Hey IMBA: Go Home, You're Drunk.

**stuckathuntermtn** · 02-04-2018, 11:50 AM

What do they care?

**jamal** · 02-04-2018, 05:35 PM

The guide/hunting/outfitter folks tend to want to keep the Wilderness all to themselves.

I guess the nice thing is there are candidates better than a washed up country music singer running against gianforte this time around. I ride bikes with Grant Kier and he was the head of five valleys land trust. Not sure where he stands on the bikes in wilderness thing but he seems like he'd do a decent job.

Eric Melson was at the recent clearwater forest plan meeting in Missoula and did have some pretty good comments against some of the recommended wilderness that is planned. I did not get into the IMBA comments about hr1349 because that's not why we were there and I'm guessing he's gotten enough shit about it.

The great burn study area is proposed to become RWA, which includes the stateline trail from hoodoo pass. That's a really nice backcountry ride and it would be nice to keep that open. Current legality of riding that is already a gray area, but people do it, and it's not enforced or signed as no bikes allowed. The new forest plan as is will definitely change that.

Funny thing is there is nothing that says RWA has to be managed exactly as the real thing. SO, in the new nez-perce clearwater plan they are allowing game carts, chainsaws, road building and maintenance, mining related activity.... but no bikes, in all the new recommended wilderness areas.

Here's the website for that, you can read the plan and alternative development document, and send in your own comments

https://www.fs.usda.gov/detail/nezpe...telprdb5447338

Surprisingly, the traditional wilderness/sierra club types were in the minority at that meeting. There were a ton of snowmobilers, and then 10ish bikers, and then probably the same amount of less that wanted more wilderness. One commenter said they wanted to see all roadless areas in idaho become actual wilderness, which I though seemed a little excessive.

**stuckathuntermtn** · 02-04-2018, 11:09 PM

Sounds like the usual R1 shit show.

**jono** · 02-06-2018, 11:56 AM

Originally Posted by jamal

Eric Melson was at the recent clearwater forest plan meeting in Missoula and did have some pretty good comments against some of the recommended wilderness that is planned. I did not get into the IMBA comments about hr1349 because that's not why we were there and I'm guessing he's gotten enough shit about it.

The great burn study area is proposed to become RWA, which includes the stateline trail from hoodoo pass. That's a really nice backcountry ride and it would be nice to keep that open. Current legality of riding that is already a gray area, but people do it, and it's not enforced or signed as no bikes allowed. The new forest plan as is will definitely change that.

Funny thing is there is nothing that says RWA has to be managed exactly as the real thing. SO, in the new nez-perce clearwater plan they are allowing game carts, chainsaws, road building and maintenance, mining related activity.... but no bikes, in all the new recommended wilderness areas.

Here's the website for that, you can read the plan and alternative development document, and send in your own comments

https://www.fs.usda.gov/detail/nezpe...telprdb5447338

Thanks for the rabbit hole...er...link. We should try to distill this into legally targeted comments and send them in large numbers while emails are still being sought. My reading of the (admittedly small fraction of) USFS documentation shows a tendancy to ignore and then eradicate resources in the form of recreation opportunities involving bicycles--meaning the grey areas are left that way until bikes are banned and the loss goes undocumented because the strategy violates the USFS directive to preserve and enhance such resources. It's a lot of reading but it does illuminate the situation in R1 in some helpful ways.

I linked this before but buried it in a long post. It's a long article but it explains exactly why they don't specifically say they're going to manage RWAs as W:

https://www.bikemag.com/lines-in-the...ontana-access/

From about halfway in:

[The USFS' unofficial policy was challenged by]...a lawsuit filed by the Idaho State Snowmobile Association (ISSA) against the Nez Perce-Clearwater National Forest in 2012. The agency claimed there was no regional directive, but a judge saw reason to believe there was. ISSA won the right to depose three people from the Forest Service: Chris Ryan, regional forester Tom Tidwell (who is now the Forest Service chief), and Clearwater forest supervisor Rick Brazell.

Just before the depositions, the Forest Service settled. (The agency paid some of ISSA's court costs but otherwise the case remains mired in legal sludge.)

ISSA public lands director Sandra Mitchell has a hunch about what she would have heard in the depositions: "That the 'policy' existed and that Rick Brazell was told he had to manage recommended wilderness as Wilderness--he had no choice. That's why the forest settled. There's no question in my mind."

