance of certain forest 

roads...solely for the purpose of dispersed camping ....‖ The authority should be used 

sparingly....rather, the official should designate spur roads for this purpose. This project does 

not affect dispersed camping opportunity. Recreation users may camp wherever they wish on 

the KNF, as long as they do not cause resource damage. The Forest Supervisor decided to 
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

_______________________________________________________________________ 

Klamath National Forest E-19

accommodate motorized access to dispersed camping through the designation of routes to 

known, historically used dispersed campsites. These spurs range from less than 100’ to 

slightly more than 1 mile in length, and provide access to a variety of different areas. 

Alternatives 2, 4, 5, 6, and 7 all propose adding routes to the NFTS to accommodate 

dispersed camping and other dispersed recreation. This allows mobility-impaired individuals 

to experience camping and other dispersed recreation away from roads and developed sites.

Enforcement Efficacy

Public comment: A number of respondents expressed concern about the efficacy of enforcement 

of the ban on cross-country travel and closing unauthorized routes not added to the NFTS (based 

on a number of studies in areas other than California), and asked that the FEIS describe in detail 

how use restrictions will be enforced, and what enforcement has been successful [172, 173, 205]; 

one respondent states that current workforce and budget should be enough for enforcement [395]. 

Other respondents stated that voluntary compliance works, OHV riders are responsible, and the 

KNF has enough gates and barriers to do the job [59, 201]. One agency asked that the KNF move 

quickly to deal with any problems created by motorized vehicle use, and display the strategy and 

commitment for doing so in Appendix D of the FEIS [417].

Response: Based on field observations, as stated in the section on Law Enforcement 

Assumptions Common to Effects Analyses of Chapter 3 of the FEIS, it is assumed that the 

majority of the motorized vehicle users on the KNF are compliant with rules. This is 

supported by data supplied by the State of California Off-Highway Motor Vehicle Recreation 

Division that suggests that 95% of users are fully compliant with rules. When the rules are 

clear on where OHVs can be ridden, as will be the case with the publication and distribution 

of the MVUM for the KNF, it is expected that at least 95% of users will follow them. As 

discussed in the Transportation and Recreation sections of Chapter 3 of the FEIS, the number 

of users on the KNF is relatively small and not expected to increase substantially, so the 

number of violations is expected to be small. 

It is assumed that some violations will occur during the transition period as users are learning 

about the rules, and the KNF is committed to an education program to ensure that happens. It 

is also assumed that the presence of law enforcement and other agency personnel will 

positively affect users’ behavior, as stated in Appendix D of the FEIS. The Law Enforcement 

section of Chapter 3 of the FEIS has been expanded to highlight the commitment of the KNF 

to give special emphasis to the areas in which most OHV use is likely to occur, to prioritize 

and quickly deal with the 1% to 5% of users who create problems, and to do so with current 

KNF funds and personnel (with possible additional funds from the State of California OHV 

grant program). 
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

_______________________________________________________________________

 E-20 Klamath National Forest

Further information on law enforcement and how it relates to travel management can be 

found in Appendix D of the FEIS.

Environmental Effects of OHVs

Public comment: One respondent is concerned with the general environmental effects of OHV 

use [30]; other respondents state that effects are minimal [59], should be considered in relation to 

the impact of other, more substantial activities [20], and that the effects of traveling off-road for 

dispersed camping are minor [417].

Response: The environmental effects of cross-country OHV use on each resource are 

discussed in the various resource sections of Chapter 3 of the FEIS for the no action 

alternative (Alternative 1). Also, the effects of traveling on unauthorized routes that are 

proposed for addition to the NFTS or areas that are proposed to be open to motorized vehicles 

(open riding areas) are discussed for the action alternatives in Chapter 3 of the FEIS. The 

purpose and need for the travel management project is to examine the effects of prohibiting 

cross-country travel, adding routes and open riding areas, and making limited changes to the 

NFTS. Therefore, it may seem as though the effects of OHV use are magnified in relation to 

the effects of other activities but there is no intent to weigh the effects of OHV use on the 

environment against the effects of other activities. In the case of many resources, the effects 

of traveling off-road are minor. Details of the effects of OHV use on each resource are 

displayed in Chapter 3 of the FEIS. 

Public comment: A number of respondents are concerned with the effect of OHV travel on 

intact ecosystems [FL 2, 204, 321-416, FL 418]; some mention concern with habitat 

fragmentation and loss of connectivity of habitat [74, 172]. Other responses express concerns 

with the effects on a healthy forest habitat in general [FL 2, 173, 204] and habitat for threatened, 

endangered, and sensitive (TES) species and management indicator species (MIS) in particular 

[173].

Response: The effects of motorized vehicle use on ecosystems and habitat are discussed in 

Chapter 3 of the FEIS, in Terrestrial Wildlife, Fisheries Resources, Botanical Resources, and 

Non-native Invasive Species sections. The Terrestrial Wildlife, Fisheries Resources, and 

Botanical Resources sections include analyses of effects of alternatives on TES and MIS 

species. Additional information is available in the summarized and referenced Wildlife 

BA/BE and results of consultation with US Fish and Wildlife Service (USFWS), Fish BA/BE 

and results of consultation with National Marine Fisheries Service, and Plant BA/BE and 

results of informal consultation with USFWS in the project record, located in the KNF 

Supervisor’s Office in Yreka, CA. 
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

_______________________________________________________________________ 

Klamath National Forest E-21

Executive Orders

Public comment: One respondent representing several organizations asks that the KNF take all 

measures to manage motorized use so as to ―minimize damage to soil, watershed, vegetation and 

other resources‖ as required by Executive Orders 11644 and 11989 [172].

Response: The purpose of and need for the travel management process on the KNF is to find 

ways to make motorized use of the KNF available while protecting resources such as soil, 

watershed, vegetation and others as required by Executive Orders and the Travel 

Management Rule. The route screening process discussed in Chapter 1 of the FEIS, the 

action alternatives identified in Chapter 2 and results of the analysis of effects on these 

alternatives disclosed in Chapter 3 are based on ways of achieving this purpose and need. 

Alternative 3 is the most restrictive alternative for most resources. However, the direction in 

the Executive Orders and Travel Management rule to consider minimizing impacts to various 

resources does not require the Forest Supervisor to select the most restrictive alternative. As 

described in the Preamble to the Travel Management Rule, ―[i]t is the intent of E.O. 11644 

that motor vehicle use of trails and areas on Federal lands be managed to address 

environmental and other impacts, but that motor vehicle use on Federal lands continue in 

appropriate locations. An extreme interpretation of ―minimize‖ would preclude any use at all, 

since impacts always can be reduced further by preventing them altogether. Such an 

interpretation would not reflect the full context of E.O. 11644 or other laws and policies 

related to multiple use of NFS lands‖ (Fed Reg V.70, No. 216, p 68281).

Geologic Resources

Public comment: One respondent representing several organizations is concerned that codifying 

user created routes on unstable land (by adding them to the NFTS) is unwise and runs afoul of the 

KNR LRMP and NFMA [172].

Response: As far as geologic hazards and resources concerns (including on unstable land), 

action alternatives would meet LRMP standards because they prohibit cross-country travel 

which is the activity with most potential impact. Consistent with the LRMP, there will be an 

overall reduction in open unauthorized roads through unstable land in all action alternatives, 

as disclosed in the Geology section of Chapter 3 of the FEIS, and effects of the travel 

management decision to geological resources would be minimal or beneficial. Adding routes 

to the NFTS does not include any changes to road width or design. Field review of 

unauthorized routes in unstable lands proposed for addition in any action alternative revealed 

no major stability issues (i.e., fill failure, landslides, or crossing failure); public-identified 

routes that included these features were removed from the list of potential additions as 

discussed in the section on how alternatives were developed of Chapter 2 of the FEIS. The 

routes that are added to the NFTS, if any, will receive regular maintenance consistent with the 
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

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 E-22 Klamath National Forest

LRMP, described in the Monitoring section of Chapter 2 of the FEIS. This maintenance is 

aimed at reducing drainage problems including the concentration of water onto the hillslope. 

Thus, the landslide potential will be reduced on the Forest scale. The routes not added to the 

NFTS would still affect the landscape in the short term but would begin to recover with time. 

INFRA Database

Public comment: One group is concerned that the INFRA database is being used to develop the 

MVUM, because routes that have already been decommissioned and roads designated as ML 1 

are shown in the INFRA database and on DEIS maps of alternatives [202].

Response: The INFRA database provides a record of all roads on the KNF, even if they have 

been decommissioned, so that accurate reports can be produced of the activities that have 

occurred on KNF roads. Decommissioned roads are not shown on DEIS maps, nor on FEIS 

maps. Maintenance level 1 roads were inadvertently shown on DEIS maps; this error has 

been corrected for FEIS maps. Neither decommissioned roads nor maintenance level 1 roads 

as entered into INFRA will be shown on the MVUM. Information is intended to be entered 

into the INFRA database as actions occur but there is sometimes a time lag; corrections to the 

database are continuously being made. The most accurate current information will be used for 

the MVUM.

Inventoried Roadless Areas (IRAs)

Public comment: Some respondents do not want OHV use allowed in IRAs [FL 2, 127, 321-416, 

FL 418]; one respondent states that current use in IRAs is appropriate [178].

Response: There are no unauthorized routes proposed for addition in IRAs under any action 

alternative (see the IRA section of Chapter 3 of the FEIS). The KNF LRMP does not prohibit 

OHV use within IRAs; therefore, the current condition and Alternative 1 allow cross-country 

travel in IRAs. Some short spurs that lie within Citizen Inventoried Roadless Areas (CIRAs 

as identified by The Wilderness Society) that provide motorized access to dispersed 

recreation sites are proposed for addition to the NFTS in Alternatives 2, 5, 6, and 7. These 

short routes, associated with NFTS ML 2 roads, occur at the edges of the CIRAs as discussed 

in the Inventoried Roadless Areas section of Chapter 3 of the FEIS.

Maintenance 

Public comment: Several respondents request a discussion be added to the FEIS of the 

opportunity to use volunteers to maintain mixed use roads, and a description of the current OHVvolunteer program and its potential to assist with the Forest’s future road and trail maintenance

through programs such as adopt-a-trail or adopt-a-road [20, 417].
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

_______________________________________________________________________ 

Klamath National Forest E-23

Response: The KNF encourages volunteers and partners to share maintenance of NFTS roads 

and trails. Non-motorized trails have been maintained for years by partners and volunteers. 

There are currently no motorized trails, other than for over-snow vehicles, on the KNF but 

local user groups have stated an interest in volunteering for route maintenance once routes are 

designated through the travel management process. There is no current OHV-volunteer 

program on the KNF.

Public comment: A number of respondents have concerns that the KNF cannot maintain its 

NFTS, yet is proposing to add routes [FL 2, 74, 172, 321-416, FL 418]; several say the KNF must 

disclose the foreseeable cumulative and direct environmental impacts of not maintaining roads to 

standard [172, 352]; and several want to save maintenance dollars by reducing the operational 

maintenance levels of ML 3 and ML 4 roads [20, 417]. One group respondent and one agency 

pointed out that passenger cars (i.e., sedans) make up a very small portion of the traffic volume 

and asked that all maintenance level 3 roads be reclassified to maintenance level 2 [20,417].

Response: The majority of the road maintenance cost on the KNF is for maintenance level 

(ML) 3, 4, and 5 roads, and is spent on resurfacing and roadside brushing, as discussed in the 

Transportation section of Chapter 3 of the FEIS. Maintenance level 2 roads do not 

substantially add to costs. Routes proposed for addition to the NFTS as roads do not generally 

require active maintenance, so the additional maintenance cost is minimal once the required 

mitigation to prevent resource damage, if needed, is complete. Routes than can be maintained 

at lower operational levels of maintenance without compromising other needs, are discussed 

in the FEIS, Chapter 3, Transportation section, and in Appendix C. Not all ML 3 roads can 

appropriately be reclassified to ML 2, as is discussed in the Transportation section of Chapter 

3 of the FEIS. Although passenger vehicles have evolved to include a wide variety of SUVs 

and extended cab pickups, an ML 3 system of arterial and collector roads to access the KNF 

is still required to allow those vehicles to operate safely with intervisible turnouts and 

adequate sight distance. This system also minimizes the risk of breaking tires, scraping brush, 

or taking out oil pans. See also the response to comments in the adding routes section of this 

appendix.

Maps

Public comment: One respondent asked that routes not be shown on the Motor Vehicle Use Map 

(MVUM) if required mitigations have not been completed [172]; others request a schedule of 

when mitigations will be complete in the FEIS so that MVUM maps are correct when printed [20, 

417].

