Undeveloped Areas Final

October 12, 2006

Kathy Paulin, Acting Forest Planner

Ashley National Forest

355 North Vernal Avenue

Vernal, Utah 84078

Re: September 2006 Evaluation of Undeveloped Areas for Potential Wilderness –

Final Information Packet

Dear Kathy:

On behalf of the Utah Snowmobile Association (“USA”), I am providing you comments on the September 2006 Evaluation of Undeveloped Areas for Potential Wilderness. We previously provided comments dated July 26, 2006 on the Draft Information Packet, which are being resubmitted with this response, since the Planning Team ignored the majority of those comments. In evaluating the now four undeveloped areas (North Slope High Country, Ashley Gorge, South Slope High Country and High Uintas B), which have an overall capability rating for potential wilderness of “High,” there has been only a cursory recognition of the existence of snowmobiling.

The Forest Service is obligated to consider existing uses when evaluating undeveloped areas for potential wilderness recommendations. We pointed out in the second paragraph on page two of our July 26, 2006 comments the experience that is being sought after by the snowmobiling public. This niche is currently being fulfilled by the cross-country snowmobile opportunities afforded primarily in the North Slope High Country, Ashley Gorge and South Slope High Country undeveloped areas.

Although the Planning Team is correct that no groomed snowmobile trails exist within the undeveloped areas identified above, they are missing the point when considering the impact on snowmobiling should these areas become designated wilderness. There are groomed snowmobile trails immediately adjacent to such undeveloped areas that provide for the direction, safety and overall access to the cross-country, over-the-snow travel that legitimately exists today. It is important to point out that mere “trail riding” is not the primary experience desired by the snowmobilers that frequent Ashley National Forest. Cross-country snowmobile access is a privilege that is paramount in the fulfillment of a rewarding snowmobile experience.

We are aware that other National Forests have recognized the need to provide a true multiple use spectrum by implementing alternative management prescriptions in lieu of wilderness recommendations. Semi-primitive, non-motorized, except for motorized over-the-snow travel during the period of November 30^th through April 30^th is a prescription that is appropriate where the criteria for an otherwise non-motorized area may exist. At a minimum, this management guideline should be considered before making an overly restrictive wilderness recommendation.

Consistent with the above logic, there is a statement on page 23 of the Final Information Packet that states: “North Slope High Country Undeveloped Area could provide opportunities for primitive and unconfined outdoor recreation experiences without a wilderness designation if resource management activities and programs were designed to protect and maintain existing wilderness-like characteristics.” We believe this concept appropriately applies to all 37 undeveloped areas on Ashley National Forest.

Although we stand firm in our belief with respect to the above comments, we realize consideration of undeveloped areas for wilderness recommendation is very subjective and crosses the line on many differing values. If, after exhaustive evaluation of existing uses, the Planning Team still concludes there are areas that truly merit wilderness recommendations, we believe there should be a stipulation added similar to the outcome for the Lakes Backcountry Undeveloped Area from the Revised Plan for the Wasatch-Cache National Forest. Snowmobiling was allowed to continue where it previously existed until such time as Congress acts on the wilderness recommendation. This was found appropriate due to the lack of any evidence of resource damage or degradation of wilderness characteristics that might prevent possible wilderness designation.

Once again, we thank the Planning Team for consideration of our comments. If you would like any further clarification, please contact Curt Kennedy at 801-582-3882 or e-mail ccklpk@msn.com. We want to stay involved with the balance of the planning process and look forward to an equitable and effective Revised Plan.