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TPA, COHVCO & RMEC Respond to the Gunnison Basin Travel Management Plan


June 1, 2009

Subject: This is the joint TPA/COHVCO/RMEC comments to the Gunnison Basin Federal Lands Travel Management Draft Environmental Impact Statement.

This is a comprehensive document that encompasses over 8 years of data collection and work on the part of the motorcycle trail riding community. Please review it and be prepared to support any follow on actions that are necessary to protect your right to public lands.

There are 7 related documents here. All 7 are listed with a link to their downloadable PDF or Excel document on the left. The first 3 documents in the list are also readable here within this page, just scroll down to read them in thier entirety or click on the title of the document to jump to the specific text.
   
   
 

June 1, 2009 Gunnison Basin Summary
Letter to the Gunnison Travel Management Planning Team.
Re: Gunnison Basin Federal Lands Travel Management DEIS
 

June 1, 2009 Gunnison Basin Comments
Comments & recommendations representing the combined input of Trails Preservation Alliance (TPA), the Colorado off Highway Vehicle Coalition, (COHVCO), and the Rocky Mountain Enduro Circuit (RMEC)
  June 1, 2009 Gunnison Basin Grants Appendix
  June 1, 2009 Gunnison Basin DEIS Appendices

8/30/2007 COHVCO Gunnison Travel Cover letter 
  8/30/2007 COHVCO Part A Planning Comments
  8/30/2007 COHVCO Part B Trail Recommendations

 
 

Gunnison Basin Summary


June 1, 2009

Gunnison Travel Management Planning Team GMUG National Forest 2250 Hwy 50 Delta, CO 81401
Re: Gunnison Basin Federal Lands Travel Management DEIS

Dear Planning Team:
The following comments and attachments respond to the opportunity for the public to comment on the “Draft Environmental Impact Statement, Gunnison Basin Federal Lands Travel Management”, February 2009.

We thank the Planning Team and the leadership of the Gunnison Basin federal land units for their efforts to include the public in the development the proposed Travel Management Plan. The process has continued since the 2001 Gunnison Travel Interim Restrictions Decision Notices by the joint agencies.

The comments and recommendations in this letter and its attachments represent the combined input of the Trails Preservation Alliance (TPA), the Colorado off Highway Vehicle Coalition, (COHVCO), and the Rocky Mountain Enduro Circuit (RMEC). These 3 organizations represent the majority of off highway vehicle users in the State of Colorado. The off highway vehicle users in the state number more than 200,000. The TPA, COHVCO, and RMEC, as well as many local clubs and organizations have been actively involved with the GNF TMP process for the last 8 years. The analysis provided in this document includes the consolidated remarks from many of the local OHV organizations in the state. All of these organizations have spent considerable time and effort in the review of the GNF TMP. The TPA, COHVCO and the RMEC intend to remain as active partners with the FS throughout the remainder of the TMP process.

Since 1994 these three organizations, their local clubs, many recreationists and the Colorado State Parks OHV Program have provided program leadership and grants of $ 1,615,744 and thousands of man hours of volunteer labor to the Gunnison Basin area trails program. We feel we have gone a long way in providing for and maintaining a multiple use trail system, while also supporting the needs of all users for open and safer trails. There has been very little accommodation, especially by the BLM in this planning effort, to perpetuate, design or enhance a quality motorized recreation programs at historic levels. . We, in example, are particularly disheartened and feel betrayed by seeing historically motorized trails like Agate Creek and the Crest Trail, enjoyed for years and maintained by motorized grant money and crews, be moved to a non-motorized category.

This eight year time period and associated interim processes have now been impacted and altered by the additional requirements of the 2005 “Travel Management Rule”. The time requirements and processes for implementation of this new Rule to create a motor vehicle use map (MVUM) and associated orders has put another unfunded burden on the USFS and BLM. It has also created additional impacts on the time and resources of communities and the various user groups. While it has been an important and necessary process, changes in agency leadership, change in community and user demographics, public use patterns, and trends in recreation vehicle design and use continue to create unsettled management dilemmas for all concerned. In the DEIS, it is clear that the planning team specialists were directed to just display and discuss the impacts created by motorized uses, while impacts by foot, horse and mountain bikes have been omitted and ignored. There is no science cited for multiple use impacts on streams, riparian/aquatic systems, and wildlife by multiple use recreationists.

The predictability and sustainability of trail opportunities is held in the highest regard by all public land user groups as evidenced by national statistics on outdoor recreation use, and many thousands of hours of volunteer time and resources. So, it has to be a shared frustration that agency leadership, staffing and budgeting issues continue to plague timely decision making, directly complicate, and contribute to the agencies roles and responsibilities for continuing “unmanaged recreation”.
We have been a part of the Gunnison Basin travel management process for over 30 years, and have enjoyed the many, year-round opportunities for motorized recreation. We have continued to share the multiple-use, public land ideal with all other trail groups. Our members support the ideas of wilderness and non-motorized recreation activities and we have helped contribute millions of dollars in grants and manpower to the benefit of all trail users, agency budgets and trail crews. We know how to share public land recreation opportunities, and we will continue to do our best in the education of users to respect others and help steward natural resources and respect for management agencies. We hope that the agencies will try to foster this same level of respect from other user groups for motorized recreationists.

