Document 2JbMdL02a3mqZav91eLKQqNYb

Submitted electronically via regulations.gov June 12,2017 Mr. Mick Mulvaney, Director Office of Management and Budget 725 17th St., NW Washington, DC 20503 Re: Notice of Request for Comment on Government-wide Reform Dear Director Mulvaney: As representatives of the undersigned conservation organizations, we write to you today to express our strong support for continued and robust investment in the land management agencies1 -- the U.S. Forest Service, U.S. Fish and Wildlife Service, National Park Service, and the Bureau of Land Management (BLM) - and their conservation programs. Together, these agencies administer on behalf of the American people more than one billion acres of public lands and waters that attract over half a billion visitors annually.2 The undersigned organizations represent millions of Americans who deeply care about our public forests, grasslands, deserts and waters. Our members and supporters value these priceless public assets for the water and clean air they provide to communities, the outdoor recreation they offer, the wildlife they harbor, and the resources they contain. On March 13 2017, the President signed Executive Order 13781 directing you, as Director of the Office of Management and Budget (OMB), to develop a plan for reorganizing the executive branch, including recommending agencies, programs, and functions for elimination. Subsequently, you launched a 28-day comment period asking the American public to weigh in on how to reorganize, reduce, and eliminate federal agencies.3 While we disagree with the premise that drastic changes to our federal resource management agencies are necessary, to the extent that you intend to reorganize and possibly eliminate agencies, we respectfully request that you consider the economic importance of these agencies and their conservation programs - and not only retain them, but also ensure they are sufficiently funded. 1 While we use the term "land management agencies" we note that it reflects more broadly public lands and waters, including marine refuges. 1 See US Forest Service, 2012. National Visitor Use Monitoring Report. Available at: https://www.fs.fed.us/recreation/proerams/nvum/2012%20National Summary Report 061413.pdf. Page 24; National Park Service. Annual Visitation Highlights. Available at: https://www.nps.gov/subiects/socialscience/annual-visitation-highliehts.htm: Department of the Interior, Bureau of Land Management. 2015. Public Lands Statistics. Page 186; U.S. Fish & Wildlife Service, 2015. Annual Performance Report FY2015: National Wildlife Refuge System. Page 1. 382 Fed. Reg. 22355 (March 15, 2017). 1 Federal Land Conservation is a Smart Investment Our federal public land agencies administer on behalf of the American people more than one billion acres of land and water from Alaska to Florida and Maine to the South Pacific. The Bureau of Land Management, the National Park Service, the U.S. Forest Service and the U.S. Fish and Wildlife Service derive their management direction from their individual organic acts and other relevant guiding statutes that impose specific, congressionally mandated, constraints and duties. Specific to conservation, these include, among others, the Wilderness Act, the Wild and Scenic Rivers Act, the National Landscape Conservation System Act, the National Forest Management Act, the Federal Land Management and Policy Act, the National Wildlife Refuge System Improvement Act, the Endangered Species Act, the Clean Water Act, the Clean Air Act, the Multiple Use and Sustained Yield Act, the National Trails System Act, and the National Environmental Policy Act. Conservation of our public lands and waters is among the country's smartest investments, providing incredible value at low cost to taxpayers. The combined budget of the federal natural resource management agencies accounts for less than 0.4% of the nation's annual budget,4 yet provides the American people with benefits worth billions of dollars. Our federal lands and waters supply this nation with clean water and air, trails and campgrounds, fishing and hunting, life-saving habitat for thousands of imperiled species, and unparalleled outdoor experiences. While these services are not bought and sold in stores, they generate immense economic returns. Consider that national forests, the single largest source of municipal water supply, services more than 66 million people in 3,400 communities. The value of this water exceeds $7.2 billion annually.5 The National Wildlife Refuge System alone provides ecosystem services valued at $32.3 billion to nearby rural communities.6 In direct economic terms, our nation's lands and waters are the infrastructure for an outdoor recreation industry that contributes nearly $900 billion and 7.6 million jobs to the American economy.7 Further, federal public lands and waters are integral to sustaining healthy local economies. In today's economy many businesses are free to choose the location for their entrepreneurial endeavors. Federal public lands - and especially protected areas -- are important for attracting 4 Office of Management and Budget Historical Tables for Sub-Function 302. Available at: https://obamawhitehouse.archives.gov/omb/budget/Historicals . 