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.