However, after each planning, executive or legislative process over the years we continue to lose miles and quality of motorized trail opportunities. The aggregate affect of decisions for Wilderness additions, special area designations, roadless regulations, staffing and budget reductions, disinvestment and decapitalization of trail and road infrastructure continues to reduce motorized recreation opportunities. The 2005 Travel Rule has left a system of rushed local decision making to Rangers, Supervisors, and Managers that have only been loosely coordinated between some Forests. There is no analysis or disclosure of regional or state-wide consequences or effects of these connected actions. In light of the regional and national USFS, BLM and Departmental deference to local decision making and politics under the 2005 Rule, it is no wonder that uncoordinated local decisions continue to erode motorized recreation opportunities.

It has been a continued struggle over the years, after many well intentioned public meetings and agency staff meetings, to develop a confidence that agency officials would fairly seek to balance user opportunities. We have been confronted by statements of responsible agency officials that say they would prefer to have no motorized use on public lands at all. Then, the same officials are responsible for recreation/travel management planning team assignments. This is not an investment in public confidence for a fair and balanced analysis or decision document. We have been concerned about potential agency staff bias at a local level since our response to the draft Travel Management Rule in 2005 and the subsequent Manual direction. This concern has continued to be displayed in all subsequent local Travel Rule planning processes. We continue to find local official and agency bias against sustaining quality motorized recreation across a variety of federal land, outdoor settings. Recreation sciences are weak or neglected, and the social economic analysis is shallow and non-responsive. Most importantly, full disclosure of all trail opportunities and recreation settings are missing.

Examples of bias include only using motorized trail impacts in discussions of streams, fisheries, and wildlife and wetland vegetation. There are no mountain bike discussions regarding these impact areas, and no research cited at all. Further, insensitive bias (see page 136) is suggested when staff described the popularity of motorized recreation in Taylor Park as being “under siege” by ATV’s, and on the same page the popularity of mountain bikes in the Crested Buttes area as being “the cradle of mountain bike recreation” and the trail system as “legendary”. In the spirit of full disclosure, we did find the recognition of the Gunnison Ranger District as providing the “gold standard” for use opportunity.

The history of the single track trail system in the CB/Taylor Park area can be documented starting in the 1960’s. This entire trail system that is in place today was built and maintained by motorcycle users, by converting old logging and mining roads into a recreational multi use trail system. We do acknowledge that in the last few years, the mountain bike community has been actively involved in trail building and maintenance. However, the historic lineage and the contribution of $1.6M in OHV funding has been the backbone of sustaining the trail system we have today. Every trail that is being closed in the Preferred Alternative, has had OHV funding utilized to maintain it. This is be either direct OHV grants, or by the utilization of the OHV trail crew through the Good OHV Management program. This include the Agate Creek and Crest Trails.

The Gunnison Basin DEIS, in the presentation of “Issue 2”, Recreational Experience and Opportunity, Motorcycles, (pg.23) states that users wanted loop trails and “did not want dead-end routes”. This does not reflect an accurate representation of the motorcycle users that we represent, and we fear that the planning team and transportation planners over re-acted by removing short dead end trails. This removal of short, dead-end trails was also highlighted at the public meeting in Gunnison as a positive response to issues. Our concern is that this strategy will concentrate dispersed recreation campers along designated, higher volume routes and remove the opportunities for motorized reservationists to enjoy semi-primitive, back country camping like other user groups. This will prove to create additional conflict based on the continued loss of back country recreation. We appreciate the challenge that travel planning presents, but the lesson to be learned here is that site-specific analysis must occur across the entire project area for all uses, and that a set of in flexible rules or templates will not produce a logical or workable end product. Some dead-end routes should not be designated, while others provide essential access to important destinations or to long-utilized and appropriate dispersed camping opportunities, the continuation of which enhances sustainable management and minimizes impacts to physical resources.

Colorado’s population grew by 145 percent between 1960 and 2000. The U.S. Census projects that Colorado will continue to grow at a rate triple to the national average and another 1.5 million people will live in Colorado by 2030. People choose Colorado because of its public lands and access to outstanding outdoor recreation settings and its diversity of outdoor activities. The off-highway vehicle registration program in Colorado has grown from 55,000 permits in 2000 to 132,166 in 2008, a 140 % increase. Of the 2008 permits, 31,013 were issued to non-resident, Colorado visitors and tourists. In recent years, there have been approximately 750,000 ATV’s sold annually in addition to 250,000 motorcycles. The need for a responsive and coordinated set of motorized road and trail opportunities is now more important than ever.

The economic and social impacts to the recreation and tourism industry in the Gunnison Valley and its communities need further disclosure and analytical rigor in this regard. This is not a discussion about which user group has more affluence. Rather, what are the specific demographics of Gunnison County, their dependency on the travel and tourism economy, job and income opportunities, multiplier values of the recreation dollar that would vary with alternative recreation opportunities? Contacting the Colorado State Demography Office and the Region 10 Economic office would provide valuable support to further display the social and economic effects of the TMP decisions on Gunnison County.