5 USDA Forest Service. Information on Water Resources. Available at: https://www.fs.usda.gOv/wps/portal/fsinternet/cs/detail/lut/p/z0/04 Si9CPvkssv0xPLMnMz0vMAflio8ziiQwgwNHCwN DI8zPvBcqYKBfk02oCA BZcx5g/?position=Contribution%20Content.Html&pname=Forest%20Service&ss=119995&navtvpe=SubNavig3tion&pnavid=110140100000000 &navid=110140110000000&ttype=detail&cid=stelprdb5107778. 6 Southwick Associates, 2011. The Economics Associated with Outdoor Recreation, Natural Resources Conservation and Historic Preservation in the United States For: The National Fish and Wildlife Foundation. Available at: https://www.fws.gov/refuges/news/pdfs/TheEconomicValueofOutdoorRecreation%5Bl%5D.pdf. 6 Outdoor Industry Association, 2017. The Outdoor Recreation Economy. Page 11. Available at: https://outdoorindustrv.org/resource/2017outdoor-recreation-economv-report/. 7 Outdoor Industry Association, 2017. The Outdoor Recreation Economy. Available at: https://outdoorindustrv.org/resource/2017-outdoorrecreation-economv-report/ 2 and retaining talented workers, entrepreneurs and investors. Rural counties with greater proportions of protected public lands have higher incomes, higher employment levels and greater population growth than rural counties without such lands.8 Chronic Underfunding is Undermining Effectiveness of Natural Resource Agencies Over the last few decades, our public lands agencies have suffered a decline in real budgets for critical programs and dwindling workforces. This has led to many difficult decisions: reduced visitor services and recreational investments, reduced scientific research and monitoring, compromised conservation and management, growing maintenance backlogs, and other impacts. For instance, between 1995 and 2015, the funding for the National Forest System has been reduced by 32% in real dollars, and the agency's staffing dropped by almost 40% between 1998 and 2015.9 This is in part due to the growing cost of wildfire suppression, which now consumes more than 50% of the agency's budget.10 Recent employee surveys reflect the impacts of chronic underfunding and staffing. A recent survey by Public Employees for Environmental Responsibility (PEER), a national organization representing federal, state and local government professionals, found that 67 percent of BLM employees believe the agency does not have enough resources to accomplish its mission.11 The survey asked how the administration could best improve the BLM. Responses included: "No hiring freeze" "NOT implementing a hiring freeze - that would be a disaster" "Do notfurther cut ourfunding. I have 1.8 million acres ofland in myfield office to manage and I am the only natural resources staff member" "Some people are doing 2-3 jobs just to get the job done." "Funding to fill vacant positions - more than 20 in our office." A similar survey of national wildlife refuge managers revealed that 94 percent of respondents were concerned that staffing at their refuge was inadequate to meet their core mission: "Addressing the chronic funding shortages that prevent us from adequately staffing our refuges." "Providing resources to address our maintenance backlog and better serve the members of the public" "Not do an across-the-board federal govt, cut which would devastate our tiny agency" 8 Headwaters Economics, 2017. Federal Public Lands in the West: Liability or Asset. Available at: https://headwaterseconomics.ore/publiclands/federal-lands-performance/. 9 USDA Forest Service, 2015. The Rising Cost of Fire Operations: Effects on the Forest Service's Non-Fire Work. August 4, 2015. Available at: https://www.fs.fed.us/sites/default/files/201S-Fire-Budeet-Report.pdf. 10 Id. 11 https://www.peer.ore/news/news-releases/trump-hirine-freeze-hamstrines-his-own-aeenda.html. 3  "Increasing funding for the NWR system so we can hire employees to accomplish our mission" "The loss of staff has impacted all aspects of the National Wildlife Refuge System. The system no longer shines like it did 20-30 years ago" Specific Functions Deserving Enhanced Support and Prioritization Given the clear importance of conservation and recreation on public lands and waters to our socio-economic well-being, we urge you not to cut - and instead bolster investment in - the following programmatic functions. Recreation and Wilderness. Federal outdoor recreation and wilderness programs enable Americans to get outside and enjoy their national forests, wildlife refuges and other public lands through a wide variety of activities. They promote public health, enhance community well-being, unite families and friends, and foster citizenship of our nation's natural resources. Investments promote access for hunters and anglers to world class fish and game habitat, and support local economies by attracting entrepreneurs and amenity-based businesses such as outfitters and gear shops. Specific programs that should be prioritized include: The Forest Service Recreation, Wilderness, and Heritage program whose funding has shrunk by 15% since 2001, even though recreation participation continues to steadily increase and is projected to increase by 30% for most activities by 2030.12 The Forest Service Capital Improvement and Maintenance program, which supports maintenance of ~21,600 