USDA Forest Service Letter

USDA Forest Service
Green Mountain 6 Finger Lakes National Forests
231 North Main Street
Rutland, VT 05701
Tel. (802)747-6700 FAX: (802)747-6766 TTY: (802)747-6765

Reply to: 1010/2710
Date: July 23, 1993

Subject: Proposed Rules for Noncommercial Group Uses and the Distribution of Noncommercial Printed Material

To: Tim Curtis, RO

We have reviewed the proposed rules for Noncommercial Group Uses and the Distribution of Noncommercial Printed Materials and have the following comments.

1. The proposed rules present a good/bad situation. Good in the sense that they will help the Forest Service deal with large group gatherings by providing a more formal procedure. Bad, in the sense that they place a burden on some groups which have been traditional users of the public lands, and have never been a problem either in administration or resource management .

An example is local snowmobile clubs, or unorganized groups of snowmobile users. These users often recreate in groups of 25 or larger. These groups usually get together 'some day and decide on the spur of the moment to ride on the National Forest and have a cookout. We do not feel that these types of groups should have to get a permit. If so, we could be regulating spontaneity out of existence! If the rules state that these groups would have to get a permit, they will probably end up riding without one,- or a asking for a "blanket" permit which will cover the entire season and district and/or forest. Other casual recreational uses that would be unnecessarily impacted by the new rules include 3rd grade class picnics, family gatherings, the local birdwatching club's Forest.hike, and many, many more.

A suggestion is to increase the group size for which a permit is required from 25 to 50. The casual recreational outing rarely is larger than 50 people due to the logistics of moving and assembling that size group.

2. Our developed recreation sites, such as picnic areas, have been designed and constructed to accommodate large numbers of users at one time. Our picnic shelters/pavilions seat more than 25 people, and other facilities such as toilets and parking areas are also meant to accommodate' large groups. We often have school class trips, family gatherings or other groups of 25 or more use these facilities as was intended. There are no environmental or administrative concerns with large groups using these facilities. It does not seem necessary to require a permit for use of these facilities. If group size is a concern at a certain developed site, site specific regulations can be implemented to control the use. This would be much more effective than requiring a permit. Therefore, we suggest that groups using developed recreation sites be exempt from the new rules for Noncommercial group use.

3. There was no reference to NEPA requirements related to the new rules. Therefore, we are assuming that these permits, issued for one year or less, would be categorically excluded from documentation in an EIS or EA, and do not require a project file or decision memo as described in the Categories Established by the Chief. If this is not to be the case, we suggest very deer guidelines be established in the implementing regulations.

4 From a practical standpoint, some groups will refuse to sign any kind of permit. This brings up the issue of enforcement. Will there be new rules or guidelines on writing citations? If a group refuses to get a permit, what then?

5. One of the best "tools" we used at the Rainbow gathering was the use of the "Operating Plan" There is no mention of that, or any similar type of management plan. The operating plan is a valuable tool that should be included as a requirement of the permit. If it is not required as part of the rules, then perhaps it could be included in the implementing regulations.

/s/ Ann E. Mates

Recreation Planner

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