USDA Forest Service
CAET, Sierra Nevada Framework Project
PO Box 7669
200 E Broadway, Rm. 301
Missoula, MT 59807

Dear Sir,

I am writing to express my grave concern over the potential implementation of any of the alternatives described in the Draft Environmental Impact Statement for the Sierra Nevada Framework Project. I must insist on the withdrawal of this DEIS until all the issues listed below are addressed:

• It has been virtually impossible for the average recreational user who will be drastically affected by implementation of the Framework Project to review and digest the more than 1500 pages contained in the DEIS. The potential impacts to public access and recreational use although not clearly defined appear to be huge.

• The standards for protection of nesting, roosting and denning sites that would apply to all of the action alternatives have the cumulative affect of severely restricting recreational use of huge tracts land for more than three quarters of the recreational season. The DEIS does not identify the trails, campgrounds, special use sites, activities, services, roads, or areas of recreation that would be affected by these restrictions. There is no way to analyze these impacts.

• The reasons given for proposing such sweeping changes to Forest Service management policy are not based on sound science. To site just one example, the document discusses the need to create Protected Activity Centers (PACs) and Limited Operating Periods (LOPs) to protect a number of different species although, in one instance, the species, the wolverine, has not been documented to exist in the area in question for over 50 years. In a second instance the establishment of a five-mile radius around nesting sites for the willow flycatcher year round is based on the perceived need to protect the willow flycatcher from nest parasitism by the brown-headed cowbird. This effectively eliminates recreational use from huge tracts of lands. Brown-headed cowbirds have impacted less than 5% of observed willow flycatcher nests in the Sierra Nevada planning area between 1997 and 1999.

• The concept of returning the forests to pre-European Settlement Conditions is a fallacy at best. The idea that we can return an area to some "edenic garden" state by changing a management policy is nonsense that has no basis in scientific planning efforts. 

• Congress has not approved the shift by the Forest Service from Multiple Use of National Forests to Habitat Preservation. Existing legislation from the Organic Administration Act of 1897 to the Multiple-Use Sustained Yield Act of 1960 to the Wilderness Act of 1964 includes recreation as a major and integral part of the functions of the National Forests. These proposed actions will cancel without justification the policies that established our National Forests. It is a direct reversal of longstanding national forest use policy.

• The Sierra Nevada Plan Amendment DEIS provides a very limited range of alternatives, none of which fully address the effects to outdoor recreation facilities, services and activities.

California is a prime destination for both domestic and international travelers. Recreational activity shapes social, economic and ecological conditions, and influences policies in the Sierra Nevada Regions. The DEIS does not in any way address the potential economic impacts on the numerous small towns and businesses that are directly dependent on the revenues from recreational users. The severe restrictions, management constraints and habitat set-asides will have significant effects on trail users and the businesses that support them without providing for a reasonable balance of uses.

Due to the broad area this document will affect and potentially severe restrictions it will place on public access to public lands it is essential that it be withdrawn from consideration any and all concerns raised by commentors are addressed.

Sincerely,

Candace Ricks

Citizens Against Recreational Eviction (CARE) of Minnesota