Bill Richardson Oregon & Washington Lands Program Manager Rocky Mountain Elk Foundation 24550 Ervin Road Philomath OR 97370 866-399-6089 office 541-760-5083 cell brichardson@rmef.org December 21, 2009 Ochoco Summit OHV Trail Planning Team Ochoco National Forest 3160 NE 3rd Street Prineville, OR 97754 Subject: Scoping Comments Ochoco Summit OHV Trail Project The purpose of this letter is to submit the Rocky Mountain Elk Foundation s scoping comments for the Ochoco Summit OHV Project. The project is proposing to establish an OHV road and trail system including addition of 124 miles of new trail within an area that already contains an extensive road network. Designation of the proposed OHV trail system must be expected bring a vastly increased level of motorized disturbance of wildlife within the project area, because the forest is nearly concurrently closing its lands to all cross country travel by motorized vehicles. The Elk Foundation is very concerned this project, if implemented, will have extremely detrimental impact upon the wildlife, particularly deer and elk, and upon the wildlife habitat within the project area by drastically increasing the level of disturbance by motorized vehicles. Published USFS research from the Starkey Forest and Range Experiment Station clearly indicates elk and mule deer are displaced long distances by motor vehicle disturbance (movement and noise). To the extent the animals may are displaced from their preferred foraging range to less valuable range their nutrition and thus physical condition will be detrimentally impacted. Even if the habitat to which the game is displaced is of comparable forage productivity, the reduced area may experience increased and perhaps detrimental foraging impact. USFS research from Starkey shows poor summer nutrition to have detrimental impact to upon animal condition, calf production and survival by USFS research from Starkey. Research also shows that deer and elk in poor condition going into the winter are more susceptible to predation. The project area contains critical big game winter, known elk calving areas and important areas of high value summer forage including wet meadows that big game will be denied use of as a result of
disturbance from nearby motorized vehicle traffic. As part of the project analysis, evaluation of specific effects of roads and OHV trail disturbance on elk displacement should be performed using spatially explicit methods. We urge you to manage motorized routes to avoid displacement of big game from their preferred habitat. Oregon Department of Fish and Wildlife (ODFW) consider the area of the proposed project to be high value mule deer and elk habitat. It must be noted that mule deer in the Ochoco Wildlife Management unit are below ODFW management objective. Increased disturbance by the proposed project can reasonably be expected have a detrimental impact on mule deer population within the project area. There is a Memorandum of Understanding between the USDA Forest Service Region 6 and ODFW (MOU 85-06-63-15). Paragraph A.3 indicates the USFS has the obligation to recognize and assist ODFW in achieving its goals and objectives for deer and elk management, and it is suggested the Oregon Mule Deer and Elk Management Plans and the Oregon Conservation Strategy be carefully considered as the proposed project is analyzed. The cited MOU also states at paragraph A.4 the USFS is to provide the ODFW the opportunity to participate on interdisciplinary teams when impacts on wildlife habitats may be of concern to ODFW. Because this project impacts an extensive area of high value elk and deer habitat, it is suggested ODFW be invited to join the IDT for this project. Hunting big game and wildlife viewing in the area of the project are traditional recreational activities. Hunting and wildlife viewing by their nature must take place in peace and quiet, thus they are not compatible with the disturbance caused by high levels of motorized vehicle disturbance. Increased disturbance levels from motorized vehicles will degrade the value of the project area for these two traditional activities by dispersing the wildlife out of their traditional range. It should also be considered that hunting and wildlife viewing provide great monetary benefit to the local economy. ODFW has an economic analysis available which clearly shows the economic value of hunting and wildlife viewing by county. Conducting an economic analysis of the relative value of the OHV trail system project versus hunting and wildlife viewing should be considered. Non-native invasive vegetation can be expected to be brought into the project area at increased levels due to the increase in motorized recreation, and this eventuality must be recognized, with strategy for mitigation and control planned and costs estimated. Analysis of this proposed project should included careful evaluation of the costs of administration, enforcement and maintenance (including control of invasive vegetation and soil erosion) requirements for each alternative considered. The