recreation sites, ~371,000 miles of roads, and ~157,000 miles of trails, and is essential to address serious public health and safety concerns, maintain public access to rural communities, and protect clean drinking water for 66 million Americans. Since 2001, funding for roads, deferred maintenance, and facilities shrank by 46%, 95%, and 68%, respectively; funding for the Legacy Roads and Trails program has been halved since 2010. Such severe reductions force the agency to close recreational facilities and access roads. The BLM National Landscape Conservation System that comprises over 30 million acres of some of the most scenic and expansive landscapes in our country, including national conservation areas, wilderness areas and other designations that attract visitors and help sustain healthy local economies. The BLM Recreation Resources Management program that enhances recreation access for all visitors to BLM lands, engages youth, promotes public health, protects visitor safety and strengthens rural economies. The Fish and Wildlife Service National Wildlife Refuge System that comprises 566 national wildlife refuges with at least one in every state and territory, includes over 20 12 USDA Forest Service. 2016. Federal Outdoor Recreation Trends: Effects of Economic Activities. PNW-GTR-945. Available at: http://www.coloradotpa.orB/wp-content/uploads/2017/02/USFS-Econ-lmpacts-Rec.pdf. 4 million acres of wilderness, and prioritizes wildlife-dependent recreation for all Americans to enjoy. Wildlife viewing, photography, hunting, fishing, environmental education and interpretation are hallmarks of the Refuge System, deemed priority public uses when compatible with wildlife conservation. The Fish and Wildlife Service Urban Wildlife Conservation Program, a visionary partnership that helps urban constituencies discover, appreciate and care for wildlife and nature in their communities. Land planning and restoration. Resource management planning is the foundation of an agency's stewardship responsibilities. Statutorily required, planning is necessary to ensure our public lands and waters continue providing the American people an array of benefits, including wildfire management, wildlife and fish habitat, outdoor recreation, clean water, and jobs. Management planning lays the groundwork for ecological restoration that improves the health of our lands and waters while injecting funds and jobs into local communities. Reduced investment impairs stakeholder engagement and collaborative decision-making that can support enduring and science-based management. Specific programs that should be prioritized include: The Forest Service Land Management Planning, Assessment, and Monitoring programs that are crucial for better wildfire management and restoration has shrunk by 44% since 2001. Land management planning is conducted in close collaboration with a national federal advisory committee comprised of diverse stakeholders charged with advancing sound implementation of the 2012 planning rule. The Forest Service Wildlife and Fisheries Habitat Management program that conserves, restores and enhances habitat for fish, wildlife, and rare plants. It is vital to the 3,500 imperiled and at-risk species that depend on national forest lands for their survival, and supports recreational fishing, hunting and wildlife viewing on national forest lands. The Forest Service Collaborative Forest Landscape Restoration Program that incentivizes long-term collaborative forest restoration. The National Greater Sage-Grouse Planning Strategy that is predicated on the concept of "saving" a species before it requires federal protection. Continued implementation of this strategy is important for the recovery of this critical western game species and those who rely on its habitat for their livelihood. BLM Master Leasing Plans, in which BLM evaluates potential conflicts and impacts on lands prior to leasing, leading to less conflict, better resource management, and more certainty. Increasing leasing and permitting without supporting environmental review and planning, including master leasing plans, will lead to more conflict, protests and litigation, and ultimately diminish the long-term sustainable flow of benefits into local communities and regions. Renewable energy. Support and funding should continue for BLM's smart renewable energy program that supports development of sustainable, clean energy sources that make sense for 5 all Americans, and reduces our nation's carbon footprint. The program helps projects succeed in low-conflict areas, reducing impacts and cutting permitting times in half.13 Renewable energy continues to increase its market share in the energy arena as technology improves and costs continue to plummet, and drive strong job growth. A 2017 report by the Department of Energy found that solar energy supports 373,807 jobs, more than the jobs in the provision of natural gas (362,118) and over twice as many jobs in coal mining (160,119).14 Wind energy is also seeing strong job creation, supporting 101,738 jobs. Continued strong funding for the BLM Renewable Energy Program and other related programs within DOI agencies will support these economic and clean energy opportunities in a smart and responsible