We appreciate their recognition of OHV recreation as a legitimate use in this proposed rulemaking. However, from the outset of this plan the Forest Service has incorrectly defined OHV as: "An OHV is a motor vehicle that is designed or retrofitted primarily for recreational use off road, including mini-bikes, amphibious vehicles, snowmobiles, off-highway motorcycles, go-carts, motorized trail bikes, and dune buggies." This definition is unacceptable, as it does not include other facilitated OHV travel such as horses, snowmobiles and mountain bikes. This discriminatory definition of OHV singles out only one categorical form of OHV recreation as the only form that needs management. With the stated objectives of resolving increased user conflicts, to simply ignore the other means of OHV travel will only make this effort ineffective. Motorized OHV is NOT the only facet of the issue or individually the entire problem. Therefore, we should not be the only ones singled out here.

We are very concerned these proposed rule changes will end up being more a plan for limiting and prohibiting legitimate motorized OHV recreational use rather than management for legitimate motorized OHV recreation and use on the National Forests. This concern is especially magnified in the light that the juggernaut of anti-access organizations is already working/lobbying very hard to make this a closure rule. This approach toward management will only exasperate problems that might exist and the Forest Service must hold firm in their commitment to organized motorized recreation to manage for OHV access.

Without exception, this process cannot circumvent the current Forest Planning Process as these proposed rule changes inherently suggest. It goes contrary to the NEPA processes to "piecemeal" change the designation of a Forest without an amendment to the current Plan of that Forest.

This proposed rule change makes no recognition of the propensity toward closure of many of those in the Forest Service who will be responsible to make decisions under the proposed new rule changes. Any rule changes in this regard NEED to address and emphasize the fact this proposed plan is not a blanket justification for closure but rather, intended to manage for OHV recreation opportunity instead of from OHV recreational opportunity.

The definitions of what roads, trails and areas are is inadequate and antiquated for current OHV use and recreation. These definitions need to be revamped in cooperation with the general public, OHV recreational interests and organizations at the local Forest level. The OHV opportunities that exist in each Forest in the System are often inimitable to that forest for reasons of terrain type, location, typical use and/or user. Therefore, rule changes should allow for definition of trails to be determined or, at the very least, modified at a local level to accommodate accordingly.

It is imperative that any proposed rule changes to OHV management be prioritized and be funded. We are very concerned that with no additional funding and no priority, the ability of the agency to complete the process in a timely and thorough manner is bound to failure in accomplishing the purpose and intent of the proposed changes. (Cite the example of the failed Montana, North Dakota and South Dakota OHV Travel Management Strategy to accomplish it’s stated goals of three years ago. Wherein, literally, after three years of the plans existence and falling well short of the plans objectives, all that has taken place is the blanket restriction to cross-country travel and initial recognition of base inventory roads and trails. In fact, certain Forests in Montana have ignored the plan completely and are illegally pursuing other management strategies in blatant disregard of the travel Management Strategy put in place.)

In this current process, base inventories must be comprehensive, and include all routes whether in the current inventory of each Forest or not.  History shows the Forest Service has failed completely to produce current and complete inventories of actual "on the ground" roads and trails. Sacrificing accuracy for expediency is unacceptable.

Any rule changes in this regard need to include mandatory, regular and complete updating of Forest Maps and made available to the public for use.

The public should be involved in the inventory and mapping process as early as possible.

Consumer GPS data and maps provided by the public must be considered.

Designation of all unpaved roads should be automatic.

While we feel management for OHV should be a priority, no arbitrary timelines should be applied. Each Forest in the System has unique needs and challenges that must be planned for. Arbitrary timelines will inherently lead to poorly crafted inventories and ultimately lead to ill-conceived closures.

Implementing this process should be done at landscape levels smaller than a Ranger District to facilitate a more complete process.

Any efforts to propose solutions through rule changes should focus first on areas with high levels of use, and move towards areas with low use or minimal issues. This should be done in cooperation with public interests and with the intent of planning for and implementing workable, localized solutions to localized challenges of management.

Any proposed rule changes need to provide for the dynamic nature of "on the ground" conditions. Decisions made under the auspices of those rules need to reflect an equally dynamic ability to adapt to meet those ever changing conditions and recreational needs. (Examples: 1) A decision for seasonally closing an area for big game winter ranging may be appropriate for the area for only a time. With the migratory habits of animals for whatever reason, that seasonal closure should be revisited to reaffirm its appropriateness. 2) Some trails that follow dry creek beds in the Black Hills National Forest may be appropriate during dry seasons and not appropriate during wet season )