USFS must be able to assure adequate funding for administration, enforcement and maintenance for the project. While not part of this project, the USFS should consider the proposed OHV trail system may be used by snowmobiles during the winter when adequate snow is present. During analysis of this project please design routes to avoid critical winter range areas and minimize disturbance of elk and deer as they are stressed by reduced nutritional resources at the same time the winter climate requires increase energy. Harassment in the winter is extremely detrimental for deer and elk. Finally, we call to your attention the Presidential Executive Order titled FACILITATION OF HUNTING HERITAGE AND WILDLIFE CONSERVATION signed August 16, 2007. This order may have some bearing on the final form of this proposed project. Appended to this letter is a list of current research related to the impacts of disturbance and nutrition upon big game that should be considered in the analysis of this project. The Rocky Mountain Elk Foundation is a non-profit conservation organization whose mission is to insure the future of elk, other wildlife and their habitat. The Foundation also works to open, secure and improve public access for hunting, fishing and other recreation. Thank you for the opportunity to comment on this project. Sincerely, Bill Richardson Oregon & Washington Lands Program Manager Rocky Mountain Elk Foundation
Appendix - Research and ODFW management plans bearing on the proposed Ochoco Summit OHV Trail Project Research Papers Cook, J.G, et al. 1998. Relations of forest cover and Condition of elk: A test of the thermal cover hypothesis in summer and winter. Wildlife Monographs. 141: 1-61. Cook, J.G., et al. 2004. Effects of Summer-Autumn Nutrition and Parturition Date on Reproduction and Survival of Elk. Wildlife Monographs. 155: 1-61 Hobbs, N.T. 1989. Linking energy balance to survival in mule deer: development and test of a simulated model. Wildlife Monographs 101:1-39 Johnson, B.K., et al. 2000. Resource selection and special separation of mule deer and elk in spring. Journal of Wildlife Management. 64:685-697. Knight, R.L. and K.J. Gutzwiller, eds. 1995. Wildlife and recreationistscoexisstence through management and research. Island Press. Washington, D.C. Naylor, Leslie M, et al. 2008. Behavioral Response of North American Elk to Recreational Activity. Journal of Wildlife Management 73(3): 328-338. Noyes, J.H., et al. 2002. Effects of male age and female nutritional condition on elk reproduction. Journal of Wildlife Management. 66: 1301-1307. Preisler, H.K., et al. 2006. Statistical methods of analyzing response of wildlife to human disturbance. Journal of Applied Ecology 43:164-172. Rowland, M.M., et al. 2000. Elk distribution and modeling in relation to roads. Journal of Wildlife Management. 64(3): 672-684 Rowland, M.M., et al. 2005. Effects of Roads on Elk: Implications for Manage Forest Ecosystems. The Starkey Project: 42-52. Wisdom, Michael J., et al. 2005. Spatial Partitioning by Mule Deer and Elk in Relation to Traffic. The Starkey Project: 53-66. Wisdom, Michael J., et al. 2005. Effects of Off-Road Recreation on Mule Deer and Elk. The Starkey Project: 62-80. Oregon Department of Fish and Wildlife Management Plans OREGON S ELK MANAGEMENT PLAN February 2003
http://www.dfw.state.or.us/wildlife/management_plans/docs/elkplanfinal.pdf OREGON S MULE DEER MANAGEMENT PLAN February 2003 http://www.dfw.state.or.us/wildlife/management_plans/docs/muledeerplanfinal.p DF The Oregon Conservation Strategy, February 2006 http://www.dfw.state.or.us/conservationstrategy Fishing, Hunting, Wildlife Viewing, and Shellfishing in Oregon 2008 State and County Expenditure Estimates http://www.dfw.state.or.us/agency/docs/report_5_6_09--final%20%282%29.pdf Internet websites The Starkey Project. Detailed information about the Starkey project, including current studies, photo gallery, data, and publications. www.fs.fed.us/pnw/starkey USDA, forest Service, Pacific Northwest Research Station. Access to all Station Publications. www.fs.fed.us/pnw