Response: The FEIS states that no routes will be officially designated and shown on the 

MVUM until required mitigation is complete (Mitigations Applicable to All Action 

Alternatives section of Chapter 2). Official files of the KNF MVUM will be retained at the 
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

_______________________________________________________________________

 E-24 Klamath National Forest

Forest Supervisor’s Office in Yreka, CA; the map will be reviewed, revised, and reissued as 

needed to include changes identified in the environmental analysis for future projects. 

Because of the timing of the motorized travel management decision, the initial MVUM may 

include potential routes but specify they will not be available for use until the mitigations are 

complete. Mitigations will be complete before the first season of use begins after publication 

of the initial MVUM.

Public comment: One local government agency asked that the FEIS include a process by which 

the KNF would take the initiative to propose additions to the MVUM rather than rely on the 

public to do so [417].

Response: The KNF will take the initiative to review the MVUM, examine internallyrecommended changes along with publicly-recommended changes, and determine the 

environmental analysis and disclosure required for decisions that would lead to revision of 

the MVUM as needed.

Minimum Road System

Public Comment: Several respondents indicate that the KNF should identify the minimum road 

system needed for safe and efficient travel and for protection of KNF lands, and should close and 

decommission NFTS routes that are not needed [172, 205].

Response: This project does not analyze the impacts of the current transportation system. 

That analysis, and decisions on closing and decommissioning NFTS roads, are outside the 

purpose and need for this project. The Pacific Southwest Regional Forester has committed to 

begin addressing Subpart A of the Travel Management Rule within the next 18 months; that 

process will provide information needed to identify the minimum road system required for 

management of the KNF. 

Mixed Use

Public comment: Several respondents state that the DEIS does not adequately analyze the effects 

of lowering maintenance levels and increasing mixed use [172, 205] and underestimates the 

effects of non-highway legal vehicle use on the spread of weeds [46, 172, 173, 404]; others ask 

for analysis of more miles of mixed use, on most or all ML 3 and ML 4 roads [20, 171, 417], 

more routes on which non-highway legal vehicles can travel [201], and consideration of 

temporary closures to logging trucks and other large vehicles so that more miles of road would be 

safe for non-highway legal vehicles [417].

Response: The effects of mixed use, and reasons for limiting mixed use to suitable routes, is 

discussed in the FEIS, Transportation section of Chapter 3, and in Appendix C. An extensive 

mixed use analysis effort was undertaken to identify ML 3 and ML 4 routes that connect ML 

2 road networks to provide seamless OHV opportunities. The analysis identified all ML 3 
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

_______________________________________________________________________ 

Klamath National Forest E-25

and ML 4 roads that are suited to mixed use and evaluated the effects of allowing mixed use 

on all these roads in Alternative 5. Numerous roads have been reclassified to ML 2 status 

over time; this effort is ongoing and will be reflected in periodic updates to the MVUM. 

Temporary closures and signing of roads to promote safety when large trucks will be using 

roads is an ongoing KNF activity; these temporary safety measures do not increase the 

number of miles of ML 3 and ML 4 roads that are suited to mixed use. The effects of mixed 

use on the spread of noxious weeds is analyzed and disclosed in the Botanical Resources and 

Non-native Invasive Species sections of Chapter 3 of the FEIS. 

Public comment: Several respondents disagree with the Regional Forester’s policy prohibiting 

non-highway legal vehicle travel on all ML 3, 4, and 5 roads, state that the correct term to permit 

these vehicles on roads should be ―combined use‖ if these are considered ―highways,‖ and do not 

think the KNF should prohibit mixed use on any unpaved road [20, 417].

Response: The Regional Forester’s letters addressing mixed use are clear on this issue, and 

the KNF will follow this direction. ―Combined use‖ is a California Vehicle Code term while 

the Forest Service uses ―mixed use‖ when non-highway legal vehicles are allowed on 

maintenance level 3 and 4 roads. A major concern of the Regional Forester is the safety of 

non-licensed drivers of non-highway legal vehicles, many of whom are under the age of 16. 

Therefore, he has decided that he will approve mixed use only for licensed drivers to operate 

non-highway legal vehicles on ML 3 roads selected for mixed use, and will not approve 

mixed use on ML 4 roads. The FEIS for the KNF addresses the effects of proposed mixed use 

on various numbers of miles for Alternatives 2, 4, 5, 6, and 7 in the Transportation section of 

Chapter 3 of the FEIS and the mixed-use analysis in Appendix C; results are displayed in the 

Transportation section of Chapter 3 of the FEIS. 

Noise or Solitude

Public comment: Several respondents expressed concern about noise pollution due to motorized 

vehicle use [30, 74], especially effects of noise on wildlife [172], horse riders [200], and quiet 

recreation [51]; one group and a local government suggested that speed limits in developed 

recreation areas would mitigate the effect of OHVs by requiring them to drive quietly [20, 417].

Response: The issue of noise in Wilderness and Inventoried Roadless Areas is the third 

significant issue discussed in Chapter 1 of the FEIS. The effects on residents of private land 

adjacent to the KNF are discussed in the Society, Culture and Economy section of Chapter 3 

of the FEIS. Mitigations for all action alternatives include measures to reduce the effects on 

noise on all uses and users identified in these public comments. Analysis and disclosure of 

the effects of noise on quiet recreation are found in the Recreation section of Chapter 3 of the 

FEIS; a thorough analysis and disclosure of the effects on wildlife is presented in the 

Terrestrial Wildlife section of Chapter 3 of the FEIS; and the decision to eliminate Alternative 
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

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 E-26 Klamath National Forest

B from detailed study is partially due to visitor conflict among horses, humans, and 

motorized vehicles on non-motorized trails (Chapter 2 of the FEIS). The suggestion to 

reduce speed limits for OHVs in developed recreation areas is outside the scope of the travel 

management decision but may be considered outside this project. 

Non-native Invasive Species, Noxious Weeds

Public comment: A number of respondents express concerns about the spread of noxious weeds 

by cross-country motorized OHV travel and oppose the addition of unauthorized routes to the 

NFTS to reduce the spread of weeds [172, 173, 404]. One group of respondents states that the 

effects on weed spread of allowing non-highway legal vehicles on ML 3 roads (mixed use) have 

been underestimated [46].

Response: One of the purposes of this project is to provide management direction for where 

motorized vehicles can travel, thereby reducing the potential for spread of noxious weeds. 

Implementation of any of the action alternatives would considerably reduce the area available 

for OHV use and the potential for spread of weeds, as disclosed in the Non-native Invasive 

Species section of Chapter 3 of the FEIS. The addition of some unauthorized routes to the 

NFTS, effects of this on noxious weed spread, and monitoring and mitigation measures in 

place to limit the spread of weeds are also discussed in the Non-native Invasive Species 

section of Chapter 3.

Public comment: One respondent representing several organizations quotes the DEIS as 

acknowledging the significant impacts of motorized use (as opposed to route/road construction or 

establishment) on the spread of invasive plant species, and that weed infestations will continue to 

spread and the rate of spread will be increased by motorized vehicle activity; the commenter 

states that the DEIS also includes the statement that ―proposed additions to the NFTS could have 

increased use which may increase impacts...‖ [172].

Response: In the DEIS the statement quoted notes that motorized use may increase on 

unauthorized routes added to the NFTS since cross country travel and other unauthorized 

routes will no longer be available for use, not that overall motorized travel use of the KNF 

will increase. The Transportation, Recreation, and Society, Culture and Economy sections of 

Chapter 3 of the FEIS disclose that there is no reason to assume that motorized use of the 

KNF, and especially OHV motorized use, will increase substantially since most users are 

local, the local area has not been growing substantially in population, and there is no 

information available to suggest that OHV use of the KNF will increase substantially in the 

future. Furthermore, any of the action alternatives would reduce the total area available for 

use, and thus reduce impacts compared to the current condition. The greatest threat to 

establishment of new weed sites is creation and repeated use of unauthorized routes; this 

activity will be eliminated under any of the action alternatives. The Non-native Invasive 
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

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Klamath National Forest E-27

Species section of Chapter 3 of the FEIS has been modified to include the measures currently 

used and planned for future use to limit the spread of weeds from road use.

Public comment: One respondent representing several organizations states that Executive Order 

13112 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. The 

comment indicates that the KNF’s intent to encourage off-road motorized use at the Humbug site 

which contains yellow star thistle does not fit with the EO. As stated on page 290 of the DEIS, 

invasive species located in the proposed OHV play areas ―could be transported to other locations 

on the Forest.‖ It appears to the commenter that the KNF is ignoring the requirements of both the 

Executive Order and its LRMP by proposing to facilitate a recreational activity enjoyed by a very 

small percentage of Forest users that the agency anticipates will directly contribute to the spread 

of invasive species; proposals to add miles of unauthorized route within 100 feet of known 

noxious weed sites violate Executive Order 13112 [172].

Response: County, State, and Federal noxious weed guidance recognize that some weeds 

have become so abundant and widespread that eradication and control are sometimes not 

feasible so they put these weeds on the C-list. Yellow star thistle is on the California C-list; it 

is considered widespread and permanently established and only eradicable in small areas. The 

Forest Service has prioritized weed infestations based on the aggressiveness of spread of the 

species, the degree of regional concern, and the feasibility of control. Yellow star thistle is 

treated in areas of the KNF where control is expected to be effective. Lands within designated 

open riding areas will be subjected to soil displacement, and much of the acreage will be 

inhospitable to weeds. Loading and parking sites are the areas that have highest risk for weed 

introduction. Those sites will be assessed for weeds and treated as appropriate. The Humbug 

open riding area is located on a heavily used County road so, even if weed infestations are 

treated, reintroduction of weeds into these areas is highly probable. The modified Non-native 

Invasive Species section of Chapter 3 of the FEIS discloses feasible and prudent measures 

being taken to minimize the risk of harm from the spread of noxious weeds as required by

Executive Order 13112. By designating motorized use routes, the KNF would substantially 

reduce the number of miles and acres available for motorized use on the Forest. In particular, 

the prohibition of cross country travel that is a component of all action alternatives would 

change the nature and extent of motorized use on the Forest and reduce the chances of nonnative species being introduced to native plant communities. Implementation of any of the 

action alternatives would increase the chances that non-native species would be confined to 

areas near roads where they can more easily be treated. See also the response to the comment 

related to minimizing effects.
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

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 E-28 Klamath National Forest

Port Orford Cedar (POC)

Public comment: One respondent representing a number of organizations indicated concern that 

the DEIS did not close unauthorized routes to prevent spread of POC root disease and did not 

identify POC as a significant issue/resource impacted by motorized use [172].

Response: In response to this comment, Chapter 3 of the FEIS includes a section on Port 

Orford Cedar. Only one unauthorized route in the area of potential spread of POC root 

disease, a short spur to dispersed recreation sites, was proposed for addition to the NFTS 

in any action alternative. Alternatives 3, 4 and 7 do not propose to add this route to the 

NFTS; in the case of Alternative 7, this is specifically to prevent the spread of POC root 

disease.

Purpose and Need

Public comment: One respondent representing several organization states that the purpose and 

need statement is insufficient to allow for a proper and complete analysis; travel planning must 

evaluate and address the environmental, social, and cultural impacts associated with unauthorized 

routes and currently designated roads, trails, and area as identified through the Forest-wide Roads 

Analysis [172].

Response: The purpose and need statement was developed to address Subpart B of the 

Travel Management Rule and is, therefore, sufficient for this process. The 

environmental, social and cultural impacts associated with routes proposed to be added to 

the NFTS in Alternatives 2, 4, 5, 6, and 7 are addressed in Chapter 3 of the FEIS. The 

KNF does not currently have any motorized trails for vehicles (other than over-snow 

vehicles) or open riding areas; the implication of the statement in the Travel Management 

section of Chapter 1 of the DEIS that trails allowing motorized use existed on the KNF 

NFTS was in error; only trails for motorized over-snow vehicles exist currently on the 

KNF. This has been clarified in Chapter 1 of the FEIS. 

Recreation

Public comment: Several respondents state that OHV use is a very small percentage of use on 

the Forest but creates a disproportionate amount of disturbance and resource damage; they want 

to make sure that the KNF does not just listen to OHV users in making a travel management 

decision [FL 2, 3, 204]; other respondents want to make sure that the KNF does listen to OHV 

users [1, 20, 417].

Response: As stated in the Travel Management Rule, as part of the evaluation criteria for 

designating roads and trails where motor vehicle use will be allowed, the Forest Supervisor 

must consider the effects of route designations on conflicts among uses of National Forest 

System lands. The Recreation and Society, Culture and Economy sections in Chapter 3 of the 
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

_______________________________________________________________________ 

Klamath National Forest E-29

FEIS address the possible conflicts among uses that would result from implementing each of 

the alternatives. The KNF is listening to all individuals and groups as indicated by the public 

involvement summarized in Chapter 1 of the FEIS, this response to comments on the DEIS, 

and modifications made and displayed in the FEIS based on public comment including the 

new Alternative 7 developed in part to respond to comments on the DEIS.