Motorized recreation continues as one of the fastest growing activities and the national recreation survey shows that the demographics of users is changing to include more older citizens and minority groups. There is a USFS planning document, (NVUM 2008) that highlights the increase of OHV recreation and the justification to address the users recreation opportunities. However, the Gunnison TMP shows an obvious bias for non-motorized recreation by providing a dramatic growth in mountain bike opportunities, reducing the single track opportunities for motorized recreation. There was little effort made to conduct a rigorous needs analysis at any level (national, regional, or local) as the basis to establish the basis for a balanced approach as required in the Travel Rule. This also ignores the trend toward older recreationists turning in their non-motorized means of travel for those that suit the needs of those with arthritis, knee and hip problems and simple old age. This is hardly the proposition that taxpayers of the past 50 years will appreciate. Perhaps not a direct Rehabilitation Act violation, but then again not everyone can keep a horse. At some point when hundreds, if not thousands, of older recreationists are told that as long as some form of non-motorized recreational means exists they can employ it or stay off the forest a new more powerful argument will be revived in the federal courts.

Additionally, since the terms “needs analysis” and “social sustainability” remain vague and undefined, it is reasonable and practical that age and disability as relating to access are elements of any analysis purporting to address needs and social sustainability.

Local federal agencies, instead of fostering and leading multiple-use trails and enhancing all-around recreation opportunities, continue to segregate mountain biking and motorized use that continues to perpetuate unnecessary conflict. While mountain bikes enjoy nearly the full spectrum of trail opportunities outside Wilderness areas, the motorcycle community is regulated to a very small percent of the trails. The use of the term “user conflict” is not valid and displays a bias by the USFS/BLM planning group. The Gunnison Basin agencies, citing reducing user conflicts as a justification, tend to continue to invest in a public land management style that rewards user group intolerance by a small group of users instead of encouraging maximum sharing of public land opportunities. This management position is contrary to the basic advocacy position of responsible motorized recreationists, and also of the International Mountain Bicycling Association (IMBA) who ask “for shared-use trails because we (IMBA) know that shared-use trails best accommodate the needs of the most users, minimize total environmental impacts, are most economical, and best build a trail community”.

The Crest Trail on the Continental Divide at Monarch Pass is an example of where the proposed alternative shifts long time (50 years) historic use from motorized to hiking/biking. Motorcycle use on the Crest Trail pre-dates the CDNST Act, and even the act protects existing motorized routes. The proposed alternative is a conflict producing decision that violates good recreation management principles. If the agencies want to continue to grow conflict, ignoring the research on the impacts on users and relocating old, historic uses and travel patterns with newer activities requiring exclusiveness, this kind of decision making and rationale is the way to do it. We recommend that the Crest Trail remain open to multiple-use as it is a distribution point for a diversity of users.

In a recent meeting with FS recreation personnel, we found out there may be some pre-decisional “deals” being made with the Gunnison Area regarding the Crest Trail. There is a perception by these personnel that most motorcycle riders would rather use Green Creek as an access and they do not need that section from Monarch Pass to Green Creek. This is totally untrue. The Crest Trail in its entirety is a focal point for all trail users in the area. The Green Creek Trail is too difficult for most riders, novice and older riders will be greatly impacted with any closure of the Crest Trail, with it’s key connections to other routes. Whatever data collection was done by planning personnel or local managers was wrong. Further, a local bike rental business in Salida is already telling its customers the Crest Trail is non-motorized and this is causing more conflict and confusion…not to mention contrary to a fair and open planning process that is supposed to be coordinated between adjoining ranger districts and forests.

We are particularly concerned about the lack of opportunity on BLM land, where great opportunity exists, but few trails are available, plus the impact of massive seasonal closures. In the April Gulch, upper Beaver Creek and areas South of US 50, there is a vast potential for developing a multiple use trail system. Yet, a road that has been shown as closed on USFS and BLM maps, is actually an open county road. We feel that the BLM could be much more open to motorized recreation in this area.
 
The TMP document while it follows the general requirements of NEPA, NFMA, and the 2005 Travel Rule, appears largely as an engineering route and road finding exercise that has been overly influenced by the need to eliminate user conflicts defined and demanded by a small group of users. The definitions of “balance” and “sustainability” remain conveniently undefined in both terms of social need, economic impacts and recreation activities. The use of the concept of “fairness” in the allocation of use process has been confused, creating a bias against managed recreation and being partially non-responsive to the requirements of the Travel Rule to enhance recreation opportunities. One major failure of the DEIS is the identification of many “UT” trails on the maps. This makes commenting on these routes nearly impossible. We have done our best to make sense of these routes, with assistance from Garth Gantt. We believe that a Supplemental EIS is required by law to meet public disclosure requirements.

The DEIS does not give adequate consideration to the ability of licensed motorcycles, which are extremely common, to utilized mixed use routes, thereby not being restricted to designated OHV routes. This opens up the opportunity for use of many short UT routes as important connectors.

In our detailed comments, you will find a summary of recreational opportunity by mode of transportation. But unlike the analysis in the DEIS, this summary shows the actual available opportunity through multiple use, i.e. hikers can use all trails designated for horses, mountain bikes, motorcycles and ATV’s. We then calculated the expected number of recreational days by type. ATV’s are afforded 3 days of recreation opportunity, motorcycles 5 days, mountain bikes 24, horses 65, and hikers a whooping 130 days. When the 540 miles of Wilderness trails are included, horse opportunity goes over 90 days and hiking goes over 180 days! The planning team should seriously consider this approach, because it is the simple reality.