way. Transparency and Public Engagement is Integral to Long-Term Success Federal lands and waters are owned by all Americans. The federal land management agencies administer them on our behalf following the direction prescribed in the guiding statutes and through numerous programs developed over many years, often with extensive stakeholder involvement. While there is benefit in legitimate processes designed to improve program delivery, such exploration and subsequent administrative shifts will only succeed if the public is engaged and the process is transparent. To that end, we respectfully request that you share draft reorganization plans with the public in a way that allows for meaningful review and comment, and that you publicize the decision-making criteria and evaluative process. In particular, for each agency, it would be very helpful to better understand: The criteria to be used by OMB to make decisions related to the reform or elimination of agencies and their functions; How public comments will be incorporated into the decision-making process; How non-market benefits and public value will be accounted for in cost-benefit analyses; When OMB will share a draft report with the public for meaningful comment and feedback; and How OMB will ensure that administrative shifts (e.g., elimination of programs, reductions in workforce) will not impair the ability of agencies to meet their statutory and regulatory responsibilities. 13 See https://www.doi.eov/pressreleases/interior-department-approves-first-solar-energy-zone-proiects 14 See https://enerev.eov/sites/prod/files/2017/01/f34/2017%20US%20Enerev%20and%20Jobs%20Report O.pdf. 6 Thank you for considering these comments. With regards, Nada Culver Senior Counsel and Senior Director, Agency Planning and Policy Department The Wilderness Society 1660 Wynkoop, #850 Denver, CO 80202 303-225-4635 Nada_culver@tws.org Peter Nelson Director of Federal Lands Defenders of Wildlife 215 S. Wallace Ave Bozeman, MT 59715 406-556-2816 pnelson@defenders.org Susan Jane Brown Staff Attorney Western Environmental Law Center 503-914-1323 brown@westernlaw.org Athan Manuel Director of Lands Protection Program Sierra Club 50 FSt NW, Eighth Floor Washington DC, 20001 202-548-4580 athan.manuel@sierraclub.org Cc: The Flonorable Ryan Zinke, Secretary of the Department of the Interior The Flonorable Sonny Perdue, Secretary of the US Department of Agriculture 7 June 12, 2017 Mr. Mick Mulvaney, Director Office of Management and Budget 725 17th St., NW Washington, DC 20503 Dear Director Mulvaney: The undersigned companies and organizations represent members of the outdoor industry whose businesses depend on outdoor recreation that takes place on America's public lands. Our customers hike, camp, mountain bike, ski, climb, and paddle in the great outdoors and their participation in these activities depends on having access to federal public lands and waters. On March 13th 2017, the President signed Executive Order 13781 directing you to develop a plan for reorganizing the executive branch including recommending agencies, programs, and functions for elimination. Subsequently, you launched a 28-day comment period asking the American public to weigh in on how to reorganize, reduce, and eliminate agencies. We write to you today to express our strong support for continued and robust investment in the conservation and recreation programs of the land management agencies: the U.S. Forest Service, U.S. Fish and Wildlife Service, National Park Service, and the Bureau of Land Management. Together, these agencies administer on behalf of the American people 674 million acres of lands that see over half a billion visits annually.1 They are the stewards of our national parks, forests, wildlife refuges, monuments, and rivers, including remarkable places such as the Grand Canyon, the Wind River mountains, Yosemite, the Appalachian Trail, and the Everglades. For a modest investment (less than 0.4% of the federal budget), our federal land management agencies generate innumerable benefits worth billions of dollars. These agencies build and maintain trails, campgrounds, and other recreation infrastructure and manage federal lands to provide unbeatable outdoor recreation experiences. Due to the stewardship of our federal land agencies, federal public lands fuel a robust outdoor recreation economy valued at $887 billion annually, which supports 7.6 million jobs.2 Funding these agencies has an outsized impact and is a great investment for the American people. Recreational visits to parks, forests, refuges, and other public lands generate $33 billion in direct spending and nearly 600,000 jobs, and contribute $37 billion to GDP annually.3 Without increased support for federal land management agencies, however, recreation infrastructure will fall into disrepair and access 1 See US Forest Service, 2012. National Visitor Use Monitoring Report. Available at: https://www.fs.fed.us/recreation/programs/nvum/2012%20National_Summary_Report_061413.pdf. Page 24; National Park Service. Annual Visitation Highlights. Available at: https://www.nps.gov/subiects/socialscience/annual-visitation-highlights.htm: Department of the Interior, Bureau of Land Management. 