Public comment: Several respondents stated that motorized vehicle use negatively affects nonmotorized recreation; they are concerned about the visitor conflicts between motorized recreation 

users and non-motorized users, especially visitors who seek quiet recreation (hikers, mountain 

bikers, wildlife-watchers and horseback riders) [74, 172, 199, 321-416, FL 418].

Response: The effects of motorized use on non-motorized recreation use were analyzed for 

all alternatives; a measurement indicator was used to compare effects of alternatives on quiet 

recreation. The effects of all alternatives on non-motorized recreation, quiet recreation, and 

resolving visitor conflicts by separating uses, are disclosed in the Recreation and Society, 

Culture and Economy sections of Chapter 3 of the FEIS.

Public Comment: One group requested an analysis of the cumulative effects of increased 

motorized vehicle use on the KNF due to publishing the MVUM [172]. Several respondents 

requested more or larger open riding areas, suggested that the open riding areas in alternatives 

may not safely (in regard to human and the environmental safety) meet demands for use; they 

asked that the FEIS analyze how many OHV users will be affected by the reduction from 1.2 

million acres available for cross-country travel to 0-65 acres depending on alternative [20, 203, 

and 417].

Response: As discussed in the Transportation and Recreation sections of the FEIS, motorized 

vehicle use levels on the KNF are relatively small in relation to capacity, and are not likely to 

increase substantially in the future. There are no data available to allow accurate prediction of 

the future impact of publication of the MVUM. The Monitoring Applicable to All Action 

Alternatives section of Chapter 2 of the FEIS has been expanded to include monitoring of 

demands for motorized vehicle use through NVUM and public comment. If monitoring 

indicates substantial increases in use, the MVUM may be modified in the future based on 

appropriate analysis and disclosure. If demand for motorized use of open riding areas is 

shown to increase substantially, so that the open riding areas selected are no longer adequate 

in regard to human and environmental safety, the travel management decision can be 

modified by future projects as discussed in Chapter 2 of the FEIS. The Recreation and 

Society, Culture and Economy sections of Chapter 3 have been modified to expand 

discussions of the effects on OHV users from the prohibition of cross-country travel. There 

are no data available to allow accurate prediction of the number of OHV users who will be 

affected by this prohibition.
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

_______________________________________________________________________

 E-30 Klamath National Forest

Roads

Public comment: Several respondents requested that the Forest modify the maintenance level 

descriptions shown on page 344 of the DEIS and page 5-6 of Appendix C to match the correct 

and current Forest Service Handbook definition shown on page 2 of Appendix C [20, 417].

Response: Maintenance level descriptions on page 2 of Appendix C come directly from the 

Forest Service Handbook. For ease of understanding, these descriptions were rewritten and 

tailored to the KNF NFTS. An explanation of this has been added to the Transportation 

section of Chapter 3 and Appendix C of the FEIS.

Public comment: Some respondents requested a display of all 800 miles of unauthorized routes 

in Appendix A so the public understands why the rest were eliminated from detailed study and not 

proposed for designation [20, 417].

Response: Over the past 20 years, the KNF has accumulated an inventory of about 800 miles 

of unauthorized routes. Some of these routes existed on the ground and were passable by a 

vehicle. Others were old skid trails that could not be driven, or temporary roads that had 

never been taken off the inventory. Some were non-existent—roads that had been planned but 

had never been built, or were identified due to map errors. Forest personnel validated several 

hundred miles of these routes, and this information was shared with the public at a series of 

meetings at various locations throughout the County. Groups and individuals were asked to 

identify routes that were being used for off-highway travel, or were desired to be used for 

such travel. The public identified 497 miles of routes. These 497 miles were then evaluated 

to identify any resource, safety and affordability concerns that might be associated with 

designating them as available for motorized use. Routes that emerged from this screening 

process as potential additions to the NFTS were field verified; some were found to be no 

longer identifiable on the ground or not useable for any motorized access while others were 

not suitable for addition to the NFTS due to resource concerns that could not be reasonably 

mitigated. The screening process is summarized in Chapter 2 of the FEIS and available in the 

project record located at the KNF Supervisor’s Office in Yreka, CA. 

Public comment: Several respondents suggested that maintenance levels on all roads be based on 

the percentage of type of vehicle use; they indicated that it makes little sense to keep roads at a 

higher maintenance level if passenger cars are a minor component of the traffic (just 2% on the 

KNF, and that all paved roads (asphalt, chip seal, etc.) should be ML 5 [20, 417].

Response: Although passenger vehicles have evolved to include a wide variety of SUVs and 

extended cab pickups, a maintenance level 3 system of arterial and collector roads to access 

the KNF is still required to handle these vehicles safely with intervisible turnouts and 

adequate sight distance. This system also minimizes the risk of damage to tires or 

undercarriages. The major differences in maintenance costs between ML 3 and ML 2 roads 
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

_______________________________________________________________________ 

Klamath National Forest E-31

are roadside brushing for safety and additional culvert cleaning (due to the safer in-sloped 

road surface on ML 3 roads). Neither of these tasks is dependent on vehicle type. Another 

difference is more frequent rock-fall removal on ML 3 roads which helps with vehicle ground 

clearance issues but also improves safety by not requiring vehicles to navigate rocks and 

other debris to avoid vehicle damage.

Maintenance level 5 roads are specifically defined as double-lane paved roads; KNF ML 4 

roads that are paved or chip-sealed serve administrative and developed recreation sites or 

were surfaced for dust abatement for large equipment related to timber sales years ago. When 

roads that are surfaced for dust abatement reach the end of their service life, consideration 

will be given to grinding and blending the surfacing back to an aggregate surface. These 

roads will then fit the criteria for lower operational maintenance levels.

Public comment: Several respondents identified a seeming discrepancy in the available mileage 

of NFTS roads shown on pages 21, 351, and 352 of the DEIS [20, 417]

Response: The number of miles shown on page 21 of the DEIS is incorrect and has been 

corrected in the FEIS. The number on page 351 is correct for the entire Klamath National 

Forest. The number of miles in the table on page 352 omits the miles maintained on the 

portion of the KNF that is managed by the Six Rivers NF (the Ukonom Ranger District) as is 

noted in the paragraph immediately preceding the table. The table heading has been modified 

to reflect this information in the Transportation section of Chapter 3 of the FEIS.

Public comment: A number of respondents suggest that the Forest should close system routes, 

primarily through decommissioning, to save maintenance costs and prevent resource damage 

from lack of route maintenance [FL 2, 17, 172, 204, 321-416, FL 418].

Response: The purpose and need for the current action is to implement Subpart B of the 

travel management regulations and address unmanaged motorized cross-country travel, not to 

close NFTS routes. Maintenance costs and the KNF strategy for meeting maintenance needs 

using current budget allocations are discussed in the Transportation section of Chapter 3 of 

the FEIS. See also earlier responses to comments on adding routes and open riding areas.

Public comment: A respondent representing several organizations suggests that NFTS roads 

identified in the KNF Roads Analysis as having both low value and high risk should be closed 

and decommissioned in this travel management decision [172].

Response: The purpose and need for the current action is to implement Subpart B of the 

travel management regulations and address unmanaged motorized cross-country travel, not to 

close NFTS routes. Roads analyses, including the KNF Forest-wide Roads Analysis, describe 

conditions at a given time, discuss findings, give recommendations, and outline strategies for 
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

_______________________________________________________________________

 E-32 Klamath National Forest

road management; they do not make decisions. Decisions on closing and decommissioning 

roads require separate environmental analyses, beyond the scope of the current travel 

management planning effort. Since the 2002 publication of the KNF Forest-wide Roads 

Analysis, a number of decisions to close and decommission roads on the KNF have been 

made. The KNF will continue its strategy for road decommissioning independent of this 

project. 

Public comment: A respondent representing several organizations stated that if the Forest 

Service continues to propose opening decommissioned and/or closed roads for motorized use, the 

rationale for the initial closure needs to be carefully re-analyzed and disclosed in the EIS [172].

Response: No decommissioned roads are proposed for opening to motorized use in this 

project. The proposed action in the DEIS included changing the maintenance level on 2 roads 

from ML 1 (closed) to ML 2 (open for motorized use). After scoping was complete on the 

proposed action, it was determined that one road (40N51) that had been closed to ameliorate 

road surface concerns and promote wildlife habitat (after a fire in 1987 had removed most of 

the vegetation surrounding the road) was reopened in 2007 after determining the closure was 

no longer needed. Road maintenance performed when the road was opened on an emergency 

basis for wildfire access had addressed road surface concerns and the vegetation surrounding 

the road had grown sufficiently to protect it from erosion and provide wildlife habitat and 

cover. Thus, only one road (41S10) was considered for a change from ML 1 to ML 2 in other 

action alternatives. This road near Doe Peak had been constructed on a railroad grade of less 

than 3% slope with large radius curves to accommodate trains when the land was in private 

ownership. After the land was acquired to be part of the KNF, the road was gated but it was 

never officially closed by a Forest Order. The road provides a loop opportunity for motorized 

vehicles to a high place with a scenic vista and does not have any documented soil erosion or 

connectivity to streams. Detailed information is available in the project record located at the 

KNF Supervisor’s Office in Yreka, CA.

Route-specific Comments

Public Comment: One group requested that several routes and one open riding area be added to 

the KNF NFTS [203]; another respondent requested that one specific route be added [320]. A 

group requested that specific roads and road segments in South Fork Indian Creek that are 

impassible due to landslides be physically closed and not be shown as open for motorized use on 

the MVUM [46].

Response: The request for additional routes was analyzed and results discussed in the 

Alternatives section of Chapter 2 of the FEIS in the discussion of Alternatives Considered but 

Eliminated from Detailed Study. The route suggested for addition by an individual was 

determined to be located on another National Forest; the comment was forwarded to that 
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

_______________________________________________________________________ 

Klamath National Forest E-33

Forest. The South Fork Indian Creek Road is now shown in INFRA as ML 1. It is physically 

closed by a barrier, and will not be displayed as being open for motorized use on the MVUM; 

this is discussed in Chapter 2 of the FEIS under Alternative 7.

Public comment: Several respondents suggest specific routes for addition to the NFTS, and 

request no season of use restrictions on added routes and open riding areas [203, 320].

Response: Some of the suggested routes were evaluated in Steps 1-3 of the travel 

management process outlined in Chapter 1 of the FEIS; a determination was made to remove 

them from consideration in this process after field verification due to resource, safety, or 

maintenance cost concerns (some were found to be no longer identifiable on the ground or 

not useable for any motorized access). Others were evaluated between the DEIS and FEIS; 

results of these determinations are as follows: 

About 1.4 miles of routes that form loop opportunities outside the Juniper Flat play area were 

identified in one comment. These routes were not part of the original inventory. Review of 

the routes indicates that vehicle use is adversely affecting several cultural resource sites. 

Therefore, these routes were not considered for addition to the NFTS in any action 

alternatives but are discussed in an alternative considered but eliminated from detailed 

analysis (Alternative F). One non-motorized trail to Siphon Lake was identified. As noted in

Alternative B, another alternative considered but eliminated from detailed analysis, nonmotorized trails were not intended for motorized use and would require engineering review, 

design, and potentially substantial reconstruction to accommodate that use. Adding 

motorized use to equestrian and foot trails would create conflicts between motor vehicles and 

non-motorized recreational uses of NFS land, and create safety issues associated with those 

conflicts. Therefore, this trail was not considered for addition to the NFTS in any action 

alternative.

Two trails were recommended by a local OHV riding group for use by all vehicles, Trails 

4608301 and 46083401. These routes are proposed for use by motorcycles only due to the 

steepness and width of the routes and their ability to provide a different type of recreation 

experience. Trail 45080208, identified early in the process, was eliminated from any action 

alternative because it provided a duplicate riding opportunity with an adjacent ML 2 road. 

Trail 46082603 was identified on a map but could not be located on the ground, nor could any 

wheel tracks be located in the vicinity, so this trail was eliminated from any action alternative. 