We remain hopeful, open and anxious to work with agency planners and decision makers to discuss our continuing issues, and more importantly site specific road and trail recommendations.

We request that Alternative A be accepted as the preferred alternative, and that information submitted by the OHV community be reevaluated by the FS/BLM staff. Our specific comments and recommendations are attached.
Sincerely,

Don Riggle
TPA Chairman
P.O. Box 38093
Colo.Springs, CO 80937
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719-338-4106

Dennis Larratt
RMEC Treasurer
10990 N. Sunshine Dr.
Littleton, CO 80125-9432
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720-530-9974

Glenn Graham 
COHVCO Chairman
P.O. Box 620523 
Littleton, CO 80162
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303-249-9730 


 
   
 

Comments and Recommendations


June 1, 2009

Gunnison Basin Federal Lands Travel Management DEIS
COHVCO – TPA -RMEC

1.
The DEIS Summary (page 1) sets up the planning bias that reflects itself throughout the document. The sixth paragraph states: “The agencies have the difficult task of balancing the need for access to the federal lands for a wide variety of uses with our mandate to manage for long-term sustainability of the federal lands and natural resources on those lands”. While we appreciate and recognize the “difficult task” of this planning effort, both the BL M and U.S. Forest Service have a “mandate” to provide for multiple use and sustained yield of all resources…including outdoor recreation …that best meets the need of American people (Multiple-Use Sustained Yield Act, 16 U.S.C. § 528, and National Forest Management Act, 16 U.S.C. § 1604(e)). These are “judicious use” concepts that include the principle of sustained yield of all of the several products and services obtained from renewable surface resources. By positioning “access needs for a variety of uses” on one end of a planning teeter-totter, against “the mandate for long-term sustainability of natural resources” on the other end, suggests an agency, predetermined, point of balance outside the mandate to also provide for sustainable services for the American people.

The term “balance” in the Travel Rule and in this DEIS remains conveniently undefined and left open to individual, local planning team interpretation. This creates bias for alternative construction and allocation of opportunities. The term, “sustained yield” means achievement and maintenance in perpetuity of a high-level, annual output of the various resources and services without impairment of the productivity of the land. This should be a planning process that finds harmonious and coordinated management programs that recognizes relative values of both goods and services. In item 37 of this comment, details are provided on available mileage by type of recreation that show motorized recreation receives the short shrift on recreational opportunity.

It has been extremely difficult for the public to participate with federal agencies that keep shifting management priorities and budget strategies. It has tended to make the anticipation of sustainable public services and facilities difficult to predict and plan for. The recreation service programs, greatly touted in the early 1990’s as a substitute for the loss of commodity programs in our rural communities, have taken a “back seat” to other resources and the allocation of land uses.

WE ASK THAT RECREATION BE AFFORDED EQUAL STATUS WITH OTHER FOREST USES, AND THAT CAPRICIOUS BUDGETING EXPLANATIONS BE REMOVED IN THE FEIS.

2.
Page 3, “Summary of Effects on Various Resources or Activities by Alternatives” Table, would benefit from a display of single-track trails by alternative since it is an issue identified on page 23, DEIS. Also, there are disclosures in the Affected Environment Chapter discussions on Recreation that suggest conceptual miles of new construction of roads and trails. Miles range from 15 to 100 miles and vary by alternatives. The reader is again directed to Item 37 for details on true recreational opportunity by type.

WE REQUEST TO HAVE THESE MILES DISPLAYED IN THIS SAME TABLE (PAGE 3) BY ALTERNATIVE, AND SHOWING THE AVAILABLE MILEAGE BY RECREATION TYPE (SIMILAR TO ITEM 37 BELOW).

3.
The DEIS document does not use or display the gains and losses of recreation trail mileage by user group by Recreation Opportunity Class (ROS). This information would benefit the Summary Table on Page 3. At the heart of the conflict this DEIS is trying to solve (the quality and enhancement of outdoor recreation), it is critical to display the impacts of users’ gains and losses of recreation settings. An example, the loss of high altitude routes in semi-primitive settings is not substitutable for constructed road riding in urban or rural settings.

WE REQUEST THAT THE SETTINGS INFORMATION BE FULLY DISCLOSED IN FAIRNESS TO THE DECISION MAKING AND PUBLIC INVOLVEMENT PROCESS.

4.
Figure 2, page 8, Map Key, shows “Forest Service Lands” and BLM Lands”. These terms should be changed to use the terms “National Forest” or “Public Lands” to avoid the bias of agency centric terminology. These lands belong to national publics, not the Forest Service or the BLM.

WE REQUEST THAT THE REFERENCES REFLECT THIS IN THE FEIS.

5.
Page 9, paragraph 4, is incomplete in its answer to “Why Replace the Current Travel Management Direction? The Forest Service Travel Management Rule (November 9, 2005)(“Travel Rule”), clearly establishes the goal to enhance opportunities for motorized recreation experiences on National Forest system lands (FR Vol. 70, No. 216, 68264). This important reason has been omitted in this section of the DEIS. It also established the position of the Department, that “designations of roads and trails…should be based on accurate, pertinent unbiased information”. The Department and the Rule did not require independent scientific review, nor supported that it had to be clearly proven to be harmless to the environment for roads and trails to be included (FR Vol. 70, No.216, 68266).