2015. Public Lands Statistics. Page 186; U.S. Fish & Wildlife Service, 2015. Annual Performance Report FY2015, National Wildlife Refuge System. Page 12. Available at: F 2 Outdoor Industry Association, 2017. The Outdoor Recreation Economy. Available at: https://outdoorindustrv.org/resource/2017-outdoor-recreation-economv-report/ 3 U.S. Department of the Interior Economic Report, FY 2015. Prepared by the Department of the Interior Office of Policy Analysis, June 17, 2016. Available at: https://www.doi.gov/sites/doi.gov/files/uploads/fy2015_doi_econ_report_2016-0620.pdf. Table 2-2. See also US Forest Service, 2012. National Visitor Use Monitoring Report. Available at: https://www.fs.fed.us/recreation/programs/nvum/2012%20National_Summary_Report_061413.pdf. Page 24. to public lands will be curtailed, diminishing the return on investment in the long run and handicapping our industry. We have already seen this come to pass in many areas across the country as a result of chronic underfunding. Outdoor recreationists understand the link between healthy lands and healthy lifestyles. We therefore urge you not to cut - and in fact invest more - in the conservation and recreation programs administered by the US Forest Service, Bureau of Land Management, US Fish and Wildlife Service, and the National Park Service. Likewise, we fully support the Environmental Protection Agency, as it ensures our public lands continue to provide clean air, clean water, and a healthy enviornment. While we disagree with the premise that drastic changes to our federal land management agencies are necessary, to the extent that you intend to reorganize and possibly eliminate agencies, we respectfully request that you consider the importance of the federal land management agencies and their conservation and recreation programs. These include, but certainly are not limited to, the 1) Forest Service's Recreation, Wilderness, and Heritage; Legacy Roads and Trails; Trails; Land Management Planning, Assessment, and Monitoring; and Fisheries and Wildlife Habitat Management Programs; 2) the BLM's Recreation Resources Management, National Landscape Conservation System; 3) The Operation of the National Park System, National Recreation and Preservation, and many other accounts within the National Park Service budget; and 4) Cross-cutting programs like the Land and Water Conservation Fund. Thank you for considering these comments. Sincerely, Alaska Heather Szundy Owner/CFO Ascending Path Girdwood & Anchorage, AK Tim Bourcy President Packer Expeditions LTD Skagway, AK California Brendan Madigan Founder/race director Alpenglow Mountain Racing, LLC Tahoe City, CA Keely Wachs Communications Director Clif Bar & Company Emeryville, CA Brendan Madigan Owner Alpenglow Sports, Inc. Tahoe City, CA Kenji Haroutunian President Friends Of Joshua Tree Joshua Tree, CA Emily HargravesOwner Backcountry Babes Truckee, CA Douglas Stoup President Ice Axe Expeditions Truckee, CA Chris Carr Director Shasta Mountain Guides Mount Shasta, CA Steve Frisch President Sierra Business Council Truckee, CA Colorado Ryan Koupal Founder/Director 40 Tribes Backcountry Adventures Boulder, CO Penn Newhard Partner Backbone Media Carbondale, CO Nicholas Legare Sales Manager Native Eyewear Longmont, CO Chris Conroy President Yeti Cycles Golden, CO Idaho Chris Valiante Owner 22 Designs Driggs, ID Tyson Stellrecht Owner/CEO Backcountry Pursuit, LLC Boise, ID Carl Co-Founder STOKE Certified San Diego, CA David Polivy Owner Tahoe Mountain Sports Truckee, CA Cindy Farny Owner High Camp LLC Telluride, CO Eric Greene Division VP/GM Kelty Boulder, CO Steve Lentz President Far and Away Idaho Michelle Reagan President Gravity Sports McCall, ID Jeff Lewerenz Partner Greenwood's Ski Haus Boise, ID Chris Haunold President Idaho Mountain Touring Boise, ID Illinois Randy Neufeld SRAM Cycling Fund Director SRAM LLC Chicago, IL Maine Dave MacLeay Publisher Trailspace.com Belgrade Lakes, ME Montana Austin Hart Owner / Guide Beartooth Mountain Guides, Inc. Red Lodge, MT Benjamin D Zavora Owner Beartooth Powder Guides LLC Cooke City, MT Marne Hayes Executive Director Business for Montana's Outdoors Montana Kelli Hart Owner Freeheel and Wheel West Yellowstone, MT Chris Lundy Owner Sawtooth Mountain Guides Stanley, ID Bob Rosso Owner The Elephant's Perch Ketchum, ID Linda Hersom green peak promotions Whitefish, MT Drew Pogge Owner/Guide Montana Alpine Adventures Bozeman, MT Sam Magro Owner/Lead Guide Montana Alpine Guides, Inc Bozeman, MT Kate Ketschek Founder, President Revolution House Media Big Sky, MT Hans Howell Owner Roscoe Outdoor LLC Red Lodge, MT New York Vinny McClelland Owner/Manager The Mountaineer Keene Valley, NY Oregon Russ Plaeger Restoration Coordinator Bark Portland, OR Tyler LaMotte VP Global Brand Marketing KEEN Footwear Portland, OR Utah Dan Benshoff Marketing Director DPS Skis Salt Lake City, UT Vermont Ted Manning CEO Ibex Outdoor Clothing White River Junction, VT Washington Dave Fitzgerald President Chillaz North America Bainbridge Island, WA Dale Sexton President TimberTrails Livingston, MT Kat Dierickx CMO Outdoor Project Portland, OR Daniel McGarigle President Pine Mountain Sports Bend, OR Tristan von Duntz Events Director Onion River Sports Montpelier, VT Dan Nordstrom CEO Outdoor Research