Routes 7J002.1A, 7J002.2, 46073201 and 46073205, recommended for addition to the NFTS 

by a local OHV riding group, would require extensive reconstruction prior to being available 

of use so they were eliminated from any action alternative. Route 7J002.6 is recommended 

for addition to the NFTS as a road in Alternatives 5 and 7. Route 45N08X crosses into private 

land; there is no right-of-way for public access on this route so it was eliminated from any 
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

_______________________________________________________________________

 E-34 Klamath National Forest

action alternative. Route 45N28.7 on Montana Peak was eliminated from consideration due to 

concerns for wildlife and rare plants. Route 7J002.3 was eliminated because it is a dead-end 

spur that does not access any recreation feature or opportunity. Roads 46N16 and 46N16A 

are proposed for highway-legal vehicles only because of concerns from private landowners in 

the area regarding conflicts with OHVs. Through an oversight, the Vesa Bluff trail was never 

mapped in the current travel management process so the effects of designating it as part of the 

NFTS were never analyzed. This route may be considered for addition to the NFTS in a 

future project decision. Road 45N41.2 is already open to motorized vehicle use as part of the 

NFTS; it was inadvertently included in the proposed action (Alternative 2) but the error was 

caught before publication of the DEIS so it is not part of any other action alternative. In 

Alternatives 5, 6, and 7, route 45N88.2 is proposed for addition to the NFTS; this would 

provide a loop opportunity with the open road 45N41.2.

The local OHV riding group also requested no season of use restrictions on routes 8J002.3c, 

8J002.3 segment 1, 8J002.3 segment 3 and 7H002.2. Season of use restrictions were placed 

on these routes due to concerns about deer winter range. The dates for the season in which 

use will be allowed were coordinated with the California Department of Fish and Game, as 

disclosed in the Terrestrial Wildlife section of Chapter 3 of the FEIS.

Public comment: One respondent representing a group suggests that the some routes identified 

for addition to the NFTS as ML 2 roads also specify that they are for motorized use only by 

vehicles less than 50‖ in width and wonders why these were not considered as 4WD trails or 

motorized trails for all vehicles [203].

Response: The DEIS, Appendix A, included an error in the placement of routes; all routes 

proposed for addition to the NFTS for use by vehicles less than 50‖ in width should have 

been in the table for addition to motorized trails. This error has been corrected in Appendix A 

of the FEIS. These routes are proposed for vehicles less than 50‖ in width to provide riding 

opportunities; they were not considered for 4WD or all vehicles due to the width of the 

existing unauthorized route surface, and resource concerns if the routes were widened. 

Routes added as roads will be available to most vehicles.

Safety

Public comment: One group stated the FEIS must address public health and safety issues, 

suggested an analysis of potential injuries related to open miles of route and the effect of law 

enforcement on safety; and asked that the FEIS disclose the potential for fatal injuries resulting 

from alternatives that allow OHV use in remote locations [172].

Response: The Motorized Mixed Use (MMU) analysis, included in Appendix C and 

summarized in the Transportation section of Chapter 3 of the FEIS, considered the safety 

aspects of designating routes for different vehicle types. Crash history for the KNF was 
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

_______________________________________________________________________ 

Klamath National Forest E-35

disclosed as part of that analysis. No crashes or injuries have ever been documented on the 

KNF between users of OHVs and highway legal vehicles as far back as records are kept. If 

safety concerns arise in the future and are documented through monitoring, mitigations may 

be implemented or modifications made to the MVUM as discussed in Chapter 2 of the FEIS.

Public comment: One respondent was concerned about safety if motorized use was allowed on 

non-motorized trails [200].

Response: Allowing motorized use on non-motorized trails was discussed in an alternative 

considered but eliminated from detailed study (Alternative B) in Chapter 2 of the FEIS. This 

alternative does not meet the purpose and need, and was eliminated from detailed study 

partially because of safety concerns. None of the alternatives considered but eliminated from 

detailed study, including Alternative B, will be selected for implementation.

Scope of the Project

Public comment: Several respondents state that the proposal focuses too much on analyzing the 

potential impacts of designating new unauthorized routes, and not enough on assessing the 

impacts of NFTS roads [172, 205].

Response: The identified need for action is to implement the prohibition on cross-country 

travel contained in Subpart B of the travel management regulations, and to identify for 

potential addition to the NFTS those unauthorized routes that are well-situated and provide 

important access and recreation opportunities. The FEIS appropriately focuses on the direct, 

indirect, and cumulative effects associated with the proposed action and alternatives. The 

NFTS, changes to the NFTS due to ongoing and reasonably foreseeable actions, and state, 

county, other Federal and private roads were considered in the cumulative effects analyses in 

the FEIS as appropriate.

Public comment: A number of respondents ask that the scope be expanded to include effects of 

the NFTS, especially of current roads and trails with known impacts [172, 202, 205, 321-416, FL 

418].

Response: The scope of the proposal is directly related to the purpose and need for action. 

Please see the responses provided to comments in the sections on adequacy of analysis and 

purpose and need. 

Seasonal Closures

Public comment: One agency stated that the DEIS does not provide information on the routes on 

which wet-weather closures will occur, related environmental impacts of allowing use on routes 

during wet weather, and effectiveness of such closures in protecting the environment [205]; 

another respondent states that closures should be based on weather-related criteria, and not set 
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

_______________________________________________________________________

 E-36 Klamath National Forest

dates [201]. One agency requested longer periods of wet weather seasonal closure [205]; a local 

government wanted a shorter seasonal closure for the Humbug open riding area and roads and 

motorized trails in the Humbug drainage [417].

Response: To provide clarity to motorized vehicle users, and improve voluntary compliance 

with the travel management decision, the seasons during which motorized use will be allowed 

will be included on the MVUM in advance and not vary daily. The dates for seasonal use of 

the open riding area, roads and motorized trails in the Humbug drainage correspond to the 

dates recommended by the State of California, Department of Fish and Game to assure 

provision of critical winter habitat for deer. The season of use for motorized vehicles other 

than over-snow vehicles on routes that are used by over-snow vehicles in the winter are set to 

separate types of motorized use and minimize user conflicts. The season of use for routes near 

Swainson’s hawk nests is set to avoid disturbance to nesting hawks. Seasons of use are not 

proposed to directly mitigate the effects of open routes on sedimentation; indications that this 

might occur in the DEIS were incorrect. Seasonal wet weather operating restrictions for 

NFTS roads are currently imposed only to protect road surfaces and roadbeds from rutting, 

and are only used for heavy vehicles such as logging trucks. Wet weather closures may be 

indirectly helpful in preventing soil movement into streams because protecting the road 

surface and roadbed from rutting can keep some soil from eroding. However, soil that is 

displaced from road surfaces in dry seasons can be mobilized by rain into streams during wet 

seasons (if there is connectivity between the sediment source and the stream) as discussed in 

the Hydrology section of Chapter 3 of the FEIS. The section on Mitigations Applicable to All 

Action Alternatives of Chapter 2 of the FEIS has been modified to correctly portray

information on seasons of use. A display of mitigations for each proposed addition to the 

NFTS is presented in Appendix A of the FEIS by route and by action alternative. Season of 

use for each route (the inverse of seasonal closure) is displayed on Tables A-3, A-4, and A-5.

Soils—Productivity, Compaction and Erosion

Public comment: Several respondents expressed concern with potential soil compaction and 

erosion from unauthorized roads that are open for motorized use [17], from cross-country travel 

[74], and from open riding areas being proposed [172]. One respondent representing several 

organizations states the Forest Service must demonstrate it is protecting soil resources, and cites 

studies that have documented that erosion of native surfaced roads is increased by traffic [172]. 

Another respondent is concerned that prohibiting cross-country travel will concentrate motorized 

use on fewer miles of routes [201], and one respondent thinks cross-country travel should 

continue to exist providing there is no resource damage such as erosion [171].

Response: Soil compaction on, and soil erosion from, unauthorized routes open to motorized 

use is discussed in the Soils section of Chapter 3 of the FEIS. A number of recent studies 

cited in the Hydrology and Soils sections have concluded that volume of motorized traffic is 
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Appendix E: Response to Comments

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Klamath National Forest E-37

directly correlated to the degree of soil erosion from road surfaces, and that motorized traffic 

is the greatest contributor to soil erosion of all varieties of traffic (horse, foot etc.). All action 

alternatives reduce the number and miles of unauthorized routes on which soil compaction or 

erosion will occur, and prohibit cross-country travel that could lead to establishment of more 

routes. Unmanaged cross-country travel has the potential to disturb soils almost anywhere on 

the 1.2 million acres open for off-road travel; it is uncertain which areas may be disturbed or 

where new routes may be located, and so effects to soils can’t be precisely addressed. 

Allowing cross-country travel only in small open riding areas minimizes the area on which 

soil compaction can take place; these open riding areas can be placed on sites that keep 

sediment from entering streams or other bodies of water. Overall, prohibiting cross-country 

motorized travel Forest-wide, and limiting the number of unauthorized routes proposed for 

addition to the NFTS to those that have minimal resource concerns, reduces the area affected 

by soil compaction and erosion. There may be a potential for increased soil erosion on some 

routes if motorized traffic is concentrated on these routes. However, designating these routes 

as part of the NFTS assures they will be monitored for soil erosion as part of the road and 

trail monitoring discussed in Chapter 2 of the FEIS. Based on the results of this monitoring, 

maintenance or mitigation can be prescribed to address resource concerns.

Public comment: Soil productivity is mentioned by one respondent representing several 

organizations who has concerns that the DEIS states that proposed NFTS additions need not abide 

by NFMA and KNF LRMP soil productivity standards [172].

Response: NFTS roads and other dedicated facilities such as developed campgrounds and 

administrative sites are exempt from soil productivity standards cited in the KNF LRMP and 

Forest Service Region 5 Soil Management Handbook Supplement (R5 FSH Supplement 

2509.18-95-1), so unauthorized routes proposed for addition to the NFTS would also be 

exempt. All action alternatives prohibit motorized use on the majority of miles of 

unauthorized routes (from 81% to 100% depending on the alternative); these closed routes 

will be covered by soil productivity standards under all action alternatives.

Public comment: One respondent representing several organizations is concerned with proposals 

to add routes and open riding areas to the NFTS in areas with high or very high Erosion Hazard 

Rating (EHR), particularly in the Humbug drainage in which the KNF found a high degree of soil 

compaction and rutting on slopes [172].

Response: Erosion Hazard Rating (EHR) is a broad evaluation of soil’s susceptibility to 

erosion and the potential for soil displacement (movement off site), as discussed in the Soils 

section of Chapter 3 of the FEIS. Soils with high or very high EHR ratings are primarily on 

the west side of the KNF. Most of the miles of route proposed for addition to the NFTS are on 

the east side of the KNF. Of the 0 to 36 miles proposed for addition to the NFTS on soils 
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 E-38 Klamath National Forest

with high and very high EHR ratings in various action alternatives, almost all are in the 

Humbug drainage. The Soils and Hydrology sections of Chapter 3 of the FEIS have been 

expanded to include more information about the potential effects on soils in the Humbug 

drainage; the Soils section includes specific mitigation for routes with documented soil 

erosion. As disclosed in Chapter 3 of the FEIS, all action alternatives would improve soil 

conditions over the current condition; soils on the 81% to 100% of miles of unauthorized 

routes closed to motorized vehicle travel would begin to recover, although recovery of soils 

with High and Very High EHR ratings would take a very long time (50 years or more). 

Terrestrial Wildlife

Public comment: A number of respondents were concerned that the proposed action would 

result in increased impacts to wildlife [51, 74, 173, 321-416, FL 418], and expressed the desire to 

the KNF to address the value of wildlife [198]; one respondent praised Alternative 6 for its 

treatment of wildlife [178].

Response: The Wildlife section of the FEIS addresses potential impacts to a variety of 

wildlife species. General conclusions are: (1) this project does not remove or degrade habitat; 

(2) prohibition of cross-country travel will result in less disturbance to wildlife, and will 

result in beneficial effects for all species analyzed, and (3) implementation of any action 

alternative may effect, but is not likely to adversely affect and will have beneficial effects for 

Threatened or Endangered species (see summary of determinations listed in the Terrestrial 

Wildlife section of Chapter 3 of the FEIS, and Biological Assessment included in the project 

files).

Public comment: One respondent requested that off road vehicles should be used only in areas 

without critical wildlife habitat values [17].

Response: Some of the action alternatives propose designating routes within NSO critical 

habitat. There would be no effects to habitat, and effects would be limited to vehicle noise 

considered to be a continuation of the current situation. The U.S. Fish and Wildlife Service 

has concurred that implementation of this project would have No Effect on designated critical 

habitat for Threatened or Endangered species. The project record includes the Wildlife 

BA/BE on which this determination is based.

Public comment: One respondent representing several organizations stated the KNF should not 

rely on the obviously illegal 2008 NSO critical habitat re-designation [172].

