Washington Department of Fish and Wildlife Commission

Mark Quinn, Lands Division Manager, WDFW

600 Capitol Way North
, WA 98501-1091






Mr. Mark Quinn and the Washington Department of Fish and Wildlife Commission,


I am writing in regards to the Washington Department of Fish and Wildlife (WDFW) and Mark Quinn regarding the proposed new chapter 13 in the Washington Administrative Code (WAC) 232 which will regulate public use and conduct on WDFW managed public land.


I reviewed the details of this proposal and I have some serious concerns with some of the language contained in a portion of this proposed WAC.


I am concerned with section WAC 232-13-200 (Vehicle use). This section states:


“Except for permitted use by persons with disabilities, or for persons holding valid grazing permits or agricultural leases on department lands, it is unlawful to possess or operate any motorized vehicle, including snowmobiles, on or across department lands, except on roads, unless posted otherwise.”


Snowmobiles should not be grouped into the same category as other motorized vehicles. They do not compact soil, as snowmobiles ride on a blanket of snow.


The 2005 OHV Final Rule recently implemented by the Forest Service (FS) and documented in 36 Code of Federal regulations (CFR) Parts 212, 251, 261, and 295, specifically exclude snowmobiles from the requirement to remain on existing roads and/or trails. It states in part … the Department believes that cross-country use of snowmobiles presents a different set of management issues and environmental impacts than cross-country use of other types of motor vehicles. Therefore, the final rule exempts snowmobiles from the mandatory designation scheme provided for under § 212.51…


Having snowmobile use regulations change from being legal in one section of FS managed public land, only to become illegal in an adjacent section of WDFW managed public lands, does not make logical sense. It would be impractical for WDFW to expect the recreating public to be able to know when they are crossing into WDFW managed public lands, so that they could attempt to abide by this policy, and it would be a management nightmare for WDFW employees to attempt to enforce.


Management of this policy will be especially troublesome in large WDFW managed public lands such as the 88,000 acre Colockum Wildlife Area and the 42,000 acre L.T. Murray Wildlife Area where checkerboard land ownership and management changes from section to section.


Thank you for the opportunity to comment on this proposal.