Here is a copy of the comments I submitted on the Forest Service's
Proposed National Forest plan for the Chequamegon and Nicolet Forests and
Draft EIS. ( For informational purposes only.)
--------- Forwarded message ----------
From: [EMAIL PROTECTED]
To: [EMAIL PROTECTED]
Date: Mon, 11 Aug 2003 22:45:18 -0500
Subject: Comments On Chequamegon-Nicolet, Forest Plan Revisions DEIS
Message-ID: <[EMAIL PROTECTED]>
Michael T. Neuman
4334 Waite Circle
Madison, WI 53711
Chequamegon-Nicolet Forest Plan Revision DEIS
P.O. Box 221090
Salt Lake City, UT 801-517-1014
Following are my comments on the Proposed Land and Resource Management
Plan on the Chequamegon and Nicolet National Forest Plan and its Draft
Environmental Impact Statement (DEIS).
I am submitting these comments on my own behalf and as a member of the
"Preserve Our Climate" coalition, a volunteer group presently operating
out of Madison, Wisconsin who's mission includes identifying and
promoting strategies to preserve the climate from additional global
warming. Accordingly, my interest in reviewing the Chequamegon-Nicolet
Forest plan and DEIS is in seeing that the plan adequately addresses the
environmental impacts of ATV and snowmobile recreational use of the
Forest, and other the impacts of other motorized fossil fuel burning
activities in the forest.
1) On page 3-197, the DEIS states that "Wisconsin ATV registrations
increased more than three fold since 1987, growing from 25,600 in 1987 to
80,111 in 1997".
Aside from the need to update these registration figures (they're already
5-years old), the plan and EIS should specifically identify extent of
existing and increased recreational ATV driving in the
Chequamegon-Nicolet Forest (CNF) itself, rather than just citing vehicle
registration figures tabulated for the entire state of Wisconsin.
To that end, one must question why the Forest Service did not conduct or
contract for a study of the extent of existing and projected recreational
use of the CNF by ATV recreationists and snowmobilers, and the
corresponding vehicle miles traveled-related impacts on the air,
serenity, soil, plant life, wildlife, and trail-user related conflicts
and human and animal safety concerns. All of these impacts are dependent
on the motorized vehicle use levels of the Forest, as measured by the
number of ATV and snowmobile "vehicle miles travelled" (VMT) in the
Forest.
To estimate the air pollution impacts in particular, forest planners
might consider estimating the number of off-road vehicle miles travelled
in the forest on an annual basis between now and the end of the forest
planning period. Once those numbers are estimated, the VMT and the
typical miles per gallon fuel efficiencies of ATVs, snowmobiles, dirt
bikes, etc., could be used to estimate the gallons of fuel that will be
burned on the Forest property over the planning horizon. (A similar
estimate might be derived for recreational boating and jet ski
activities.)
>From the quantities of fuel burned, and the known emission rates, forest
planners ought be able to estimate the environmental pollutants and
greenhouse gases emitted to the air, and atmosphere, from projected
motorized recreational use of the Forest.
Off-road vehicles are known contributors of toxins, carcinogens, ozone
precursors; and greenhouse gases such as carbon dioxide and nitrogen
oxide, which are known to be building up in the atmosphere now in large
quantities. In fact, greenhouse gas accumulations from fossil fuel
burning, over the last century in particular, are now scientifically
implicated in causing global warming in the last century, and increased
rates of warming in the last 25 years in particular. Rising average
annual temperatures in the Midwest, including in Wisconsin, are now well
documented by highly respected Midwest university scientists working on
the issue of climate change through the auspices of the United Nation's
and World Meteorological Society's Intergovernmental Panel on Climate
Change (IPCC) and the Union of Concerned Scientists' recently published
study: "Confronting Climate Change in the Great Lakes Region", <
http://www.ucsusa.org >).
The conclusions of these studies have led the authors of these studies to
sound the alarm bell on the increasingly imperative need to minimize
fossil fuel burning emissions from transportation, recreation, and other
sources of energy. The CNF plan ought pay attention to these calls for
alarm and not allow continued burning of fossil fuels in the Forest to
serve only the interests of environmentally and economically
unsustainable recreational pursuits, such as snowmobiling and ATV driving
for the fun of it, activities that are already known to be contributing
to increased melting rates in the Midwest, shorter winter tourism seasons
and changes to Wisconsin's biological and physical makeup.
2) In Chapter 2, pgs 2-13 - 2-34 ["Alternatives Considered in Detail"] -
all of the proposed alternatives assume 284 miles of ATV trails in the
Chequamegon segment of the Forest will continue in ATV use. There ought
be an alternative in the plan that proposes no off-road [ATV or
snowmobile recreational travel] in both the Nicolet and the Chequamegon
forest areas. The plan should compare the impacts of having no off-road
vehicle use of the entire forest with the alternatives that include such
uses, examining impacts on air quality, noise, user needs, soil erosion,
long term sustainability, health and public safety.
Information on the environmental impacts of off-road vehicles and other
small engine vehicles follows:
A-1: "Dirt bikes, all-terrain vehicles (ATVs), snowmobiles and other
off-road vehicles are major sources of air, water and noise pollution
nationwide. Off-road vehicles produce a wide range of dangerous
pollutants, including carbon monoxide, nitrogen oxides, hydrocarbon,
particulate matter, benzene, methyl tertiary butyl ether (MTBE), and
compounds known as polycyclic aromatic hudrocarbons (PAHs)."
Particulate matter, benzene and PAHs are known human carcinogens while
MTBE is a possible carcinogen that has contaminated water supplies
throughout the United States.
http://www.naturaltrails.org/factsheets/fs_pollution.html
A-2: "... Off-road vehicles are a major source of pollution on public
lands. In Yellowstone National Park, although cars outnumber snowmobiles
16 to 1, snowmobiles produce as much as 68% of the Park's annual carbon
monoxide pollution and up to 90% of all hydrocarbon emissions...."
http://www.wyoming.sierraclub.org/alerts/a120601.html
Sincerely,
Michael T. Neuman
Environmental Analysis and Review Specialist
Preserve Our Climate Coalition
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