Seattle, WA Eric Hayes CMO Superfeet Worldwide Bellingham, WA Wyoming Jamie Schectman CEO Mountain Rider's Alliance Jackson, WY Diane Verna Owner/guide Teton Backcountry Guides Alta, WY cc. Honorable Ryan Zinke, Secretary of the Interior Honorable Sonny Perdue, Secretary of Agriculture Senate Interior Appropriations Committee House Interior Appropriations Committee June 12, 2017 Mr. Mick Mulvaney, Director Office of Management and Budget 725 17th St., NW Washington, DC 20503 Dear Director Mulvaney: The 124 undersigned organizations represent millions of Americans who partake in outdoor recreation on this nation's forests, parks, and other public lands. Our members ski, climb, mountain bike, paddle, hike, and camp on public lands and they reap enormous benefits from these experiences. To pursue these activities, our members depend on having access to federal lands where they can immerse themselves in nature with their friends and families, away from urban areas and development. On March 13th 2017, the President signed Executive Order 13781 directing you to develop a plan for reorganizing the executive branch including recommending agencies, programs, and functions for elimination.1 Subsequently, you launched a 28-day comment period asking the American public to weigh in on how to reorganize, reduce, and eliminate agencies.2 We write to you today to express our strong support for continued and robust investment in the conservation and recreation programs of the land management agencies: the U.S. Forest Service, U.S. Fish and Wildlife Service, National Park Service, and the Bureau of Land Management. Together, these agencies administer on behalf of the American people 674 million acres of lands that see over half a billion visits annually.3 For a modest investment (less than 0.4% of the federal budget), our federal land management agencies generate innumerable benefits worth billions of dollars. They provide us clean water and air, trails and campgrounds, and unmatchable outdoor recreation experiences. Most importantly, they provide the recreation infrastructure and opportunities that fuel a $887 billion outdoor recreation economy that generates 7.6 million jobs.4 In the 12 Western states alone, the agencies manage 193,500 miles of hiking trails and 12,659 miles of mountain bike trails. Likewise, virtually all backcountry skiing, 43% of whitewater paddling, and 71% of climbing in the West occurs on lands managed by these agencies5. Funding the recreation and conservation programs of these agencies has an outsized impact and is a great investment for the American people. Consider that recreational visits to parks, forests, refuges, and other public lands generate $33 billion in direct spending and nearly 600,000 jobs, and contribute $37 billion to GDP annually.6 Consider also that the clean water that our national forests provide to over 66 1 https://www-whitehouse.gov/the-press-office/2017/03/13/presidential-executive-order-comprehensive-plan-reorganizine-executive 2 82 Fed. Reg. 22355 (March 15, 2017) J See US Forest Service, 2012. National Visitor Use Monitoring Report. Available at: https://www.fs.fed.us/recreation/programs/nvum/2012%20National Summary Report 061413.pdf. Page 24; National Park Service. Annual Visitation Highlights. Available at: httos://www.nps.gov/subiects/socialscience/annual-visitation-highlights.htm: Department of the Interior, Bureau of Land Management. 2015. Public Lands Statistics. Page 186; U.S. Fish 8i Wildlife Service, 2015. 4 Outdoor Industry Association, 2017. The Outdoor Recreation Economy. Available at: https://outdoorindustrv.org/resource/2017-outdoorrecreation-economv-report/ 5 Data from Winter Wildlands Alliance, American Whitewater, and Mountain Project 6 U.S. Department of the Interior Economic Report, FY 2015. Prepared by the Department of the Interior Office of Policy Analysis, June 17, 2016. Available at: https://www.doi.gov/sites/doi.gov/files/uploads/fy2015_doi_econ_report_2016-06-20.pdf. Table 2-2. See also US Forest Service, 2012. National Visitor Use Monitoring Report. Available at: https://www.fs.fed.us/recreation/programs/nvum/2012%20National_Summary_Report_061413.pdf. Page 24. million people in 3,400 communities in 33 states is worth over$7.2 billion annually.7 In that same vein, clean air, clean water and other ecological services provided by our National Wildlife Refuges provide $32.3 billion in benefits to local communities.8 Outdoor recreationists understand the link between healthy lands and healthy lifestyles. We therefore urge you not to cut - and in fact invest more - in the conservation and recreation programs administered by the US Forest Service, Bureau of Land Management, US Fish and Wildlife Service, and the National Park Service. Likewise, we fully support the Environmental Protection Agency. The EPA and its programs ensure that our public lands provide clean air, clean water, and a healthy environment. Without the EPA our public lands will lose these essential qualities. While we disagree with the premise that drastic changes to our federal land management agencies are necessary, to the extent that you intend to reorganize and possibly eliminate agencies, we respectfully request that you consider the importance of