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USFS - Tahoe National Forest

Preliminary Application Comments

 My name is John Timmer. I enjoy hiking throughout the Tahoe National Forest. Many years ago, I discovered the area along the South Yuba River known as Pierce Meadows. My wife and I love to walk along the river and swim in quiet pools amid granite boulders and tall pines. The pools and waterfalls of this stretch are a beautiful, quiet and relaxing destination. That quiet beauty is in danger.

Over the years, I have been witness to the constant degradation perpetrated on the river, its riverbanks and the surrounding forest lands by Off Road Vehicles. I have witnessed the Forest Service’s almost annual efforts to correct the problems associated with allowing ORVs in and around the river and the associated streams of the Pierce Meadows Area. I have cataloged these problems and communicated my concerns to Forest Service representatives regularly. It is well past time to address these problems and create solutions that protect the Yuba watershed and its main artery, the Yuba River.

Due to my interest in the Pierce Meadows stretch of the South Yuba River, I have been involved the public participation that the Forest Service has encouraged regarding its plans for Travel Management on the Tahoe National Forest. By attending the numerous planning sessions hosted by the Forest Service, I have educated myself on the issues pertaining to at-risk forest resources and the balanced recreational needs of a wide variety of users.

I have learned that the funds to buy a half section in this area from private landowners were obtained through the California State ORV program. Since that time, over ten years ago, the Forest Service has introduced ORVs to the river banks and the riverbed of the South Yuba River to disastrous results. Past grant applications have secured small amounts of CA State grant funds to fix the problems along this river stretch but the damage by ORV enthusiasts is always re-visited on the area.

The S. Fork of the Yuba River should be protected from erosion and water pollution resulting from the interface of ORV routes and the River.

Solution: Close ORV routes that provide direct access to riverbed and buffer zone which create Resource Damage to the River and its water quality.

1) Problems resulting from Use of Riverbed of South Yuba River as ORV _areas_

• Upper Ford - 1300’ of riverfront between 20’ and 500’ at widest point has been reduced to a gravel bar. Willows are being trampled. River banks are being eroded away on both sides of the river by multiple entry points to the river and by indiscriminate ORV ‘play’. Trees are being toppled every year because the riverbank is weakened by ORV ‘play’. Willows on river right above ford have been clearcut to get over and around USFS barriers to closed campsites. This is not an play 'area' but a route. The impacts should be limited to less than 50' wide.

• Lower Ford – impacted area extends for over 430’ of river front (100’ to 170’ wide). Multiple cutbanks on either side of river. USFS tried to close all but one on each side in 2005. Defeated by flood and overtopped by ORV users. The Upper Ford provides a textbook example of what will happen to the Lower Ford in the coming years if ORV impacts continue. Also forested island in SE quadrant will disappear under ORV impact as ATVs drive over roots, compact soils and create cutbanks on the island.

• Below Lower Ford, river right – ORV users have driven around USFS barriers to access river bottom and beach. 450’ by 20’ to 60’. Watch for stream bank erosion and toppled trees. Roots are driven over, exposed and will be toppled. Adjacent to 3 parallel roads. Campfire ring within river bed.

2) Human waste – Prevalent throughout the entire area, within 100’of river in many cases and at Upper Ford actually in the riverbed while FS toilet is only 200 yards away. No apparent attempt to bury human waste.
Danger to water quality and human health.

3) Off route use – There are multiple routes leading off into forest that are not authorized – USFS has created barriers and ORV users have overtopped them or gone around them. Most barriers have failed to contain the abuse for more than one year. Current barrier schemes include dropping trees and digging ‘tank-traps’. While relatively cheap, these schemes do not foster a health regard in the hearts and minds of visitors. Some folks see them as ugly and others see them as an encouragement to wreak havoc themselves.

    * Law enforcement must be increased, laws must be enforced.
    * Trails and campsites must be shifted away from the river.
    * Unauthorized trails must be blocked. (these trails extend in every
    * Current trail blocking is done by the use of downing trees and
      digging 'tank traps'. This mode of blockage does not encourage the
      respect of ORV users to the area.

The lion's share of funds requested by the USFS - Tahoe National Forest is to continue to 'maintain' ORV routes. Very little of the money is alloted law enforcement or to fix the problems created by introducing this form of recreation into sensitive areas. The OHV section of the California Parks and Recreation Department should not fund grant applications that expect different results from the same actions. The State should favor grant applications that solve these long-standing problems and protect the water quality of our rivers. Stop throwing good money away after bad. Fix the problems endangering this river or close the area permanently. [John Timmer - 4/6/09]

 The following are my comments for OHV Grant, G08-02-20-G01, Ground Operations, for the Tahoe National Forest:
I advise against funding of this Grant request as written. It contains funding requests for scientific studies. Those studies should be funded from the RESTORATION category. All expenses for those studies should be removed from this Ground Operations Project and entered into a new grant request under RESTORATION.

(a) Purpose
(3) Restoration Projects also include scientific and cultural studies regarding
OHV impacts and Restoration Planning efforts

1. Project Description
A. Statement of GO Activity
“Our resource specialists (wildlife biologists, soil scientists, botanists, hydrologists, fish biologists, archaeologists and ecologists) are involved in the OHV management program on the Forest. Grant monies will fund resource specialists to continue monitoring wildlife, soils, water, Threatened and Endangered species, and cultural sites.”