WE REQUEST THAT THE FEIS CLEARLY IDENTIFY AND FOLLOW THE DIRECTIVES IN THE NOVEMBER 2005 TRAVEL RULE.

6.
Page 12, Screening Tools, User demand and desire. Here is another example of the planning team’s misunderstanding and separating “providing varied experiences” away from “providing multiple-use, sustainable resource management”. Sustainability as discussed above, by law, is intended to apply to public use, people and services…not just natural resources. A bio-centric bias is of great concern here.

WE REQUEST A FULLER DISCUSSION OF SUSTAINABILITY OF PEOPLE AND SERVICES THAT WAS MISSED IN THE DEIS

7.
Page 13, paragraph 1, Sustainability of a transportation system. This is a two paragraph discussion associated with the costs of maintaining a transportation system, but seems to address the roads only. The choice of words by the author, “While this may not meet the criteria for a fiscally sustainable transportation system”, and “the agencies’ ability to reasonably maintain the routes” suggests there is not full awareness or recognition of cooperative road maintenance programs, trail partnerships, volunteers, and grants. We do recognize that later in the DEIS, under the Transportation section, the author does recognize grant and volunteer opportunities.

Since 1994, in example, the Colorado State OHV program has provided over $1.6 million in grants to the Gunnison Basin area for trail maintenance and trail crews. These grants are summarized in Appendix I of this document. The Travel Rule (at FR, Vol. 70. No. 216, 68281) states that “volunteers and cooperators can supplement agency resources for maintenance and administration, and their contribution should be considered in this (TMP) evaluation”. We think this addition to the discussion would help disclose all the opportunities for trying to achieve fiscally sustainable transportation systems.

Of particular concern, is the loss of motorized trails that have for years been maintained by motorized groups, and crews with the Colorado State OHV funds. An example would be Agate Creek. We have been advised that the Forest would not reallocate motorized trails that have been maintained with OHV grants to other uses. We would request a re-evaluation of the trail inventory in all alternatives to assure these remain in the motorized use category in all alternatives.

Each Colorado OHV Program Grant for specific trails includes an agreement to maintain the trail for motorized recreation for a period of 20 years. A listing of the Colorado OHV Program Grants is provided in Appendix I. It is obvious that a number of the trails that are slated for prohibition from motorized recreation are on this list.

WE ASK THAT EACH OF THEM BE ALLOWED FOR THE APPROPRIATE MOTORIZED USE IN ALL DEIS ALTERNATIVES. WE REQUEST THAT THE PLANNING TEAM UNDERTAKE AN EFFORT WITH COHVCO AND TPA TO ADDRESS ANY MOTORIZED ROUTES THAT ARE BEING CONSIDERED FOR PROHIBITION TO MOTORIZED USE DUE TO MAINTENANCE FUNDING. WE THINK THAT THERE ARE OPPORTUNITIES TO MITIGATE THESE ISSUES PRIOR TO DECISIONS IN THE FEIS.

8.
Page 13. Purpose and Need for Action. This section would benefit from just using the wording from the Travel Rule. The planning team attempts to segregate human (social) values sets as different from resource protection concerns that tends to disconnect the public from their closely held values for resource protection. This is not a “balancing game” of “winners and losers”, but the development of management alternatives that integrate values that include humans as members of the natural environment and their public lands. The challenges are in finding the right set of integrated management techniques and mitigations to achieve public land management objectives. There may be a place for the term “balance” in the discussion about how fairly road and trail opportunities are shared or distributed between user groups. However, our concern for your concept of “balance” applied to our values for natural resource protection is that we do not want to be separated from our land ethic and stewardship responsibilities. We have to confront agency processes that are unnecessarily biocentric, and tend to judge recreation and social needs on a separate and disconnected standard. Human benefits are derived from natural resources, and natural resources have been given their value, respect and management by humans.

WE REQUEST THAT “PURPOSE AND NEED” STATEMENTS BE MORE SENSITIVE ABOUT USING HUMAN-NATURE INTEGRATION PROCESSES AND TERMINOLOGIES, RATHER THAN WEIGHED/BALANCE CHOICES.

9.
Page 16. Route Designation. There is a statement that “some routes cause resource damage, are inconsistent with recreation experience and opportunity objectives, or serve no transportation or resource management purpose”. Routes do not cause resource damage themselves. Poor location, improper design, lack of maintenance, users and storm runoff cause impacts and in some cases damage. The statement implies that there are “recreation experience and opportunity objectives” identified. We find in Appendix A/B concerns, issues, District Rationale, and public comments, but no established set of experience or opportunity objectives in this DEIS document.

This is at the heart of our concern for this process. The DEIS process objectives establishes finding a “balance” as a primary goal, but there is no display of recreation settings or experiences for each class of activity to evaluate balance or opportunities.

WE REQUEST THAT THE AGENCIES PROVIDE A SCHEDULE OF MITIGATION OPTIONS FOR ALL ROUTES PROPOSED FOR CLOSURE UNDER ANY OF THE ALTERNATIVES, AND THAT THE AGENCIES WORK WITH COHVCO AND TPA TO OFFER SOLUTIONS TO THESE MITIGATION NEEDS, PRIOR TO THE FEIS.

10.
Page 17. Season of Use. The two examples of limiting season of use are for wet roads and wildlife habitat. We believe that managers should also include potential for scheduling different recreation activities seasonally, monthly, or weekly as a method to reduce conflicts and still provide access opportunities for all classes of users.