the federal land management agencies and their conservation and recreation programs. These include, but certainly are not limited to, the 1) Forest Service's Recreation, Wilderness, and Heritage; Legacy Roads and Trails; Trails; Land Management Planning, Assessment, and Monitoring; and Fisheries and Wildlife Habitat Management Programs; 2) the BLM's Recreation Resources Management, National Landscape Conservation System; 3) The Operation of the National Park System, National Recreation and Preservation, and many other accounts within the National Park Service budget; and 4) Cross-cutting programs like the Land and Water Conservation Fund. Thank you for considering these comments. Sincerely, Adam Cramer Executive Director Outdoor Alliance Washington D.C. On behalf of the following organizations: Alaska Brian Okonek President Alaska Quiet Rights Coalition Anchorage, AK 7 USDA Forest Service. Information on Water Resources. Available at: https://www.fs.usda.gOv/wos/portal/fsinternet/cs/detail/iut/p/z0/04 Si9CPvkssv0xPLIVlnMz0vMAflio8ziiQwgwNHCwN DI8zPvBcqYKBfk02oCA BZcx5g/?position=Contribution%20Content.Html&pname=Forest%20Service&ss=119995&navtvpe=SubNavigation&pnavid=110140100000000 &navid=110140110000000&ttvpe=detail&cid=stelprdb5107778 8 Southwick Associates, 2011. The Economics Associated with Outdoor Recreation, Natural Resources Conservation and Historic Preservation in the United States For: The National Fish and Wildlife Foundation. Available at: https://www.fws.gov/refuges/news/pdfs/TheEconomicValueofOutdoorRecreation%5Bl%5D.pdf Alabama Tom Nelson, DVM President Northeast Alabama Bicycle Association Annsiton, AL Mary Anne Swanstrom President SORBA Huntsville Huntsville, AL Arizona Lorraine Montuori President Desert Foothills Mountain Bike Association Cave Creek, AZ Brent Roberts Board President Prescott mountain Bike Alliance Prescott, AZ California Steve Messer President Concerned Off-Road Bicyclists Association Los Angeles, CA Nate Greenberg President Eastern Sierra Avalanche Center Mammoth Lakes, CA Kenji Haroutunian President Friends Of Joshua Tree Joshua Tree, CA Darrel Jury President Friends of Plumas Wilderness Meadow Valley, CA James Wells President Southeastern Alabama Mountainbikers Dothan, AL Joe Fuller Chapter President West Alabama Mountain Bike Association Tuscaloosa, AL Michael Bonnette President Rim Country Mountain Biking Association Payson, AZ Wendy Schneider Executive Director Friends of the Inyo Bishop, CA Tom Johnson Board President Mammoth Lakes Recreation Mammoth Lakes, CA John Wentworth President/CEO Mammoth Lakes Trails and Public Access Foundation Mammoth Lakes, CA Geoffrey McQuilkin Executive Director Mono Lake Committee Lee Vining, CA Kevin Loomis President San Diego Mountain Biking Association San Diego, CA Steve Larson President SHARE Mountain Bike Club Corona Del Mar, CA David Reichel President Tahoe Backcountry Alliance South Lake Tahoe, CA Colorado Erik Murdock Policy Director Access Fund Boulder, CO Jonathan Cox President Advance Colorado Fund - Bailey Hundo Palmer Lake, CO Maria Povec Policy Director American Alpine Club Golden, CO Jason Bertolacci Co-founder berbur, lie Denver, CO Greg Williams Executive Director Sierra Buttes Trail Stewardship Graeagle, CA Alan Jacoby Board President Sierra Eastside Mountain Bike Association (SEMBA) Mammoth Lakes, CA Marcus Libkind President Snowlands Network Campbell, CA Suzanne Webel President Boulder Area Trails Coalition Boulder, CO J.B. Haab Boulder Climbing Community Boulder, CO Steven Watts Executive Director Boulder Mountainbike Alliance Boulder, CO Kate Rau Executive Director Colorado High School Cycling League Boulder, CO Gary Moore Executive Director Colorado Mountain Bike Association Denver, CO Julie Mach Conservation Director Colorado Mountain Club Golden, CO Keith Bauer Executive Director Crested Butte Nordic Crested Butte, CO Robert Andrew President Cyclists 4 Community Boulder, CO Adam Haid Founder/ Board Member Erie Singletrack Advocates Erie, CO Nicholas Jimroglou President High County River Rafters Wheat Ridge, CO Al Head Stewardship Coordinator The Golden Giddyup Golden, CO Delaware Dave Ellegood President Cape Fear SORBA Wilmington, DE David Wiens Executive Director International Mountain Bicycling Association Boulder, CO Kenny Bearden Executive Director Overland Mountain Bike Club Fort Collins, CO Lindsay Bourgoine Manager, Advocacy & Campaigns Protect Our Winters Boulder, CO Mike Pritchard Executive Director Roaring Fork Mountain Bike Association Aspen, CO Mike Smith Board Member Salida Mountain Trails Salida, CO Maureen Hall President Silent Tracks Crested Butte, CO Florida Kevin Phelps Trail Director Flagler Area Biking SORBA Palm Coast, FL Joseph Schwarz Board Member Florida Mudcutters Fort Myers, FL Georgia Brett Davidson President Atlanta Chapter of the Southern Off Road Bicycle Association Atlanta, GA Andrew Kloster President CVA SORBA Columbus, GA Mike Palmeri President Ellijay Mountain Bike Association Ellijay, GA Lisa Broughton President Gwinnett Area Trail Riders Lawrenceville, GA Woody and Kathy Wood Owners Woody's Mountain Bikes Helen, GA Jared Hartman President Ocala Mountain Bike Association Ocala, FL Jose Sanchez President Tallahassee Mountain Bike Association