Response: An analysis for NSO using the 1992 habitat layer was conducted between DEIS 

and FEIS in response to this comment. Results are included in the Terrestrial Wildlife section 

of Chapter 3 of the FEIS. 
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Klamath National Forest E-39

Public comment: One respondent representing several organizations stated that Alternative 6 

proposes to designate and encourage motorized use on routes within LSRs and Critical Habitat 

Units (CHUs) (DEIS page 194.) This alternative also authorizes routes within 0.25 mile of two 

NSO activity centers (DEIS page 193). The DEIS discloses that user-created motorized routes are 

currently sparsely used, suggesting that owls near these trails may not be habituated to noise 

disturbance. Alternative 6 would also authorize 4.2 miles of user-created routes within LSRs and 

CHUs, potentially affecting NSO dispersal, foraging, and nesting. The Rogue-Siskiyou National 

Forest concluded on pages II-33 and II-47 of its DEIS that limiting OHV use near spotted owl 

sites would contribute to the avoidance of owl harassment. No such acknowledgement is present 

in the KNF DEIS [172].

Response: Alternative 6 was developed to correct errors and omissions in the original 

proposed action. While it includes routes within NSO critical habitat, the U.S. Fish and 

Wildlife Service has concurred that adoption of any action alternative would constitute a No 

Effect for critical habitat for Threatened and Endangered species.

Public comment: One respondent representing several organizations states that rather than 

analyze, disclose, avoid, or mitigate the impacts of foreseeable noise harassment from proposed 

motorized use on NSO reproductive success and behavior patterns, the DEIS arbitrarily defines 

such noise harassment as ―ambient‖ based on the contention that motorized vehicles have been 

used on these routes for years. DEIS page 182. The commenter points out that page 347 of the 

DEIS reveals that proposed routes ―tend to have very low traffic volumes‖ and page 261 of the 

DEIS informs the reader that ―proposed additions to the NFTS could have increased use...‖ 

[172]. 

Response: Current traffic levels on these routes (and on most roads within the KNF) are low. 

The assumption (used for all resource analyses) that vehicle use on designated routes will not 

measurably increase in the near future is based on demographic and NVUM data displayed in 

the Society, Culture and the Economy and Recreation sections of the FEIS. Most motorized 

recreation use on the KNF is by local residents, and the population of Siskiyou County has 

not grown appreciably in the last decade. The assumption used in the wildlife analysis was 

that use of unauthorized routes by vehicles has established an ambient noise level for local 

wildlife that is low and sporadic in nature.

Pacific fisher

Public comment: One respondent representing several organizations noted that the discussion of 

the Pacific fisher is lacking. The Forest Service has not disclosed the impacts of motorized use 

on this at-risk species [172].
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 E-40 Klamath National Forest

Response: Effects to fisher are discussed in the late-successional species group in the 

Terrestrial Wildlife section of Chapter 3. The wildlife analysis considered fisher habitat to be 

the same as NSO late-successional habitat, and effects to that habitat type are fully disclosed. 

There are no known fisher denning sites identified on the KNF, so there is no way to 

determine the miles of routes within 0.25 mile of such sites.

Public comment: One respondent representing several organizations stated that the USFWS 

warranted but precluded findings contain a detailed review on the conservation status of the 

fisher, including a comprehensive analysis of threats to the continued existence of the species (69 

Fed. Reg. 18770, 18770 (April 8, 2004)). For example, FWS noted that "habitat loss and 

fragmentation appear to be significant threats to the fisher. Forested habitat in the Pacific coast 

region decreased by about 8.5 million acres between 1953 and 1997." Id. at 18780. "Forest cover 

in the Pacific coast is projected to continue to decrease through 2050, with timberland area 

projected to be about 6 percent smaller in 2050 than in 1997." Id. "Thus fisher habitat is projected 

to decline in Washington, Oregon, and California in the foreseeable future." Id. [172].

Response: This project does not propose removal of any habitat, and in fact would promote 

long-term recovery of unauthorized routes in late-successional habitats. Prohibiting crosscountry motorized travel from over 102,000 acres of late successional habitat will eliminate 

the potential for more user-created routes that could fragment, degrade or remove this type of 

habitat.

Public comment: One respondent representing several organizations noted the FWS status 

review discloses that "[v]egetation management activities such as timber harvest and fuels 

reduction treatments . . . can destroy, alter, or fragment forest habitat suitable for fishers." Id. at 

18778. "A number of studies have shown that the fisher avoids areas with little forest cover or 

significant human disturbance and conversely prefers large areas of contiguous interior forest." 

Id. at 18773. "The fisher's need for overhead cover is very well documented. Many researchers 

report that fishers select stands with continuous canopy cover to provide security cover from 

predators." Id. "Fishers probably avoid open areas because in winter open areas have deeper, less 

supportive snow which inhibits travel, and because they are more vulnerable to potential 

predators without forest cover." Id. "Furthermore, preferred prey species may be more abundant 

or vulnerable in areas with higher canopy closure." Id. [172] 

Response: This project does not remove late-successional habitat or affect canopy closure. 

The amount of human disturbance associated with designated routes will not increase in the 

foreseeable future (see discussion in the Society, Culture and Economy and Recreation 

sections). The prohibition on cross-country motorized travel will remove vehicle use from 

102,000 acres of late-successional habitat, and allow over 400 miles of undesignated routes to 
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Klamath National Forest E-41

revegetate. The effects on prey species for fisher and marten are addressed in the 

environmental effects section of the Wildlife analysis in Chapter 3.

Public comment: One respondent representing several organizations noted there is no mention 

made in the DEIS of the impacts of increased noise and human disturbance on the remaining 

fisher habitat. While the DEIS (at page 173) acknowledges many fisher detections over the past 

decade on the west side of the Klamath NF, the DEIS simply assumes that publication of the 

MVUM will not result in additional motorized harassment of the species [172].

Response: The assumption (used for all resource analyses) that vehicle use on designated 

routes will remain at currently low levels and will not measurably increase in the near future 

is based on demographic and NVUM data displayed in the Society, Culture and the Economy 

and Recreation sections of the FEIS. Ambient noise along newly-designated routes will 

continue to be sporadic. Depending on the alternative selected, less than 1% of latesuccessional habitat on the KNF could continue to be affected by vehicle noise. The potential 

for human disturbance on over 102,000 acres of late-successional habitat accessible by 

vehicles will be substantially reduced as this acreage is made unavailable for cross-country 

motorized travel.

Unauthorized routes

Public comment: One respondent suggested that motorized use should be prohibited on all 

unauthorized routes and they should be replanted with native vegetation [17]. 

Response: Prohibition of use of all unauthorized routes was analyzed (Alternative 3). The 

Transportation section of Chapter 3 of the FEIS discusses the plan to allow most unauthorized 

routes that are not designated as part of the NFTS to revegetate naturally. This will keep the 

cost of restoration of routes to a minimum and allow the vegetation that is native to the area 

to grow. As also discussed in that section, and in the Mitigations Applicable to All Action 

Alternatives section of Chapter 2 of the FEIS, some limited physical restoration and 

naturalization treatments may occur at the point of closure for unauthorized routes if needed 

as mitigation for resource or visitor conflict concerns. Natural materials will be used if such 

mitigation actions are undertaken.

Visual Quality

Public comment: One respondent representing several organizations finds the assertion in the 

DEIS that all alternatives meet visual quality objectives (VQOs) is unsupported by documentation 

[172]; another respondent states that roads take away from natural beauty [382].

Response: Visual Quality Objectives (VQOs) for the KNF were established in the LRMP. 

These VQOs define minimum acceptable thresholds for landscape alternations from an 
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 E-42 Klamath National Forest

otherwise natural-appearing forest landscape. The Retention VQO requires that landscapes 

remain natural-appearing; the Partial Retention VQO requires that alterations remain visually 

subordinate. The Modification and Maximum Modification VQOs allow alterations to 

dominate the landscape. The analysis contained in the Visual Quality section of Chapter 3 of 

the FEIS includes the compliance of each alternative with the Retention and Partial Retention 

VQOs. The analysis also includes the use of indicators that examine the effect of each 

alternative on the KNF’s key viewsheds, and miles of unauthorized routes available for 

revegetation or visual recovery.

Water, Watersheds and Hydrology

Public comment: A number of organizations and individuals have concerns about the general 

effects of motorized vehicle use on clean water [FL 2, 17, 74, 172, 198, 205, 366]; others ask for 

protection of watersheds [326, 328, 414] and emphasize the important value of clean water [173].

Response: The Hydrology section of Chapter 3 of the FEIS analyzes and discloses the 

impacts on water quality and watersheds of prohibiting cross-country travel and adding miles 

of unauthorized routes (0 to 92 miles depending on the alternative) to the NFTS. This section 

of the FEIS also discloses how the alternatives would meet the requirements of the Clean 

Water Act (CWA) and objectives of the Aquatic Conservation Strategy (ACS) from the KNF 

LRMP.

Public comment: One respondent representing several organizations stated that the DEIS fails to 

adequately address the cumulative impacts on water resources which result from the incremental 

impact of action alternatives added to the conditions of the watersheds, cumulative impacts of 

foreseeable road projects, individual components of alternatives and cumulative effects of 

individual components taken together. This respondent also questions the adequacy of Appendix 

B as a cumulative effects analysis [172].

Response: The Hydrology section of Chapter 3 of the FEIS has been modified to clarify the 

cumulative effects of action alternatives on water resources. As noted in that section, the 

effects of ongoing and reasonably foreseeable road projects are beneficial for water resources 

on the west side of the KNF due to removal of 50 miles of road from the NFTS (48 miles 

through road decommissioning and 2 miles by converting a road to a non-motorized trail). 

Road additions on the east side of the KNF have little to no effect on water due to soils, 

topography, and interior draining. The current condition of watersheds is discussed in the 

affected environment portion of the Hydrology section of Chapter 3. The additive effects of 

each alternative and ongoing/reasonably foreseeable road-related actions are discussed for 

each alternative under cumulative effects. It has been clarified throughout the document that 

Appendix B is a listing of ongoing and reasonably foreseeable projects, not an analysis of 

cumulative effects.
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Appendix E: Response to Comments

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Klamath National Forest E-43

Public comment: One respondent representing several organizations stated that a quantified 

detailed disclosure of the cumulative impacts from concrete proposals to increase the number of 

system roads in riparian reserves is required by NEPA, and they are concerned that the proposed 

action would designate a significant mileage of unauthorized routes for motorized use in riparian 

reserves [172].

Response: As noted above, the Hydrology section of Chapter 3 of the FEIS has been 

modified to clarify the cumulative effects of action alternatives on water resources. The direct 

and indirect effects of prohibiting cross-country travel, and of adding unauthorized route 

miles in riparian reserves (0 to 23 miles), and in key watersheds (0 to 8 miles), to the NFTS, 

are analyzed and disclosed; the cumulative effects of these actions added to the effects of 

ongoing and reasonably foreseeable road projects are disclosed under cumulative effects of 

each alternative. Resulting route densities are discussed for all alternatives. See also the 

response to the third comment under the adding routes and open riding areas section of this 

appendix.

Public comment: One respondent representing several organizations stated that the Forest 

Service must manage public lands in an ecologically sustainable manner that protects water 

resources, streams, streambanks, and shorelines, and show how it is protecting these resources 

[172].

Response: As discussed in the Hydrology section of Chapter 3 of the FEIS, all of the action 

alternatives represent substantial reductions in road mileage in riparian reserves, and 

reductions in road density in most watersheds where additions to the NFTS are proposed to 

occur. Compliance with law, regulation and policy is also disclosed in the Hydrology section 

of Chapter 3 of the FEIS. See also the response to comments under Soils.

Public comment: One respondent representing several organizations is concerned that proposed 

cumulative impacts in Upper Humbug ―would probably exert a detectable change in hydrologic 

response‖ [172]; an agency requests that the FEIS show that motorized use will not impair water 

in the Humbug area [205].

Response: The direct and indirect effects of adding unauthorized routes to the Upper 

Humbug Creek watershed are analyzed and disclosed for all action alternatives in the 

Hydrology section of Chapter 3 of the FEIS. Direct and indirect effects include a 

(potentially) detectable positive change in hydrologic response; this is because there are 

currently more miles of unauthorized route in the Upper Humbug Creek watershed than in 

any other watershed, and the impact of closing most or all of these routes to vehicles could 

possibly be detectable. In other watersheds, the impact of closing routes is much less and, 

therefore, less likely to be detectable. The Hydrology section of Chapter 3 of the FEIS has 

been modified to clarify the effects of actions on open road density, and possible hydrologic 
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 E-44 Klamath National Forest

impact. In addition, the FEIS includes mitigations to the Humbug drainage that would further 

reduce the effects of added routes on water, detailed in the Soils section of Chapter 3 of the 

FEIS. Also, as stated under cumulative effects of action alternatives in the Hydrology and 

Fisheries sections of Chapter 3 of the FEIS, the long term effects of decreasing road density 

in action alternatives would be beneficial to water and fish.

