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Forest Service issues decision on Oregon dunes management

Oregon Dunes National Recreation Area
Riders in the Oregon Dunes

The Oregon Dunes National Recreation Area consists of 45 square miles stretching from Florence to North Bend along the central Oregon Coast.

In the formal record of decision, Supervisor Jerry Ingersoll of the Siuslaw National Forest said he tried to reduce conflicts between motorized and non-motorized uses of the recreation area while accommodating at least some of the requests made by recreational off-roaders.

Historically, a little more than 9 square miles of open sand had been set aside for OHV use, with another nearly 7 square miles of vegetated areas where riding was allowed on 34 miles of designated trails.

Congress designated the Oregon Dunes on the Siuslaw National Forest as a National Recreation Area (ODNRA) in 1972, and prescribed that it be managed for “…public outdoor recreation use and enjoyment,” and for “the conservation of scenic, scientific, historic, and other values contributing to public enjoyment.” The ODNRA is comprised of approximately 28,900 acres of forested areas, water and open sand areas between Florence and North Bend on the Oregon coast. This area of diverse and constantly changing landscapes is host to a wide array of outdoor recreational uses.

One popular use of the area is OHV riding. The ODNRA provides a riding experience almost unique in the United States, and many families travel long distances to enjoy the open sand. OHV riding is a multi-generational, social experience that connects participants to each other and the out of doors. Many families consider the opportunity to ride on the ODNRA unique and irreplaceable. OHV riders are also an important source of economic activity for coastal communities from Florence to Coos Bay. Riders travel long distances to reach the ODNRA and often stay for several days in campgrounds or hotels, purchasing supplies from local stores.

Management of the ODNRA is guided by the 1994 Oregon Dunes National Recreation Area Plan (the Dunes Plan). The Dunes Plan was adopted, following extensive public involvement and the completion of an environmental impact statement, as an amendment to the Siuslaw National Forest Land and Resource Management Plan (1990). The 1994 Dunes Plan updated and replaced the earlier 1979 Dunes Plan. The 1994 Dune Plan was appealed by 10 separate individuals or groups. Each appeal was reviewed by the Regional Office Reviewing Officer Richard Ferraro, Deputy Regional Forester at the time. In each case he affirmed the Forest 4Supervisor’s decision to amend the Siuslaw National Forest Plan with management direction for the ODNRA.

The Dunes Plan established separate management areas with differing resource emphases within the ODNRA. The Dunes Plan set the conditions for OHV use within each management area under Executive Order 11644 and 36 CFR Part 295. The 11 management areas, their primary emphases, and associated acres are as follows:

  • 10 (A) – Non-Motorized Undeveloped – 7,830 acres (27%) 
  • 10 (B) – Off-Road Vehicle Open – 5,930 acres (21%) 
  • 10 (C) – ORV on Designated Routes – 4,455 acres (15%) 
  • 10 (D) – Developed Corridors – 1,050 acres (4%) 
  • 10 (E) – Snowy Plover Habitat – 1,010 acres (3%) 
  • 10 (F) – Plant, Fish and Wildlife Habitat – 3,120 acres (11%) 
  • 10 (G) – Wetlands Emphasis – 2,540 acres (9%) 
  • 10 (H) – Wildlife and Fish Viewing – 315 acres (1%) 
  • 10 (J) – Recommended Wild and Scenic River – 1,090 acres (4%) 
  • 10 (K) – Research Natural Area – 1,190 acres (4%) 
  • 10 (L) – Noise Control Buffer – 370 acres (1%)
The Dunes Plan provides for public OHV use in two management areas: 
  • Management Area 10 (B) includes large areas of open sand and is managed primarily for recreational OHV use; 
  • Management Area 10 (C) is largely vegetated, and restricts OHV use to “designated routes.”

The Dunes Plan provides that MA 10 (C) be managed to “protect vegetated habitats while providing controlled opportunities for Off Road Vehicles (ORV) touring and traveling on designated routes.” The Dunes Plan further states that the goal for this management area is “to minimize OHV impacts on vegetated areas while allowing controlled opportunities for riding and travel through the area on designated routes for access to the beach and other areas which are open for OHV use.” Several routes in MA 10 (C) were identified and designated in the Dunes Plan itself. These include major access points to the open sand, many of which are signed and maintained. The Dunes Plan also called for the designation of additional routes within 3 years of Plan approval and the obliteration or naturalization of non-designated, largely user-developed, routes. In MA 10 (C), then, the Forest Service was directed to:

  • Designate those routes open to OHV use; 
  • Obliterate those routes not so designated; and 
  • Restrict OHV use to designated routes. 

Staffing and budget constraints delayed this effort, as the Siuslaw National Forest focused on implementing other direction from the Dunes Plan, including restrictions on alcohol use, management of sand camping, development of additional access at Riley Ranch, and recovery of the threatened snowy plover. These efforts have largely been successful: restrictions on alcohol have limited wild parties and kept the Dunes open to family recreation; sand camping remains safe, predictable, and available; the Riley Ranch campground and access trail are open and popular; and the plover populations are beginning to recover. However, the delay in designating routes in Management Area 10 (C) presents the Forest Service, counties, OHV riders, and other interested parties with several management challenges.

The Dunes Plan restricts OHV use in Management Area 10 (C) to designated routes, but the only formally designated routes are the major access trails. An extensive network of unauthorized, user-developed routes continues to be used and additional routes have probably developed. None of these (except the Riley Ranch Trail) have been designated for OHV use, but undesignated routes have not been enforced as closed and allowed to re-vegetate either.