WE REQUEST THAT THE PLANNING TEAM UNDERTAKE AN EFFORT WITH COHVCO, AND THE TPA TO ADDRESS ANY MOTORIZED ROUTES THAT ARE BEING CONSIDERED FOR PROHIBITION TO MOTORIZED USE DUE TO SEASONAL USE ISSUES, TO PROVIDE AN OPPORTUNITY TO IDENTIFY MITIGATION OPPORTUNITIES PRIOR TO DECISIONS IN THE FEIS.

11.
Page 19. Mixed Use Determinations. Motorized mixed-use analysis. Mix-use, safety decisions as stated here are at the “discretion of the federal land manager”. We request this discussion be expanded to include the role of the county and state (CDOT) road jurisdictions on the federal lands. We would also like to see and hear the rationale for safety-based decisions.

12.
Page 22. Recreational Experiences and Opportunity. The issue statements for ATV’s and Motorcycles (page 23) are incorrect as they apply to our membership and motorized recreationists in general. The planning team’s interpretation of public input that ATV and motorcycle enthusiasts want to eliminate dead-end roads and trails is wrong. While motorized recreationists seek out long distance and loop trip opportunities, they still have a high interest in maintaining their special places and campsites…many of which are on dead-end roads.

Most dispersed campers use motor vehicles to get to their favorite campsites, even if they do not use them for recreation. This group of dispersed campers are most impacted by the closure of spur routes, and are also less likely to be actively involved in the TMR process, and so become unheard citizens.

To automatically eliminate dead-end roads and trails is to remove reasonable, enhanced recreation settings that have been historically enjoyed by many motorized users. To eliminate these dead-end sites is to concentrate motorized camping along designated routes (+/-300 ft) only and sets up a situation that disrupts other users and perpetuates potential conflicts. It is essential that the agency perform site-specific analysis in order to determine the proper designation status of dead-end routes, rather than adopting some form of rigid guideline that will inappropriately eliminate legitimate use that will have a net beneficial effect on the environment.

WE REQUEST ALL OF THE DEAD-END TRAVEL ROUTES, INCLUDING THOSE OF LESS THAN A QUARTER MILE, RECEIVE SITE SPECIFIC ANALYSIS OR BE PLACED BACK INTO THE INVENTORY OF ESTABLISHED ROUTES FOR MOTORIZED USE, AND BE AVAILABLE FOR CONSIDERATION IN ALL ALTERNATIVES.

13.
Page 23. Mountain Bikes. Those users who contended “that bikes do not have the same adverse impacts on soil, wildlife, and primitive recreational settings as other forms of travel” are evidently hoping they are going to pass this off as a completely valid statement. There are no studies documented in Appendix E, and most importantly the discussion about mountain bike impacts is vacant from the narratives and Tables in Chapter 3, Affected Environment and Environmental Effects. This is especially true in areas of wetlands, water, riparian and soils discussions where only motorized water crossings and impacts are discussed. There are plenty of areas on federal lands where mountain bike impacts are obvious, damaging, contributing to conflict among all other user groups, a major distraction in primitive settings. The issue statements regarding mountain bikes needs to be more honestly displayed in this issues section, because it “drives” the rest of the document that require thorough and professional disclosure. Also, see the lack of mention of mechanized equipment under Issue #4: Resource Protection where only motorized recreation is adversely affecting wildlife, soil and water.

This is another example of the documents biased approached, whether intended or not. It is well documented that wildlife are, in some contexts, more adversely affected by “stealth” approaches than those with sound levels that announce both the approach and exits of others into their habitat areas.

WE REQUEST A MORE THOROUGH DISCUSSION OF THIS ISSUE TO HELP AVOID THE DOCUMENT’S OTHERWISE BIASED APPROACH. AGAIN, SITE-SPECIFIC ANALYSIS, NOT OVERGENERALIZATION, MUST BE THE ANALYTICAL TOOL OF CHOICE.

14.
Page 26. Issue 7: Maintenance/Funding. The issue of grants, donations, and in kind services to help provide maintenance is disposed of in this DEIS by saying it is “outside the scope of the travel
Page 5 of 17 analysis”. Funding levels, historic grants and volunteer programs are very much a concern of the Travel Rule direction. See paragraph # 7, above and FR 70 at 68281, again. It was intended that no trails be left out of consideration because of lack of agency funding, so it is within the scope of this analysis to include these trails in the basic inventory for alternative consideration. It is an inventory and opportunity area to be discussed, because volunteerism is a recreation benefit opportunity, not just an implementation concern outside the scope of the document.

WE REQUEST THAT THE FEIS TAKE INTO REGARD THE ENORMOUS FINANCIAL CONTRIBUTION OF THE MOTORIZED RECREATION COMMUNITY, AND COMPARE THIS TO THE CONTRIBUTIONS (OR LACK THEREOF) OF THE NON-MOTORIZED USERS.

15.
Page 27. Societal Issues. Noise, dust, speed and the local economic consequences are a weak and an incomplete portrayal of the social-economic issues that we know have been expressed regarding the development of this analysis and document. Issues in this area have to include the resulting loss of benefits, life styles, displacement of historic opportunities, and those issues associated with the understanding and disposition of conflict. There are no social-economic references or science cited in the Appendix. There is no apparent use or inclusion of Region 2 economic or Gunnison County data that more precisely demonstrate community jobs, business dependencies, and demographics.