Public comment: One respondent representing several organizations stated that the DEIS 

acknowledges that motorized use is the predominate cause of sediment production from native 

surface roads but is proposing to add 24 miles of unauthorized routes to the NFTS in 

hydrologically sensitive areas and wonders how this contributes to attainment of ACS objectives 

[172].

Response: Once routes have been created, motorized use (motorized traffic volume) is the 

predominant cause (more than hikers, horses or bicycles) of soil displacement, and of 

sediment production if the routes have hydrological connectivity to streams or other bodies of 

water. The amount of sediment created by addition of native surfaced routes to the NFTS 

depends on a number of factors such as the amount of motorized use, terrain, soils, slope and 

drainage patterns as well as connectivity to water. The Hydrology section of Chapter 3 of the 

FEIS includes information about the number of routes that would be added to the NFTS in 

riparian reserves in each action alternative, the number that would be closed to motorized use 

(81% to 100% depending on the alternative), and the resulting road density. The 

determination of how the action alternatives contribute to the attainment of the ACS 

objectives of restoring water quality is also disclosed in the modified Hydrology section of 

Chapter 3 of the FEIS.

Public comment: One respondent representing several organizations is concerned that the DEIS 

generally limits analysis to the impacts of route establishment as opposed to the foreseeable 

impacts of increased motorized use on additional routes in riparian reserves, and states that this is 

particularly important for those routes proposed in watersheds that already exceed their Threshold 

of Concern (TOC) [172].

Response: As displayed in the Hydrology section of Chapter 3 of the FEIS, none of the 

analyzed watersheds in which more than 1 mile of unauthorized routes are proposed to be 

added to the NFTS currently exceed the TOC, and the action alternatives all represent 

substantial reductions of miles of open route in riparian reserves. The modified Hydrology 

section emphasizes that almost all ongoing and reasonably foreseeable road actions on the 

west side of the KNF remove miles of road from the NFTS, which will positively affect water 

quality in the long term. The disclosure of cumulative effects of alternatives has been 

modified to clarify the added effects of the ongoing and reasonably foreseeable road actions 

to the effects of the travel management project. As noted earlier in this section, there is no 
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

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Klamath National Forest E-45

information available that indicates increased motorized use of the KNF will occur in riparian 

reserves.

Public comment: One respondent representing several organizations noted that the Klamath 

River is 303(D) listed for temperature and nutrients and proposed for sediment listing, and the 

Salmon River is also listed for both temperature and sediment. The commenter asks how 

increasing the number of system roads in hydrologically sensitive areas and riparian reserves will 

meet the agency’s obligations delineated in the Basin Plan and meet CWA requirements for rivers 

that are 303(D) listed for sediment [172].

Response: The Hydrology section of Chapter 3 of the FEIS includes information about the 

watersheds in which unauthorized routes are proposed for addition to the NFTS that could 

influence the Klamath and Salmon Rivers. As stated in that section of the FEIS, designating 

some routes and leaving the others to revegetate over time will reduce open route density in 

all watersheds considered. The number and density of routes in riparian reserves will also 

decrease, helping meet Clean Water Act requirements to mitigate non-point source pollution 

to meet requirements of the Basin Plan. Prohibiting cross-country travel will eliminate the 

potential for creation of new routes in these areas.

Public comment: One respondent representing several organizations noted that the DEIS 

indicates that only a small proportion of unauthorized routes were field reviewed, and contends 

the public and decision-maker cannot rely on the numbers presented in the Hydrology section of 

Chapter 3 [172].

Response: An error was made in the Hydrology section of the DEIS regarding field review 

information; this error has been corrected in the FEIS. Field review of unauthorized routes 

has occurred throughout the travel management process. As noted in the alternative 

development section of Chapter 2 of the FEIS, the KNF Interdisciplinary Team (IDT) 

members performed the initial screening of unauthorized routes to rule out those with serious 

resource concerns and those that did not meet the purpose and need of the project. A proposed 

action was formulated after the initial screening with field review occurring simultaneously. 

At the end of these reviews, more than 3⁄4 of the unauthorized routes had been dropped from 

consideration. Additional field review (including review of approximately 30 miles of 

unauthorized routes, most in the Humbug drainage) occurred after the Notice of Intent was 

published in 2005; results of this additional review, along with public comment on the NOI, 

led to the development of action alternatives to the proposed action. Additional GIS analysis 

and further field review occurred between DEIS and FEIS; this field review, in addition to 

public comments on the DEIS, led to development of another action alternative (Alternative 

7).
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

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 E-46 Klamath National Forest

Public comment: An agency requests that the KNF consult with the North Coast Regional Water 

Quality Board (NCWQCB) on this project and add more Best Management Practices (BMPs) and 

mitigation [205].

Response: The KNF has been in discussions with the NCWQCB on various proposed roadrelated activities and has agreed to in-stream monitoring of activities as discussed in the 

Hydrology section of Chapter 3 of the FEIS. Proposed mitigations to reduce the potential 

effects of motorized use are displayed in Chapter 2 of the FEIS, in the Soils and Recreation 

sections of Chapter 3 of the FEIS, and in the project record located in the KNF Supervisor’s 

Office in Yreka, CA. The project record includes the BMPs included in the Regional Water 

Quality Management Plan, as discussed in the Hydrology section of Chapter 3 of the FEIS.

Wild and Scenic Rivers

Public comment: One respondent stated that no OHVs should be allowed near Wild and Scenic 

Rivers [17]; another group expressed concern about unauthorized routes being proposed for 

addition to the NFTS in or adjacent to Wild and Scenic River Corridors [172].

Response: As discussed in the Recreation section of Chapter 3 of the FEIS, there are rivers 

on the KNF that are formally included within the National Wild and Scenic River (WSR) 

system as ―Wild,‖ ―Scenic,‖ or ―Recreational.‖ None of the routes considered for addition to 

the NFTS are within the river corridors designated as Wild or Scenic. Some routes are 

proposed for addition with Recreational corridors; this action would be consistent with 

direction in the KNF LRMP as long as beneficial uses are maintained. The Hydrology and 

Fisheries sections of Chapter 3 of the FEIS discuss maintenance of beneficial uses and 

conclude that addition of routes meets requirements of the Aquatic Conservation Strategy and 

the Clean Water Act. The Visual Quality section determined that all action alternatives meet 

Forest visual quality standards. 

Wilderness Areas

Public comment: Several respondents stated that no OHVs should be allowed close to 

wilderness [199, 200]; one respondent suggested that no OHV use should occur within 2 miles of 

a wilderness boundary [17].

Response: Motorized vehicle use is prohibited in Wilderness. As part of the Mitigations 

Applicable to All Action Alternatives section of Chapter 2 of the FEIS, wilderness boundaries 

will be clearly signed when any motorized route approaches within 1⁄4 mile so that motorized 

vehicle users will know they are approaching a Wilderness. This will help reduce inadvertent 

incursions into Wilderness areas. The Recreation analysis in Chapter 3 of the FEIS includes 

an indicator to compare the effects of proposed additions to the NFTS on wilderness. This 

indicator (miles of route within 1⁄2 mile of a wilderness boundary) was developed using 
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Klamath National Forest E-47

information from scientific studies and reports listed in the references section of Chapter 4 of 

the FEIS. There is no agency direction to surround wilderness with buffers or to limit 

activities such as motorized use areas outside the wilderness boundaries.

List of Respondents to the DEIS

Name Address City Sta Zip

Robert Jump 33 Coleman Dr. San Rafael CA 94901

Mac Sutherlin 430 ashland st Ashland OR 97520

Karen Horn 536 Tulipan Way #A Talent OR 97540

Lydia Garvey 429 S. 24th St. Clinton OK 73601

Chad Derosier 3232 SE 8th Ave Portland OR 97202

Mick Bress General Delivery Gold Beach OR 97444

Dee Decker 2922 Grizzly Dr. Ashland OR 97520

Art & Carol Buck 116 Church Street Ashland OR 97520

jean-Guy Martin Applegate OR 97530

Liisa Wale 115 Lincoln St. #2 Ashland OR 97520

Selene Veltri Veltri 495 Carol St. Ashland OR 97520

George Lescher 347 High St. Ashland OR 97520

Maura Hayes 435 Holly Street #15 Ashland OR 97520

Beth & Jon Carlson Levin

Barbara Hughey 4599 Thompson Cr.Rd. Applegate OR 97530

Tommy Garland 5414 Via Lane Crozet VA 22932

George & Frances Alderson 112 Hilton Ave. Baltimore MD 21228

Stuart O'neill 441 beach street Ashland OR 97520

Cate Schoenharl 415 E. Nerton St. Talent OR 97540

Sylvia Milligan, Chr. ROC 4000 Beacon Drive Anderson CA 96007

Leslie Cox Gold Hill OR 97525

Heidi & Dudley Finch Haehlen P.O.Box 1444 Jacksonville OR 97530

Marcia McDuffie CA

Edith Montgomery 156 Blue Heron Lane Ashland OR 97520

Debbi Catalina 19765 williams hwy Williams OR 97544

Fred Lifton 4314 NE Grand Ave. Portland OR 97211

Gayla Barrows 2020 Martin Dr. Medford OR 97501

Ayani mikasi 408 creel Talent OR 97540

Barrett Edgar PO Box 210 Wedderburn OR 97491

Tim Ream

Carla Hervert 2948 Dry Creek Rd. Eugene OR 97404

Malena Marvin 220 W. Hersey St. Ashland OR 97520

Arnica Wertheimer

Nathan Pundt 2014 Rose St Berkeley CA 94608

Scott Harding PO Box 202 Ashland OR 97520

Ara Johnson 133 Nutley St. Ashland OR 97520

Giancarlo Panagia 6430 Ferrari Place Indianappolis IN 46224

Janice Brotman 281 E. Main St. Apt.3 Ashland OR 97520

Heidi Wolfe 12695 Hwy 238 Applegate OR 97520

Pat Brotman 16 Snowden Rd. bala Cynwyd PA 19004
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

_______________________________________________________________________

 E-48 Klamath National Forest

Carolyn Self 932 Harmony Ln Ashland OR 97520

Ted Kennel 395 Richmond Dr.Apt.12 Millbrae CA 94030

Duane Martinez 430 ashland st Ashland OR 97520

Toni Siegrist 17 Quincy Street Cambridge MA 02138

DonnaJo Woollen 401 Mill St. Mt. Shasta CA 96067

Bob Musgrove, Sierra Club 507 Meadow Ave. Mt. Shasta CA 96067

Robert Cameron CA 96064

Laura Rost 3386 SE Waverleigh Bl.#5 Portland OR 97202

Philip Mancus 1795 Moss Street Eugene OR 97403

Geraldine Bish 8651 Wagner Cr. Rd. Talent OR 97540

Tim Lillebo 16 NW Kansas Ave Bend OR 97701

Michele Cornelius P.O.Box 1131 Happy Camp CA 96039

Denise Lytle 73 Poplar St. Fords NJ 08863

Richard Spotts 1125 W. Emerald Drive St. George UT 84770

Lester & Judy Hoyle

M.L. Moore Moore 419 Liberty St. Ashland OR 97529

Aubree Johnson 425 Liberty Street Ashland OR 97520

David Midrexler PO Box 715 Joseph OR 97846

Bill Mullen 39 Wendy Road Trumbull CT 06611

Karen Phillips 1150 1/2 SW Lee Lane Grants Pass OR 97526

Paul Howard 2777 SW Wake Robin Pl. Corvallis OR 97333

Margery Winter 634 Iowa St. Ashland OR 97520

Alan Bowes 4624 S Pacific Hwy #1 Phoenix OR 97535

Duane Bowman 2131 Little Applegate Rd. Jacksonville OR 97530

Kathleen Stasny 133 Orange Ave. Ashland OR 97520

John Weatherman 202W 1st st Los Angeles CA 90012

Cathy Robinson 774 Willow Springs Dr. Mobile AL 36695

Erich Reeder 41 Eastwood Dr. Medford OR 97504

Sally Buttshaw 300 Luman Rd. Space 173 Phoenix OR 97535

Susan Deles 2801 sykes creek rd Rogue River OR 97537

Jim Lockhart 5630 S.E. 65th Ave. Portland OR 97206

Grant Low 2110 Highland Dr. Prosser WA 99350

Dakota Otto Otto 1012 Bellview Ave. Ashland OR 97520

Christopher Lish PO Box 113 Olema CA 94950

Robert L. Delsman 850 Hillview Dr. Ashland OR 97520

Carol J. Delsman 850 Hillview Dr. Ashland OR 97520

Courtlandt Jennings 523 drager st Ashland OR 97520

Tom Bouton 319 n. 17th st Boise ID 83702

Bill Riggs 1711 Lighthouse Ln Reno NV 89511

Robin Strangfeld 900 Hillview Dr Ashland OR 97520

D. W.Levin 899 Hillview Dr Ashland OR 97520

Ashley N. McAllister 268 E. Lake St, Apt. #286 Weed CA 96094

Dorothea Joyce 404 N.Mt.Shasta Bvd.#131 Mt. Shasta CA 96067

Patrice Thiessen 212 E. Lake Mt. Shasta CA 96067

Neil Sechan 101 Scenic Drive Ashland OR 97520

Therese Ferrer PO Box 238 Hornbrook CA 96044

Elaine Frodsham 98378 E. Cougar Ln Gold Beach OR 98003

Kimberlty K M Intosh 591 Gilman Ave Weed CA 96094

Leslie Ellorin 502 McCloud Ave Mt. Shasta CA 96067

James A Curran 917 McCloud Ave Mt. Shasta CA 96067
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