The ODNRA is an area characterized by the rapid spread of predominantly non-native, invasive plant species, especially European beachgrass (Ammophila arenaria). Some of the userdeveloped routes evolved because they were popular, regularly-used travel ways and rapid vegetation encroached on either side making what was once open sand a vegetated area, with a now “unauthorized” motorized trail through it. Other trails, as in the Fingers area, involved the gradual breakdown of upland forests as riders sought out challenging riding experiences and hill climbs.

Without a complete formal route system or adequate signing and closure orders for most of MA 10 (C), use of undesignated routes and establishment of additional user-developed routes continues. Responsible riders cannot reliably tell where riding is appropriate. As a result, the majority of existing trails within MA 10 (C) today are not designated routes. This has, in turn, led to greater and unnecessary impacts to important plant communities within and adjacent to the MA 10 (C) areas.

In 2005, the Forest Service published a final Travel Management Rule (36 CFR Part 212, Subpart B), requiring every national forest to designate those roads, trails, and areas open to motor vehicle use. Forest Service regulations (36 CFR 261.13) now prohibit use of motor vehicles that is not consistent with the designations. The Siuslaw National Forest completed the Siuslaw Travel Management Project in 2009, and has published a motor vehicle use map each year since 2010. On most of the 630,000 acre Siuslaw National Forest, travel management was relatively simple and non-controversial. Cross-country motor vehicle use in steep, wet, densely forested lands is difficult if not impossible. However, the agency recognized in 2009 that route designation in the Oregon Dunes National Recreation Area was not complete, and would be much more complex. Until route designation is completed, OHV use on many established routes in MA 10 (C) is technically prohibited but unenforced under 36 CFR 261.13, an undesirable and unsustainable situation. The 2009 Siuslaw Travel Management Project decision pointed towards the Designated Routes Project to complete designation on the Oregon Dunes National Recreation Area.

This project redeems the Forest Service’s responsibility to implement the Dunes Plan, the Travel Management Rule, and Executive Order 11644 by designating routes within MA 10 (C), 6providing OHV access and reasonable, enjoyable connections between valued riding areas while minimizing impacts to adjacent and intervening native plant communities and habitat.

This decision is limited in scope. While it does include a non-significant amendment to the Dunes Plan, it does not attempt to re-draw the overall balance of motorized and non-motorized allocations in the ODNRA. The Dunes Plan established that overall zoning following extensive participation by OHV riders, county governments, the environmental community, and others. The 1994 Dunes Plan was itself founded on the preceding 1979 Dunes Plan, which was developed with the help of the original Advisory Committee called for under the legislation establishing the ODNRA.

OHV riding is a legitimate and appropriate use of the Oregon Dunes, consistent with the establishing legislation for the ODNRA. This decision does not close any area zoned in the Dunes Plan for open riding. Non-motorized recreation is also an appropriate use of the Oregon Dunes. This decision does not open to OHVs any area zoned in the Dunes Plan as nonmotorized. Rather, this decision addresses only Management Area 10 (C) – that portion of the ODNRA zoned for OHV use on designated routes only.


Based on my review of the alternatives and environmental impacts described in the Oregon Dunes NRA Management Area 10 (C) Designated Routes Project Final Environmental Impact Statement (FEIS), the comments on the DEIS submitted by other agencies and the public, the evaluation of objections submitted during the objection period, and other information available in the project record, I have selected Modified Alternative 4. The specific modifications to Alternative 4 are identified in this Record of Decision (ROD). 

The following summarizes the analysis completed by the interdisciplinary team of the differences between Modified Alternative 4 and Alternative 4 as analyzed in the FEIS. 
Modified Alternative 4 will: 
  • Designate an additional 2.3 miles of trails. This is the same as Alternative 4 in the FEIS. 
  • Reallocate 518 acres of Management Area 10 (C) to Management Area 10 (B), opening these lands to cross-country OHV use. This area contains 46 miles of user-developed routes. This is a modification of Alternative 4 in the FEIS because the reallocations of areas A3 and A16 have been changed, and an additional area has been added, A17. In the North Riding Area, reallocation A3 has been increased from 6 acres to 28 acres, containing 1.2 miles user-developed routes. I made this modification because it responded to the public’s concern about not having enough trail riding experiences in that area and it was close to sand camps sites 1, 2, and 3. Although A3 contains 78% native vegetation, OHV use should have a low impact on a majority of those acres because of difficult access and seasonal flooding. This area was historically open sand, and has been vegetated in response to stabilization of dunes by European beachgrass. Also in the north, I added 64 acres to A17 in order to respond to the public’s concern surrounding limited trail riding in that area. I feel it was appropriate to respond to this concern by adding acreage to A17 since that area does not have any native plant associations and it was historically open sand. In the Middle Riding Area, reallocation A16 has been reduced from 132 acres to 109 acres, containing 6.3 miles of user-developed routes. I felt that this reduction in acres was needed so I could respond to a public concern regarding user conflicts on the adjacent non-motorized beach.
This decision amends the Siuslaw National Forest Land and Resource Management Plan (Siuslaw Forest Plan; 1990) to: 
  • Provide for designation of 2.3 miles of trails beyond the 3-year window envisioned in the 1994 Dunes Plan; and 
  • Reallocate 518 acres from Management 10 (C) – ORVs on Designated Routes Only, to Management Area 10 (B) – Open Riding 

I have determined that this project-level Forest Plan amendment is not significant under regulations implementing the National Forest Management Act because it is very limited in geographic scope and does not affect the overall mix of goods and services provided from the Siuslaw National Forest.

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