WE REQUEST THAT THE SOCIETAL ISSUES BE PROPERLY ADDRESSED IN THE FEIS.

16.
Page 28. Future Demands. The issue on consideration of recreational opportunities and primitive settings should be presented and discussed under Issue 2: Recreational Experience and Opportunity, not “Future Demands”. This is at the heart of this whole TMP need to describe and allocate recreation opportunities and settings among recreation users. “Preservation” of a full spectrum of recreation settings (ROS) is absolutely critical to the current and historical use presentations in this document (which is missing). This is not just an issue about preserving primitive settings in the future.

It is clear that the Forest Service has failed to meaningfully consider viable alternatives to those formally analyzed in the DEIS. NEPA imposes a mandatory procedural duty on federal agencies to consider a reasonable range of alternatives to the preferred alternative. 40 C.F.R. § 1502.14 (“agencies shall rigorously explore and objectively evaluate all reasonable alternatives.”) The alternatives section is considered the “heart” of the EIS and a NEPA analysis must “explore and objectively evaluate all reasonable alternatives.” 40 C.F.R. § 1502.14. A NEPA analysis is invalidated by “[t]he existence of a viable but unexamined alternative.” Resources, Ltd. v. Robertson, 35 F.3d 1300, 1307 (9th Cir. 1993).

Numerous existing and historically traveled routes were not considered for detailed analysis in any action alternative. While we generally support Alternative 1, even that alternative is far from ideal and doesn’t offer any increase in the network of routes available for motorized travel.

The agency has improperly ignored viable, if not persuasive, alternatives and proposals in violation of NEPA. The management of and access to these lands are important to us and many diverse Forest visitors.

WE RESPECTFULLY ASK YOU TO REVIEW THE QUESTIONABLE MANAGEMENT DECISIONS MADE IN THE DEIS. WE SPECIFICALLY REQUEST THAT YOU EXPAND THE RANGE OF ALTERNATIVES AND RECEIVE ADDITIONAL PUBLIC COMMENT IN ORDER TO PROVIDE AN ADEQUATE ROUTE NETWORK FOR THE GUNNISON PUBLIC LANDS. AS A FORWARD LOOKING DOCUMENT, THE FEIS SHOULD FORECAST THE USER DEMANDS BY RECREATION TYPE. FURTHER, WE REQUEST THAT SPECIFIC USE ONLY, IE FOOT AND HORSE, BE ELIMINATED AND THAT ALL TRAILS REMAIN MULTIPLE USE AS APPROPRIATE.

17.
Page 30-31. Alternative Development. The highlights list of management objectives is a helpful presentation, but avoids discussion or definition about balance of uses among users or with natural resources as stated in the purpose and need section above. (See Paragraph 8, above).

Of greatest concern is the objective to “protect wilderness values by removing motorized and mechanized use at or along wilderness boundaries”. This is a classic “buffer area” management style that was not intended by the various national and Colorado wilderness acts, nor agency policy. Wilderness values were protected by law, and the identification and establishment of the original boundaries. Just because the sights and sounds of man may be felt by wilderness users, does not justify wilderness boundary “expansion”. Only Congress can designate Wilderness under the Wilderness Act. The act specifically states that, wilderness areas are “to be composed of federally owned areas designated by Congress as ‘wilderness areas’…no Federal lands shall be designated as ‘wilderness areas’ except as provided for in this chapter or by a subsequent act.” 16 USC §1131(a). Reviewing courts have agreed that this express command reserves the power to designate wilderness exclusively to Congress. Wyoming v. U.S. Dept. of Agriculture, 570 F.Supp.2d at 1350; Parker v. United States, 309 F.Supp. 593, 597 (D. Colo. 1970), aff’d, 448 F.2d 793 (10th Cir. 1971). While the Secretary of Agriculture, and therefore the Forest Service, certainly has responsibilities under the Wilderness Act, those duties are succinctly summarized as “the duty to study and recommend.” Parker, 309 F.Supp. at 597. Neither the Travel Management Rule nor other law authorizes the Forest “to establish their own system of de facto administrative wilderness through administrative rulemaking….” Wyoming, 570 F.Supp.2d at 1350. This is a major land allocation finesse by the planning team, and well outside of NFMA and FLPMA. These decisions are protected by public law and policy to the Congress, and well outside the scope of a locally produced travel management plan.

WE REQUEST THAT THE ALLOCATION OF ADDITIONAL BUFFERS TO EXISTING WILDERNESS BOUNDARIES BE AVOIDED IN THE FEIS AND ADJOINING TRAILS AND ROADS BE EVALUATED AND RECONSIDERED IN ALL ALTERNATIVES.

18.
Page 41. Table 2-5. Comparison of Alternatives by Effects. Water Resources and Aquatic Species categories could be combined as motorized stream crossing and road density data is the same. We think the 680 miles of motorized trail riding should be 687 miles under Alternative 4 in the Recreation Opportunity section and the Local Economics section. There is an apparent attempt to lump data under motorized trail riding in order to show Alternative 4 increases over Alternative 1, No Action in the Recreation Opportunity section. This certainly covers the loss of single track motorized trails shown in the Travel Opportunities section and hunting/fishing categories, in light of the across the board increases for mountain bike use opportunities.