_______________________________________________________________________ 

Klamath National Forest E-49

Nancy Pereira 908 MtCloud Ave Mt. Shasta CA 96067

Paula Fischer 1700 San Hill Rd. #306 Palo Alto CA 94304

Robert W. Hirschboeck 71 Scenic Drive Ashland OR 97520

Alan Galka 135 Scenic Dr Ashland OR 97520

Matthew Messner 101 Scenic Drive Ashland OR 97520

Ronald W. Little 180 Logan Dr. Ashland OR 97520

Claudia K. Little 180 Logan Dr. Ashland OR 97520

Karen Lovely 343 B St. Ashland OR 97520

Lori Haynes 343 B St. Ashland OR 97520

Sharon Davenport 694 Glendale Ave. Ashland OR 97520

Darlene Beckett 260 4th St Ashland OR 97520

Hilary Tate 133 Gresham Apt A Ashland OR 97520

Selena Garefino 209 Gresham Ashland OR 97520

Helga Motley 231 Gresham St. Ashland OR 97520

Jim Schlight 41 Gresham St. Ashland OR 97520

Roxanne Ral P.O. Box 1150 Ashland OR 97520

Susan E. Springer 19 Gresham St Ashland OR 97520

Caroline Downie 306 Riverwood Lane Dunsmuir CA 96025

Sushila Mertens 13002 Golden Eagle Way Nevada City CA 95959

Tyler Hawkins 200 High St. Mt. Shasta CA 96067

Michael Sitranstire 2515 Springhill Drive Ashland OR 97520

Carol Clearubans 4213 Cesbue Av Weed CA 96094

Carol Marlak P.O.B. 507 Mt. Shasta CA 96067

Jim Crosby 404 N. Mt.Shasta Bv.#318 Mt. Shasta CA 96067

Lynn Shilwater 153 Granite #D Ashland OR 97520

Cat Syrbe 112 N. B St Mt. Shasta CA 96067

Bret Speers P.O.Box 994488 Redding CA 96099

Beth Rudolf P.O.Box 938 Mt. Shasta CA 96067

Wendy Crist 5914 Mountain Ave. Dunsmuir CA 96025

Clint Jackson 2034 N. Old Stage Rd Mt. Shasta CA 96067

Juan G. Diaz 562 A St. Ashland OR 97520

Todd Trigsted 7360 Adams Road Talent OR 97540

Allen Sayble 821 Hillview Dr. Ashland OR 97520

Adrienne Fansler & Daniel Cazares 720 Holly St Ashland OR 97520

Marie Kimokeo Goes 120 Ridge Rd Ashland OR 97520

Lynda Sirianni 558 Holly St. Ashland OR 97520

Jime Matoush 457 Holly St. Ashland OR 97520

Rene' Lafaurice 821 Hillview Dr. Ashland OR 97520

Donald N. Morris 1644 Ross Lane Ashland OR 97520

Gary Powell 562 A St. Ashland OR 97520

Nichelle Sher 16368 Del Mar Way Penn Valley CA 98246

Cecilia Gates 1020 Kingston Rd SW Mt. Shasta CA 96067

Mario Puppo 155 6th St. Gustine CA 95322

Robert Houghton 710 Pine St #28 Mt. Shasta CA 96067

Jeff Stiles 1231 Beks Ln Mt. Shasta CA 96067

Mark Mizrahi 9854 Babbitt Ave Northridge CA 91325

Barbara Riviere 1928 Hopkins St. Berkeley CA 94707

Denise Young 406 Old McCloud Rd Mt. Shasta CA 96067

Emily Conlin 699 Rideour Rd. Gahanna OH 43230

Joel Schlopski 6605 Linville Dr Weed CA 96094
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

_______________________________________________________________________

 E-50 Klamath National Forest

Bruce McKinley P.O.Box 1298 Mt. Shasta CA 96067

Karen Carty 417 Adams Dr. Mt. Shasta CA 96067

Jan Tucker 925 El Rancho Rd. Santa Barbara CA 93108

Corinna Jerue 305 E. Lake #1 Weed CA 96094

Nick Hogue P.O.Box 1746 Hanalei HI 96714

Myr Skipper 712 Ski Vill. Dr. Mt. Shasta CA 96067

Jill Gardner P.O.Box 473 Mt. Shasta CA 96067

Laurie Ottens 317 W. Alma St. Mt. Shasta CA 96067

[name illegible] [no address]

Thomas S. Patterson 63 Gresham St. Ashland OR 97520

Dorrie Couts 175 Piedmont Ashland OR 97520

Stacie Hardy 305 Terry Lynn Ave. Mt. Shasta CA 96067

Jim Gannon Corning CA 96021

[name illegible] 1019 S. Ream Ave Mt. Shasta CA 96067

[name illegible] 200 S. A St. Mt. Shasta CA 96067

Diane M. Scott 316 Smith St. Mt. Shasta CA 96067

Chris Jones 210 1/2 Lake St

Thomas M. Brown 608 Alder St. Mt. Shasta CA 96067

Simon van Asch Netherlands EU

[name illegible] 1198 Lyons St. Redwood City CA

Stephanie Pollard 467 Holly St. Ashland OR 97520

Richard Alito 940 Hillview Dr. Ashland OR 97520

Leslie Selkmer 312 Old McCloud Mt. Shasta CA 96067

[name illegible] 704 S. Washington Dr. Mt. Shasta CA 96067

Rubin Hog 380-A Paseo Madeira Green Valley AZ 85614

Louise Patice [no address]

Serge Margot [no address]

[name illegible] 108 S. B St. Mt. Shasta CA 96067

[name illegible] 506 Eiler

Paula Sartrami [no address]

75 Hawthorne St.

George Sexton (KS Wild & others) P.O.Box 102 Ashland OR 97520

Francis Mangels 736 Pine Ridge Ave. Mt. Shasta CA 96067

Patricia Sanderson Port (DOI-OEPC) 1111Jackson St., Ste. 520 Oakland CA 94607

Tom Harasin 973 Oak St. Ashland OR 97520

Rex Wilson 19218 Pinnacle Ct Redding CA 96003

John Anderson 3715 Scala Lane Montague CA 96064

John Stevens Visalia CA

John Fields(CA Rifle & Pistol Assn) 271 Imperial Hwy. Ste.620 Fullerton CA 92835

Tom Roland 439 Lit Way Ashland OR 97520

R. Dandlute[name illegible] 924 Park St Ashland OR 97520

Mia Morrish 913 Park Ashland OR 97520

Ken Morrish 913 Park St Ashland OR 97520

Mari Black 273 Normal Ashland OR 97520

Joan Ballenger 911 Harmony Ln Ashland OR 97520

Lisa Pavati 961 Harmony Ln Ashland OR 97520

Marc Vinicky 903 Harmony Ln Ashland OR 97520

Paul Giancarlo 916 Garden Way Ashland OR 97520

Richard Seidman 924 Garden Way Ashland OR 97520

Blair Johnson 870 Harmony Lane Ashland OR 97520
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

_______________________________________________________________________ 

Klamath National Forest E-51

Russell White 422 Ray Ln. Ashland OR 97520

Michael Barnard 445 Normal Ave. Ashland OR 97520

Jennifer G. Watt 635 Fordyce St. Ashland OR 97520

Rebekah Davis 495 Ray Ln. Ashland OR 97520

Paul James Martin 490 Ray Lane Ashland OR 97520

Pat Smith 635 Fordyce St. Ashland OR 97520

Susan N. Silva 1774 Homes Ave. Ashland OR 97520

Kay Kendall 1025 wildwood way Ashland OR 97520

Michael Stapleton P.O.Box 6418 Eureka CA 95502

Gail Lyons, Pres. Back Cnty Horsemen P.O.Box 461 Etna CA 96027

Ron Hipkiss 5008 Alan Court Carmichael CA 95608

Stan Van Velsor, ORV Coord, TWS 655 Montgomery,Ste.1000 San Francisco CA 94111

Jim Lipke, SCORR President P.O. Box 1925 Yreka CA 96097

Jan Lytjen 1025 Park Street Ashland OR 97520

Kathleen Goforth, Mgr, Env.Review, 

EPA 75 Hawthorne Street San Francisco CA 94105

Lily G. Stephen P.O. Box 1211 Mt. Shasta CA 96067

Ruth Nelson-Moore 200 High Street Mt. Shasta CA 96067

Perry Sims 309 Ackley Ave. Mt. Shasta CA 96067

John Velti P.O. Box 785 Mt. Shasta CA 96067

Dawn Fazende 300 E. Lake Mt. Shasta CA 96067

Jack Talbott P. O. #17 McCloud CA

Joel Goopman P.O. Box 890 Mt. Shasta CA 96067

Johnny Peil P. O. Box 195 Dunsmuir CA 96025

Anne Holding 9534 Swigart Rd. Montague CA 96064

Laurel Gerber P.O. Box 1712 Mt. Shasta CA 96064

A Johnson 6905 Linville Drive Weed CA 96094

Doug Tedsen 511 Lennon St. Mt. Shasta CA 96067

Robert Kirth P.O. Box 41 Mt. Shasta CA 96067

Kelly Jones 272 Senate Drive Pacheco CA

Kathryn S. Ariel 2650 Amy Ct. Mt. Shasta CA 96067

S Hase 870 Shasta Circle El Dorado Hills CA 95762

J Rodaughn 1203 Nixon Rd Mt. Shasta CA 96067

Polly Elliott 2920 Hwy 99 South Ashland OR 97520

Dina Ederer 1310 Ramona Dr. Mt. Shasta CA 96067

Delia L. Ann 607 A. Pine St. Mt. Shasta CA 96067

Jona Peters P.O. Box 165 Tahoe Vista CA 96148

Al Noon 12086 E. Fork Rd French Gulch CA 96003

[name illegible] [no address]

Katharine Scovik 5808 Deer Creek Mt. Shasta CA 96067

Grace Cohen 4 Hillcrest Ashland OR 97520

Jonathan Wickes P.O. Box 465 Williams OR 97544

Bayla Greenspoon 300 Terry Lynn Ave. Mt. Shasta CA 96067

Ken Jimenez 1025 Mott Airport Rd. Mt. Shasta CA 96067

Alexandra Saadi 418 S. Mt. Shasta Blvd. Mt. Shasta CA 96067

Bryan Jamieson 418 A S. Mt. Shasta Blvd. Mt. Shasta CA 96067

Larry Zanetti 708 Mill St. Mt. Shasta CA 96067

David Bell 709 S. Mt. Shasta Blvd. Mt. Shasta CA 96067

Sarabecca Barnett 1915 Audubon Rd. Mt. Shasta CA 96067

Eric Bragg 514 Mill St. Mt. Shasta CA 96067

Jennifer Wills-Christian 502 Berry St. Mt. Shasta CA 96067
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

