Submitted to the Subcommittee on National Parks, Recreation, and Public Lands
April 16, 2002

The Wilderness Society, Natural Trails and Waters Coalition, Sierra Club, Wild Utah Project, Save Our Canyons and Southern Utah Wilderness Alliance appreciate this opportunity to provide written testimony for the Subcommittee's hearing on H.R. 3936, the Shoshone National Recreation Trail Act. Our combined membership of nearly one million Americans work toward protecting and restoring public lands and waterways from the abuse caused by all-terrain vehicles and other off road vehicles.

We oppose H.R. 3936, a bill that would encourage off-road vehicle use without considering the wildlife and natural resource impacts to the Wasatch Cache National Forest and surrounding federal, state, and private lands. We believe that this legislation would undermine the ongoing land use planning process for the Wasatch Cache National Forest. For about two years, the Forest Service has been utilizing the National Environmental Policy Act (NEPA) process to ensure environmental analysis and adequate public input. In addition, the Forest Service is in the middle of designating motorized routes on this Forest based on public comments through the Travel Management Plan, that is due out this Fall or soon after. By legislating this off-road vehicle route system, the current public process would be undermined. We urge the Subcommittee to oppose this legislation

The Wasatch Cache National Forest and adjacent lands are critical links in the Rocky Mountain ranges, containing one of the richest wildlife corridors. The proposed Shoshone Trail System would create a grid that would break apart this continental wildlife linkage. According to Utah Division of Wildlife Resources, elk, bear, and moose thrive in these areas. A recent study commissioned by the U.S. Fish and Wildlife Service found approximately 36 animal and 18 plant species at risk that use this rugged terrain. If designated, this motorized route system poses a serious risk to the continued viability of these species.

The connectivity and structure of the route system is questionable at best. The route system appears to go through private land and to convert non-motorized routes to motorized routes. Furthermore, the legislation only allows non-motorized use "to the extent that such use is compatible with motorized use." Due to the serious public safety issues associated with off-road vehicles and federal agencies' obligation to safeguard visitors, we believe this language would essentially close the trail to non-motorized visitors. We are concerned that the impact of this bill on hikers, equestrians, and other visitors may not be well understood. This legislation also raises concerns with the rights of current and future landowners' ability to use their property for their own needs. This includes utilizing the trails on their property for non-motorized uses. This legislation would also prevent adaptive management that provides the agency with the ability to make needed changes as conditions to routes change. As stated earlier, the land use and travel management planning processes take many of the issues into account and both rely on environmental analysis and public input.

In May 2001, the Forest Service updated its roadless areas inventory within the Wasatch Cache National Forest. These areas, identified on the enclosed map, would be put at risk by this route system. We are concerned with the routes that go around and through roadless areas. Due to this new route designation, motorized use would be intensified potentially causing illegal off-trail use, widening routes, promoting new routes, and other impacts.

In Utah, off-road vehicle use has skyrocketed in the past 12 years from 22,000 to about 100,000 vehicles. At the same time, federal land management agencies have not adequately enforced existing rules. We have documented that new routes tend to promote the development of new offshoots and uncontrollable use in other areas. In fact, the Piute Trail in Utah has a growing number of illegal routes off the designated routes. Based on our fieldwork, the newly created routes may now total more miles than the Puite Trail. The Forest Service and BLM have shown little interest in controlling this proliferation of routes. In the absence of the needed monitoring and enforcement, the agencies have allowed this impacts to propagate without agency recognition. This history of poor enforcement and monitoring must raise concerns with the management of the potential Shoshone motorized route system.

Lastly, according to H.R. 3936 the Shoshone National Recreation Trail will be managed as "a national recreation trail in accordance with the National Trails System Act (16 U.S.C. 1241 et seq.)." This would be the first time the purpose of national recreation trail is solely motorized use. We are concerned that this would set a precedent of permanently designating a motorized route system without adequate analysis.

We support the Forest Service's continuing effort to analyze these issues rather than instituting this route system without critical information. We believe H.R. 3936 is unnecessary, the Wasatch Cache National Forest has an ongoing planning process that should proceed. Due to the short time period to react to this legislation, we would appreciate an opportunity to add to the record in upcoming weeks.
We urge the Subcommittee to oppose H.R. 3936.

Sincerely,

Kristen Brengel
Natural Trails and Waters Coalition
(202) 429-2694

Lawson Legate
Sierra Club
(801) 467-9294

James Catlin
Wild Utah Project
(801) 328-3550

Heidi McIntosh
Southern Utah Wilderness Alliance
(801) 486-3161 x15

Gavin Noyes
Save Our Canyons
(801) 539-5333

Dave Alberswerth
The Wilderness Society
(202) 429-2695