“Funding will provide for monitoring: The effectiveness of bald eagle vehicle closures; the effectiveness of OHV barriers to yellow-legged frog habitat, the impact of OHV on willow flycatcher, goshawk and spotted owl nesting near motorcycle trails, the OHV impacts to the fairy shrimp, the OHV impacts to sensitive plants and fens.”

Thank you for considering my comments. [Bruce Brazil - 4/6/09]

 Comments on the TNF YRRD Travel Management Implementation Grant Request

I support the Tahoe National Forest's planning grant request titled "YRRD Travel Management Implementation". If the TNF is able to see the proposals outlined in the request to completion, the loss of OHV opportunity due to the Travel Management Rule process will be mitigated so some extent.

I applaud the TNF for what appears to be a proposal that is in line with comments received from the public during the Travel Management Rule process. If the "Preferred Alternative" is implemented into the Travel Management Rule, key routes that link trail segments will be reclassified as "Open to Highway Legal Vehicles Only", or will be closed to motorized vehicles all together. The result will be a fragmented OHV trail system that would make it impossible for "green sticker" vehicles to link trails that they can legally link today.

During review of the TNF Motorized Travel Management Plan DEIS, members of the public recognized that the "Preferred Alternative" would limit OHV opportunity, especially with regards to the reclassification of roads "Open to Highway Legal Vehicles Only".

During the public comment period, several suggestions were made to the TNF as possible solutions to mitigate the future loss of OHV opportunity. Several of those solutions are the same as what the TNF is proposing in this grant request.

I would like to point out that three of the four proposed trails discussed in detail in the grant request would keep OHV opportunity the way it is today. These are proposals 1, 3, and 4. Proposal 2 would take OHV opportunity beyond what it is today and would be a welcome addition. The Fiddle Creek/Halls Ranch trails are terrific single-track motorcycle trails that are isolated from the rest of the single-track trails in the Downieville area due to a short paved section of "highway". One can ride the Fiddle Creek/Halls Ranch trails in half a day, so in order to continue to ride, the user has to load the motorcycle into their truck or trailer and haul them up the road and then unload again to ride the rest of the Downieville trail system. The proposed trail additions will alleviate the need to trailer the bikes, and would result in a more enjoyable OHV recreational experience.

The Tahoe National Forest's planning request shows foresight, sound management, and a commitment to future OHV recreation. [Kevin Liles - 4/6/09]

 On behalf of CORVA and myself, we would like to support the Tahoe National Forest's Planning Grant application.

This is an excellent example of the proper use of OHV trust funds - planning to add to and enhance OHV opportunities in the forest. This is a plan supported by OHV volunteers, local users and clubs.

Please fund this Planning Grant application. [Amy Granat, Northern Director, CORVA - 3/28/09]

 On behalf of CORVA and myself, I would like to voice some concerns about the Grant Application for Ground Operations.

I acknowledge that the Tahoe National Forest contains many OHV and OSV opportunities, however a good portion of the grant monies requested would serve to fund the various 'ologists employed by the Forest Service, supposedly to "monitor" conditions.

In my experience, the only thing the 'ologists do is find excuses to close trails, as seen in the recent DEIS. Most of the biological opinions have already been issued and expounded upon in the recent DEIS. Any and every possible change of conditions or harm to flora and fauna that may be done by OHV recreation has been investigated ad infinitum in the DEIS. Therefore, any monitoring that needs to take place can be done by much lower paid staff, perhaps assisted by volunteers.

Over $200, 000 has been requested to fund specialists of various kinds, specialists whose information should have been used quite recently in the preparation of the 1400 + page DEIS. What, if not reports by specialists, was contained in those 1400 pages of the DEIS? Shouldn't the information garnered in preparation of the DEIS be complete and timely? If not, was the DEIS incomplete, and should we question the accuracy of the information contained in that document? It seems that the Forest Service, having finished the DEIS at this point, is looking to the OHV trust fund to pay these specialists when their work is essentially finished. It seems like "busy work" and I have found no significant reason in this grant request to support the use of funds in this manner.
I also have questions about the matching funds calculated from volunteer labor. In the American Ranger District of the Tahoe National Forest, we have had significant difficulty obtaining an MOU to undertake basic maintenance work on the Foresthill OHV Trail System, work to be done solely by volunteers. The District Ranger has been unresponsive to requests to work together, undermining the volunteers' enthusiasm and dedication to working with the Tahoe National Forest. Much trust and goodwill has also been eroded due to the recent DEIS. I would caution the forest to truly take stock of the volunteers' willingness to work in the forest, and caution the division that the matching funds calculated from the valuation of volunteer labor might be grossly overestimated. As we know, it has been OHV volunteers who have done the majority of this work in the past, and given the size of the proposed closure of OHV trails, many of those same volunteers may prove to be unavailable in the future.

Other items in this grant request are quite legitimate and do directly contribute to the health and maintenance of the trails and OHV staging areas. These parts of the grant are acceptable, and deserve to be funded.

The OHV public, having become somewhat educated during the Travel Management process, is now demanding that the OHV trust fund be used for ground operations that  enhance and support OHV recreation.

Requests for grant money that do not fit this description, should simply not be funded. In regards to the other grant request, in contrast the Planning grants request does deserve to be funded. It is well thought out and presented, and directly relates to improvements to the OHV trail system. This is a good use of OHV monies, and I would encourage the division to fund this request. [Amy Granat, Northern Director, CORVA - 3/28/09]

 Link to comments from Don Amador, Western Representative, BlueRibbon Coalition, Inc.  [3/26/09]