Tallahassee, FL Lisa Randall Owner Mountain Goat Adventures Canton, GA Chris Sieverson President SORBA West Georgia Hiram, GA Jay Wilkes President SORBA Woodstock Woodstock, GA Tom Sauret Executive Director Southern Off-Biciyle Association Gainesville, GA Idaho John Robison Public Lands Director Idaho Conservation League Boise, ID Sarah Michael President Nordic and Backcountry Skiers Alliance of Idaho Sun Valley, ID Tim Adams Executive Director Teton Valley Trails And Pathways Driggs, ID Mississippi Timothy Phelps President North Mississippi Trail Alliance Olive Branch, MS Montana Tom Kohley Chairman Beartooth Recreational Trails Association Red Lodge, MT Lance Pysher President Bitteroot Backcountry Cyclists Hamilton, MT Greg Peters President Montana Backcountry Alliance Missoula, MT Ben Horan Executive Director MTB Missoula Missoula, MT Mark Menlove Executive Director Winter Wildlands Alliance Boise, ID Brett Stevenson Board Chair Wood River Bicycle Coalition Sun Valley, ID Jeremy Polk President Tri-County Mountain Bike Association Madison, MS Hilary Eisen Member Representative Outdoor Alliance Montana Bozeman/Missoula, MT Chad Broderius Chair Pedal United Billings/Red Lodge, MT Ian Jones President Southwest Montana Mountain Bike Association Bozeman, MT Claudine Tobalske WMTCC Chair Western Montana Climbers Coalition Missoula, MT North Carolina Kevin Colburn National Stewardship Director American Whitewater Cullowhee, NC John Gannon President Nantahala Area Southern Off-Road Bicycling Association Cullowhee, NC Jack Brown President Northwest North Carolina Mountain Bike Alliance Lenoir, NC New Hampshire Tyler T. Ray Granite Chief Granite Backcountry Alliance North Conway, NH New Jersey Ellen Moskowitz Trustee Kayak and Canoe Club of New York New Jersey New Mexico Daniel Roberts President Albuquerque Mountain Bike Association Albuquerque, NM Shelley Longmire Current board member Santa Fe Fat Tire Society Santa Fe, NM Stephen C. Williams President Piedmont Fat Tire Society Greensboro, NC Emily Watts President Tarheel Trailblazers Charlotte, NC David Houskeeper President Triangle Off-Road Cyclists Morrisville, NC Mary Ann DeBoer President Chama Valley Outdoor Club Chama, NM Nevada Paul W. Papa President Southern Nevada Mountain Bike Association (SNMBA) Las Vegas, NV New York Rob Cook President Cycle-CNY: Chapter of International Mountain Bicycling Association Ithaca, NY Christine Guarino Vice President Fats in the Cats Kingston, NY Christopher Trombley Program Director NYCMTB New York, NY Margaret Siller Treasurer Zoar Valley Paddling Club Buffalo, NY Oregon Russell Plaeger Restoration Coordinator Bark Portland, OR Chris Rotvik President Northwest Trail Alliance Portland, OR Lance Colburn Secretary Blue Mountain Singletrack Trails Club La Grande, OR Russ Pascoe Board member Oregon Kayak and Canoe Club Portland, OR Russell Pascoe Conservation Chair Lower Columbia Canoe Club Portland, OR Robert Alan Ping Chief Instigator and NCIA race league director Oregon Youth Mountain Biking Portland, OR Adam Baylor Stewardship and Communications Manager Mazamas Portland, OR Wayne Clark Board President Team Dirt Corvallis, OR Pennsylvania Lisa Zaverack President Anthractite Mountain Pedalers Forty Fort, PA David A. Kurtz Assistant Scoutmaster Boy Scout Troop 32 State College, PA South Carolina Steve Masone President Midlands SORBA Columbia, SC Tennessee Jason Campbell President SORBA Mid TN Nashville, TN Utah Tracy Bentley Shop Owner Chile Pepper Bike Shop Moab, UT Lukas Brinkerhoff President Dixie Mountain Bike Trails Association St. George, UT Chris Adams Board President Wasatch Backcountry Alliance Salt Lake City, UT David A. Kurtz President and Chief Coach Mach One Slalom Team Bellefonte, PA Cat Newsom President Southeastern Pennsylvania Trail Riders Philadelphia, PA Tracy Bentley Board Chair Moab Mountain Bike Association Moab, UT Trina Hedrick Secretary-Treasurer Northeastern Utah Mountain Bikers Vernal, UT Virginia Mike Aronoff Owner Canoe Kayak and Paddle Co. LLC Vienna, VA Greg Rollins President rvaMORE Richmond, VA Washington Gus Bekker President El Sendero Backcountry Ski and Snowshoe Club Wenatchee, WA Yvonne Kraus Executive Director Evergreen Mountain Bike Alliance Seattle, WA John Latta Founder Inland Northwest Backcountry Alliance Spokane, WA Jon Hoekstra Executive Director Mountains to Sound Greenway Seattle, WA David Mainer President Paddle Trails Canoe Club (200+ members) Seattle, WA Ernest Rodriguez President Mid-Atlantic Off-Road Enthusiast (MORE) Fairfax, VA Luke Bakken Conservation Committee Chair Spokane Mountaineers Spokane, WA Jennie Goldberg Director The League of Northwest Whitewater Racers Seattle, WA Katherine Hollis Conservation and Advocacy Director The Mountaineers Seattle, WA Shanna Gachen Membership Chair Washington Kayak Club Seatttle, WA Andrea Imler Advocacy Director Washington Trails Association Seattle, WA Wyoming Charles Manganiello Executive Director Togwotee Backcountry Alliance Lander, WY Marco Restani Executive Director Wyoming Wilderness Association Sheridan, WY cc. Honorable Ryan Zinke, Secretary of the Interior Honorable Sonny Perdue, Secretary of Agriculture Senate Interior Appropriations Committee House Interior Appropriations Committee