Ryan seemed to confirm as much when she leaned forward and almost whispered, near the end of a 45-minute interview, "Yeah, I guess there really wasn't a lot of discretion."

That article goes on to illustrate how legal leverage is used (or not used) in the hammering out of differences between user groups and I believe it makes the case for raising funds, lawering up and going to court if we want to be taken seriously. Exactly the opposite of IMBA's approach.

To take this a step further, I see an alliance with ISSA on this one, particularly since the USFS plans would put fat bikes on snowmobile trails by stating that they are inappropriate for groomed non-motorized trails. I can see keeping them off groomed classic-XC ski tracks as is SOP on any shared trail I've ridden, but to say they're only appropriate on groomed motorized or ungroomed is flat out dangerous and ignores better strategies. The only real reason to do that is to alter the political landscape. First by reducing bicycle use and then by creating conflicts between bicycles and snowmobiles. And this plan will last 20 years. It should be challenged again while Chris Ryan is around to be deposed.

**downvalleytrash** · 02-06-2018, 12:30 PM

Originally Posted by jamal

Eric Melson was at the recent clearwater forest plan meeting in Missoula and did have some pretty good comments against some of the recommended wilderness that is planned. I did not get into the IMBA comments about hr1349 because that's not why we were there and I'm guessing he's gotten enough shit about it.

Melson can hold his own, but good on you for showing up to the meeting. I wonder how many other commenters on this thread have actually gone to a forest plan meeting or participated in the process in a meaningful way?

It should be noted that Melson is an IMBA employee. How many people does STC have on payroll that are showing up to forest plan meetings?

There is clearly a demand for STC's stance, but all I've seen them do so far is get into bed with the some of the most anti-public lands people in congress. Beware wrestling with pigs and all that...

As for the raising money and going to court vs advocacy and participation in the administrative process there are a few problems for mtb'ers.
First, at no time in the foreseeable future will we be able to out-raise TWS, Sierra, and the other enviro groups. Second, if they can out-raise us, they can out-litigate us. We all know lawyering up is expensive.
Third, and perhaps most importantly, if it goes to court and the court rules against us, it sets a precedent. Courts rarely overturn precedent, so there is a huge risk in going to court and losing.
The rule of thumb for most non-profits I've been involved with is don't go to court unless you have a GREAT case and are likely to win. I hate Region 1's bullshit management of RWAs as wilderness as much as the next guy, but we have to be very careful suing over this unless we are damn near sure we can win.

Having said all that, if wilderness advocates and the FS are going to treat human powered bicycles the same as motorized uses, do we have any alternative but to team up with motorized users? This, as anyone that has seen what a few Texas Wheelchairs can do to singletrack, is problematic in its own right.

Its a long, slow, often frustrating process. Get involved.

**jono** · 02-06-2018, 01:48 PM

I didn't make that statement about going to court lightly; I agree about the potential risks. But we aren't going to sue the Sierra Club or the Wilderness Society, so their funds don't matter, only the case we bring. ISSA was able to make a very significant gain by going to court in this very matter. If the case is built carefully beforehand, we could take that further. The details for doing so are in the link Jamal posted--the USFS responsibilities and objectives simply have to be understood and arranged appropriately.

We want the opportunity for a specific, challenging recreation experience with scenic elements that is only provided by bicycling in these unique singletrack locations. The scenic nature of the trails, the lack of motorized traffic and the challenging nature of these trails (technicality, distance traveled and elevation gained and lost) are all critical elements of the experience. This experience defines a recreation resource. Protecting and enhancing these resources is in the USFS directive as they themselves state (it sure is buried under a mountain of other jargon, but it's there and I'll find it again).

There is no question that the USFS is overstepping by attempting, by their own description, to alter the political landscape in order to make Wilderness designation more likely, and that improper goal explains a lot of their actions. We know this. Proving it in court may be difficult but thanks to the very public nature of their past statements it's far from impossible. They've already made most of the case for us.

Court should be the last resort but given the prejudicial statements of numerous USFS employees it should be expected. We should be sending comments with that in mind. Namely, the comments should speak directly to the USFS responsibilities, cite how they are being applied to other user-groups but denied to mountain bikes along with any applicable laws. We should expect that our comments will be ignored until we point it all out to a judge and craft them accordingly. But obviously we have to make the comments first.