_______________________________________________________________________

 E-52 Klamath National Forest

Noel Wolfe 505 Berry St. Mt. Shasta CA 96067

Jasper Alt 210 Sisson St. Mt. Shasta CA 96067

Herb McLane [no address] Mt. Shasta CA 96067

Jason Parett 610 Brush St. Mt. Shasta CA 96067

Stefanie Goebel 412 Alder St. Mt. Shasta CA 96067

Kristin Mazzei 288 Harrison St. Ashland OR 97520

Marguerite Forni P.O. 785 Mt. Shasta CA 96067

Wayne G. Kingsbury 324 Pony Trail Drive Mt. Shasta CA 96067

Jule Schult 16021 Arrowhead Pl. Weed CA 96094

Jan diStefano 508 Meadow Ave. Mt. Shasta CA 96067

Barbara Clark 9431 Rocky Rd. Weed CA 96094

Poga Anders 6034 Deer Creek Rd. Mt. Shasta CA 96067

J Purtle 909 McCloud Mt. Shasta CA 96067

Kimberley E. Harper 301 Perry St. Mt. Shasta CA 96067

Robert Carr 1821 Eddy Dr. Mt. Shasta CA 96067

Holly Christiansen 334 Bridge St. Ashland OR 97520

Alexander Mitchell & family 1312 Pine Grove Dr. Mt. Shasta CA 96067

Carol White 19358 Maple Ave. Weed CA 96094

Shawn Raley 623 Caroline Ave. Mt. Shasta CA 96067

Zach R. Shriver 623 Caroline Ave. Mt. Shasta CA 96067

Anna Klimaszewski 425 Oakway Rd. Mt. Shasta CA 96067

Lisa C. Watson 709 S. Mt. Shasta Blvd. Mt. Shasta CA 96067

Eugene Woody 5327 Lake Shastina Drive Weed CA 96094

JoAnna Woody 5327 Lake Shastina Drive Weed CA 96094

Gabe Groom 812 Holiday Court Mt. Shasta CA 96067

Robin Clayton 558 Everitt Memorial Hwy. Mt. Shasta CA 96067

Richard Linn 510 Sara Bell Mt. Shasta CA 96067

Allison Roach 515 Hercules Dr. Mt. Shasta CA 96067

Catherine M. Preus 610 Hercules Mt. Shasta CA 96067

Jena Sinclair 515 Hercules Dr. Mt. Shasta CA 96067

Kate Yorke P.O. Box 1383 Mt. Shasta CA 96067

Ruthmari Rumell 508 Everitt Memorial Hwy. Mt. Shasta CA 96067

John Thelender 510 Lennon Mt. Shasta CA 96067

Jennifer Payton P.O. Box 632 Mt. Shasta CA 96067

Nadine Aeth 115 North A St. Mt. Shasta CA 96067

Emily Nesbitt 303 McCloud Ave. Mt. Shasta CA 96067

Brian Santos 307 McCloud Ave. Mt. Shasta CA 96067

Jan Cole 1605 Sunset Ashland OR 97520

January Lenning 882 Garden Way Ashland OR 97520

Dr. Vicki T. Purslow 780 Oakway Cir. Ashland OR 97520

Kyra Damashert 221 Liberty St. Ashland OR 97520

P. All 562 Louis St. Talent OR 97540

M. Pamela Nelson 1286 Woodland Dr. Ashland OR 97520

Ramona Gorman P.O. Box 3087 Ashland OR 97520

Gerald Cavanaugh 560 Oak St. Ashland OR 97520

Dona J. Meade-Beauregard 369 W. Verde St. Ashland OR 97520

Laura Seefairchild 776 Oak St. Ashland OR 97520

Annette Lennerz 717 Oak St. Ashland OR 97520

John Fisher-Smith 245 Oak St. Ashland OR 97520

Sandra Ward 700 Oak St. Ashland OR 97520
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

_______________________________________________________________________ 

Klamath National Forest E-53

Matt Dopp 1655 Parker St. Ashland OR 97520

A. Bonney 750 Park St. Ashland OR 97520

John Gorman P.O. Box 3087 Ashland OR 97520

Ken Brown 595 Lit Way Ashland OR 97520

Kelly Weislteipl 595 Ray Ln. Ashland OR 97520

John Baxter 595 Ray Lane Ashland OR 97520

Tom Harasin 973 Oak St. Ashland OR 97520

David Campanelli 131 Oak Meadows Pl. Ashland OR 97520

David B. Faudoin 835 Oak St. Ashland OR 97520

Ash McFadden 895 Oak St. Ashland OR 97520

Joseph Kauth 1 Corral Ln. #13 Ashland OR 97520

Pamala Joy 472 Walker Ave. Ashland OR 97520

Rikki Ruth 467 Walker Ave Ashland OR 97520

Diana McFarland P.O. 981 Ashland OR 97520

Cody Callavan 1628 Parker St. Ashland OR 97520

Daniel Hamnett 935 Harmony Ln. Ashland OR 97520

Bruce Comstock 858 Blackberry Ln. Ashland OR 97520

Pam Greenblatt 501 Allison St. Ashland OR 97520

Suzanne Steele 2959 Diane St. Ashland OR 97520

Chris Hjerrilo 2958 Diane St. Ashland OR 97520

Karen McCLintock 2790 Diane St. Ashland OR 97520

M Miclulsees 2810 Diane Ashland OR 97520

Daniel Greenblatt 49 N. Main St. Ashland OR 97520

Barbara Broziic 865 Blackberry Ln. Ashland OR 97520

Roger Armstrong 866 Blackberry Ln. #10 Ashland OR 97520

Dana Carter 866 Blackberry Ln. #10 Ashland OR 97520

Nathale Prettyman 193 Oak Meadow Pl. Ashland OR 97520

Dean Day 915 Oak St. Ashland OR 97520

Patrice Thatcher-Stephens 640 Oak St. Ashland OR 97520

Dee W. Sanders, Trinity Lumber

Richard Saretsky 20720 E. Walnut Cyn. Rd. Walnut CA 91789

Tom Hazelleaf 4656 Fir Ave. Seal Beach CA 90740

Deborah Filipelli, Ph.D. P.O. Box 341 the sea ranch CA 95497

Sandra Money 3461 Laguna Ave oakland CA 94602

Thomas Brustman 2013 Devita Ct Walnut Creek CA 94595

Lee St. John 21900 Barton Rd #170 Grand Terrace CA 92313

Terelle Terry 1701 "O" Street, Apt.101 Sacramento CA 95811

Nancy & Ken Macy 15485 Bear Creek Road Boulder Creek CA 95006

F. Hammer 1490 Chestnut St San Francisco CA 94123

Jeris Turner 3273 Nyeland Ave. #F Oxnard CA 93036

Michael Terry 503 West Rustic Road Santa Monica CA 90402

George Ball 4818 w 9th st. inglewood CA 90301

Richard Schuh 1346 Legs Ln Sonoma CA 95476

Pamela Osgood 349 Church St. San Francisco CA 94114

Daniel Richards 216 Agnus Drive Ventura CA 93003

Yuko Nakajima 63 Oakvale Ave. Berkeley CA 94705

M. A. McDonald 2653 2nd Ave #3 Sacramento CA 95818

Linda Tiffany Stuart St. Berkeley CA 94705

Eugene Craig 5267 Camden Ave #152 San Jose CA 95124

Mark Feldman 137 Winchester Dr Santa Rosa CA 95401
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

_______________________________________________________________________

 E-54 Klamath National Forest

Sandra Christopher 1425 N. Kenwood St. Burbank CA 91505

Phyllis Elliott 608 San Vicente Blvd. Santa Monica CA 90402

Greg Corning 76 Bernal Heights Blvd. San Francisco CA 94110

William & Hiroko Mattsson 131 Giorno Ave. Ukiah CA 95482

Kathleen Seeley 57588 Mesa Drive Yucca Valley CA 92284

Carmen Rodriguez 4159 Dyer Street Union City CA 94587

Evelyn Cummings 8429 Macawa Ave San Diego CA 92123

Patricia Wilson P.O. Box 7516 Spreckels CA 93962

Chris MacKrell 5642 Walnut Ave Long Beach CA 90805

Mary Markus 10462 Ramona Way Garden Grove CA 92840

Susan Trivisonno 2810 Oak Estates Ct. San Jose CA 95135

Gary Falxa 1615 Swanson Ln Eureka CA 95503

Randall Tyers 63 Oakvale Ave. Berkeley CA 94705

Brigida Williams 290 Van Buren Sat. #B23 Monterey CA 93940

David Harris 1678 Buena Vista St Ventura CA 93001

Siddharth Mehrotra 3230 Orange Drive Camarillo CA 93010

Kristin Hurley 13243 Aubrey St. Poway CA 92064

Kathleen Watson 8190 Grape Ave Forestville CA 95436

Mimi Routh P. O. Box 1687 Mt. Shasta CA 96067

Carolyn Dennison 12622 Haster Street Garden Grove CA 92840

Dwight Johnson 62 Estates Dr. Orinda CA 94563

Michael Molamphy 1746 Grand Canal Bl. 15 Stockton CA 95207

Nancy Piotrowski 3450 Geary Blvd. Ste.#107 San Francisco CA 94118

Deniz Bolbol PO Box 5656 Redwood City CA 94063

Lisa Shinn 14270 Morningside Atascadero CA 93422

Harriet Hill 1444 McFarlan Street Eureka CA 95501

Freda Hofland 27070 Sherlock Road Los Altos Hills CA 94022

McLane Downing 2150 Pacific Beach Dr.#232 san Diego CA 92109

Dan & Mary Agnes Hardie 1749 Ducker Court Concord CA 94519

Mark Bartleman 1984 Del Mar Ave Laguna Beach CA 92651

Phillip Cripps 35898 Calle Raphael Cathedral City CA 92234

R.H. Kroell 66 S. Ventura Ave. #207 Ventura CA 93001

Iginio Fontana PO Box 542 Saint Helena CA 94574

Betty Lewis 1955 W. Bayshore Dr. Anaheim CA 92801

Aileen Carissimi 200 Prospect Ave. Los Gatos CA 95030

Melissa Bryan 2200 Village Court #32 Belmont CA 94002

Russell Ridge P.O. Box 396 Point Reyes Station CA 94956

Dana Thompson 23060 Evergreen Lane Los Gatos CA 95033

Robyn Cooper 4745 Nova Drive Santa Cruz CA 96062

Thomas Aldridge 296 s 13 st san jose CA 95112

Gloria Aluzas 682 Black Hills Dr. Claremont CA 91711

Noah Schlager 116 barn road tiburon CA 94920

Ellen Franzen 970 Jones Street Berkeley CA 94710

Luci Evanston 752 Glenview Dr #209 San Bruno CA 94066

Carolyn Barkow 7844 Whelan Dr San Diego CA 92119

Martin Schulz 2703 Adrian St. San Diego CA 92110

Sarah Dixon PO Box 6235 Malibu CA 90264

P. Daniels 288 shirley blvd. arcata CA 95521

A Bonvouloir PO Box 70185 Sunnyvale CA 94086

Dorine Kramer 3373 Patricia Ave Los Angeles CA 90064
Motorized Travel Management Final Environmental Impact Statement

Appendix E: Response to Comments

_______________________________________________________________________ 

Klamath National Forest E-55

Donald Wallace 1719 Cold Canyon Road Calabasas CA 91302

Michael Heister 6320 Carpenter Ave North Hollywood CA 91606

Rita Williams 2275 Hidalgo Ave Los Angeles CA 90039

Dorian Sarris 2167 Turk San Francisco CA 94115

Larry Dennis 35170 Garcia Street Union City CA 94587

Richard Dimatteo 236 Kalmia #107 San Diego CA 92101

Dona van Bloemen 1117 3rd Street Apt. 5 Santa Monica CA 90403

Doug Thompson PO Box 800 Morongo Valley CA 92256

Dan Hitt p.o. box 542 palo alto CA 94302

Eric Simpson 828 Ocean Crest Rd. Cardiff-by-the-Sea CA 92007

Marcy Anzardo 14515 Leffingwell Rd. #41 Whittier CA 90604

Jack Fris 5113 La Calandria Way Los Angeles CA 90032

Richard McCombs P.O. Box 9 Big Bear City CA 92314

Olivia Benavidez 206 clearview place Felton CA 95018

Howard Cohen 3272 Cowper Street Palo Alto CA 94306

Robert Ewing 2272 William Ct. McKinleyville CA 95519

Matthew Emmer 4143 Via Marina Marina del Rey CA 90292

Jeanne Michaels 3068 C Via Serena North Laguna Woods CA 92637

Matthew Reid 1311 Pine St Calistoga CA 94515

Patricia McQuade 426 Vivienne Dr Watsonville CA 95076

Chris Ashton 9357 Lake Murray Bl. Unit B San Diego CA 92119

Jonathan Dirrenberger 403 Fair Oaks Apt 1 San Francisco CA 94110

Kathleen Lawton 847 W. Spain St. Sonoma CA 95476

Julie Payne 11681 Valleycrest Rd. Studio City CA 91604

Teresa Nemeth 1189 Harrison St. Santa Clara CA 95050

A W Jaymes 316 Goldfinch Way Livermore CA 94551

Ric Constales, NR, Siskiyou County P.O. Box 750 Yreka CA 96097

Form Letter-TWS 655 Montgomery,Ste.1000 San Francisco CA 94111