If you really think we get a full seat at the table without showing ourselves willing to go to court then I have to ask if you read the article I linked above?

If you have more faith in the USFS than I do that's great; I hope you're right and they listen up front. I don't see any difference for the immediate strategy, and you're right: at least 90% of us in this thread should be more involved and we should be bringing other riders into it as well.

**LightRanger** · 02-06-2018, 03:15 PM

Originally Posted by jono

But we aren't going to sue the Sierra Club or the Wilderness Society, so their funds don't matter

Groups on the opposing "side" of recreation issues commonly intervene in suits against the Forest Service. In my following of these issues and cases over the last 10-15 years it seems to happen more often than not. A lot more often than not.

**jono** · 02-06-2018, 04:16 PM

Originally Posted by LightRanger

Groups on the opposing "side" of recreation issues commonly intervene in suits against the Forest Service. In my following of these issues and cases over the last 10-15 years it seems to happen more often than not. A lot more often than not.

Of course, but taking the ISSA suit as an example, where the issue is that the USFS has a policy that hasn't been subject to public review, how does any third party hope to influence such a case? The typical scenario of competing user groups showing up to argue opposing sides seems kind of moot if the USFS broke the law. Are the SC/WS going to argue they didn't? In the ISSA case, at least, that seems pretty hopeless without getting to the depositions, which the USFS actually settled to avoid. Seemingly for obvious reasons, since the author of the white paper has herself admitted the allegation.

**Empty Beer** · 02-06-2018, 05:37 PM

Hard to argue with anything this IMBA co-founder writes in this looooooong letter to IMBA Board:

http://www.nemba.org/news/jim-hasena...lderness-areas

**toast2266** · 02-06-2018, 06:43 PM

Originally Posted by Empty Beer

Hard to argue with anything this IMBA co-founder writes in this looooooong letter to IMBA Board:

http://www.nemba.org/news/jim-hasena...lderness-areas

That letter lays it out nicely.

IMBA has done, and continues to do plenty of good. But their accomplishments get overshadowed by their tone deaf actions and statements of late.

Sent from my SM-G950U using Tapatalk

**jono** · 02-06-2018, 07:22 PM

+1. I'm curious if IMBA's current bylaws saying only the board gets a vote showed up when they moved to Colorado. Couldn't help noticing that NEMBA has voting members. Nice for IMBA if they manage a win here and there, but as long as their members are on mute I'm all-in for replacing IMBA outright.

**stuckathuntermtn** · 02-07-2018, 01:05 AM

So who wants to show me some good bc rides before they totally disappear? Doable on a hardtail?

**livefreerdie** · 02-22-2018, 09:06 PM

Originally Posted by stuckathuntermtn

So who wants to show me some good bc rides before they totally disappear? Doable on a hardtail?

I'd be glad to show you around Lionhead this summer. SWMMBA and others will be there the 1st weekend of July at the Mile Ck trailhead. Hopefully it is available to us in the future but it is certainly on the chopping block as of now. Custer Gallatin NF's proposed action would manage RWA for no bikes or chainsaws, resulting in a loss of over 20 miles of MT's best backcountry riding north of the CDT. The comment period ends March 5th. There aren't many comments from mountain bikers posted yet...maybe 5 of 1500, mostly about bison.

**DolphinSki** · 02-23-2018, 08:32 AM

Originally Posted by livefreerdie

I'd be glad to show you around Lionhead this summer. SWMMBA and others will be there the 1st weekend of July at the Mile Ck trailhead. Hopefully it is available to us in the future but it is certainly on the chopping block as of now. Custer Gallatin NF's proposed action would manage RWA for no bikes or chainsaws, resulting in a loss of over 20 miles of MT's best backcountry riding north of the CDT. The comment period ends March 5th. There aren't many comments from mountain bikers posted yet...maybe 5 of 1500, mostly about bison.

Really interesting to hear. That could be a huge loss of amazing backcountry trails. It's weird I haven't heard anything about it. SWMMBA has posted up about the Gallatin Forest Partners quite a bit, and has even written a letter in support of SB 2006 (Daines' bill eliminating 5 WSAs), but nothing about the Lionhead. I'll be writing my own letter, and attending the SWMMBA Community Forum on Monday. You'd think they would have a form letter drafted up, I'm curious why not.

**DolphinSki** · 02-23-2018, 12:25 PM

For anyone else curious about livefreerdie's comment about the Lionhead, I dug up the documents today:

Proposed Action-Revised Forest Plan: https://www.fs.usda.gov/Internet/FSE...eprd567788.pdf
-Page 92 lays out all Recommended Wilderness Areas in the Proposed Plan
-Page Lionhead is again mentioned on page 137 in the designations for the Madison/Henry Mountains

Appendix D: Evaluation of Wilderness Inventory Areas: https://www.fs.usda.gov/Internet/FSE...eprd567792.pdf
-Pages 419-24 cover the Lionhead area including a map of biking trails in the RWA

The Lionhead area has been an RWA since the previous forest plan, the difference now is the new plan will incorporate Region 1's policy of treating RWAs as designated Wilderness. The Mile->Sheep ride is mentioned on pg 422 of the Appendix. They know it's there, we just need to speak up to let them know we don't want it closed. I'll be writing my comment now.

Here is where you can comment- https://cara.ecosystem-management.or...?project=50185

**406** · 02-23-2018, 12:43 PM

Man, that would be a major loss. Keeping the CDT open is also very important.

**stuckathuntermtn** · 02-23-2018, 01:29 PM

And how do they plan on enforcing this fascism with no money?

**livefreerdie** · 02-23-2018, 01:35 PM

The CDT is currently not in the boundary that they have drawn at Lionhead, but there are definitely two groups with the word Wilderness in their name that want it all and have put in comments saying that.

I don't think there is written direction on how USFS is supposed to handle form letters, but they seem to have much less weight than individual comments. The public reading room is where you can see others comments, there is a button right at the top to filter out form letters. I worked on this email that SWMMBA sent to our mailing list. Some of it could be copied and pasted, or used as an outline for a comment. I think this link will stay put for anyone who wants more background, or feel free to post or message me here. Another thing that was brought to my attention is that fatbikes are not mentioned anywhere in our plan, they need to be listed alongside skiing and snowshoeing in the Recreation Opportunity Spectrum section of the proposed action.

**DolphinSki** · 02-23-2018, 02:01 PM

No idea on actual enforcement, but having these trails officially banned would be a huge loss. I've attached a form letter I drafted up (part of what I do for a living). Feel free to enter in your name and submit. That being said, the FS counts individualized letters with more weight than they do multiples of the exact same letter, so switch up the language a bit to reflect your own feelings.

**toast2266** · 02-23-2018, 02:13 PM

I haven't waded into the specifics of the Lionhead thing, but the Forest Services' conclusion that "recommended wilderness areas are not suitable for motorized or mechanized recreation" is bullshit. Every other Forest Service region in the country allows mechanized uses in RWA's on a case by case basis. And the forest planning rule allows for mechanized uses in RWA's if it doesn't prevent the protection of the area.

Up in the Flathead, we just submitted an objection on the Forest Plan on this exact topic. You can read our objection here: http://www.flatheadamb.org/news/flat...iles-objection

**stuckathuntermtn** · 02-23-2018, 02:14 PM

Yup

**panchosdad** · 02-23-2018, 04:50 PM

Thanks for the links above and the form letter, put together my own from that, including Toast's objection language to the categorical exclusion of mountain bikes in recommended wilderness. Learned a lot in the last hour, and I'm ready to rumble.

**toast2266** · 02-23-2018, 06:52 PM

I think it's also worth noting, given the title of the thread, that in my experience, imba is on the right side of the rwa issue. Folks from imba helped write the objection I linked above.

Credit where credit is due...

**homemadesalsa** · 02-23-2018, 08:54 PM

Ready set go. Am putting together a full press with our Mountain Bike the Tetons newsletter and Facebook page to get a STACK of letters written. A lot of us love to go up there and ride- it's my most favorite WILD place to be. We help every year with the SWMMBA trail clearing weekend and have made some really good friends in that crew.

Hey if you are just thinking about it, then write a letter please. We don't want the long Lionhead rides to go away like the White Clouds.

**panchosdad** · 02-23-2018, 10:36 PM

Originally Posted by toast2266

I think it's also worth noting, given the title of the thread, that in my experience, imba is on the right side of the rwa issue. Folks from imba helped write the objection I linked above.

Credit where credit is due...

Thanks for that, I was wondering how involved they are. They have legal minds on it?