Page 7 of 17 WE REQUEST THAT THE PLANNING TEAM RE-EVALUATE THESE ELEMENTS.

19.
Page 44. Chapter 3. Affected Environment and Environmental Effects. Paragraph one states that scientific data would be presented to summarize physical, biological, social, and economic environments and the associated effects by alternative. As identified above the document is particularly weak in displaying and using the social and recreation sciences, local economic and demographic data, and any data associated with mechanized use impacts.

WE REQUEST THAT THE FEIS EXPOUND ON THESE ISSUES IN A FASHION THAT IS UNBIASED AGAINST ANY ACTIVITY, ESPECIALLY MOTORIZED RECREATION.

20.
Page 46. Soils. Paragraph 2 has a discussion about narrow trails contributing less erosion than roads, and then claim there is no change in relative erosion rates by slope class between trails and roads.

WE REQUEST FURTHER EXPLANTION OR CLARIFICATION OF THIS.

21.
Page 46. Table 3-2. Miles of Motorized Routes in Alpine Areas. This table shows only motorized routes. Our concerns remain about where is the science and impacts of mechanized, foot and horse use disclosed.

WE REQUEST A CORRECTION IN THE FEIS, WITH A COMPLETE COMPARISON OF ALL TYPES OF USE IN ALPINE AREAS.

22.
Page 47. Water Resources and Water Quality. The affected environment discussion is about motorized uses of roads and trails only. There is no discussion about mechanized, foot or horse impacts in this section or its associated summary tables or cited science. This is really a major oversight and flaw through out this entire Chapter, especially as it relates to soil, wetland, riparian and wildlife analysis.

WE REQUEST A RE-EVALUATION AND PROPER SCIENTIFIC EVALUATION OF WATER RESOURCE AND WATER QUALITY.

23.
Page 55. Last paragraph. Environmental Effects by Alternatives. This whole section of discussion and associated tables is introduced by the lead sentence that says: “For the purpose of this analysis only motorized roads and trails were summarized”. We consider this poor planning management of a process that requires full disclosure and has multiple issues identified about all user groups. Route densities and stream crossings, in example, can be seen for only motorized use. See Tables 3-8 and 3-9 as additional illustrations of this bias.

WE REQUEST THAT ALL ALTERNATIVES BE EVALUATED FOR ALL TYPES OF USES, OR THAT THE EVALUATION FOR MOTORIZED ONLY BE REMOVED.

24.
Page 59. Last paragraph. The Alternative 4 discussion suggests that alternative 4 consequences would be of the same magnitude as the Proposed Action. Then the author who assigns a self proclaimed simplistic level of analysis establishes that actually Alternative 4 is actually less preferable than the

Page 8 of 17 Proposed Action. This even assumes better new road and trail locations with best management practices applied. The science here is hard to follow.

WE REQUEST THAT THE FEIS SHOW THE SAME CONSEQUENCES FOR ALTERNATIVES 4 AND THE PREFERRED ALTERNATIVE.

25.
Page 69. Aquatic Resources. The apparent planning assumptions assigned to most specialists on the Planning Team were to consider effects on motorized routes only. The same has been the case here in the Fish and Aquatic MIS (Management Indicator Species – Affected Environment section).

WE REQUEST THAT ALL ALTERNATIVES BE EVALUATED FOR ALL TYPES OF USES, OR THAT THE EVALUATION FOR MOTORIZED ONLY BE REMOVED.

26.
Page 75. See discussion above. The list of eight specific effects to aquatic biota describe motorized routes only and include the associated concerns for chemical contamination, sediment, crushing of biota, introduction of exotics, spread of pathogens, exploitation of fishing because of increased pressure, and fragmentation by drainage structures. This is a professionally unacceptable, narrow disclosure of impacts created for and attached to motorized uses only. There is no science or references to hiker, horse or mechanized uses and their somewhat similar impacts to aquatic biota resources. This is especially shocking in a document that allocates uses and routes for all users. Planning has always been an interdisciplinary process incorporating overlapping issues that attempts to disclose all effects. This is another example of our developing a sense that a multi-disciplinary process was used allowing personal or professional agendas to override interdisciplinary processes addressing all the issues of Chapter 1. For example, the design of motorcycle trail bike tires and mountain bike tires are very similar and both have the ability to introduce unwanted plant species when not addressed by the user. It is well documented that the greatest risk for the spread of Aquatic Nuisance Species (ANS) is through poor cleaning of fisherman’s waders and all types of watercraft.

WE REQUEST THAT THE AQUATIC ANALYSIS BE EXPANDED TO INCLUDE TO INCLUDE ALL RISKS AND EXPLAIN THE RELATIVE RISKS.

27.
Pages 91-128. Chapter 3. Wildlife-Affected Environment. This section was extensive and based on species specific analysis with a focus on management indicator species (MIS). A literature review was conducted (page 92) to research the effects of vehicle use and recreation on wildlife species. However, in the final application, risks ratings and habitat effectiveness are all based on motorized road and trail densities. For example, (page 105), potential impacts to elk as a MIS were only evaluated from the aspect of roads and motorized trails. This effort, as with the water, soils, wetlands, and fish sections, is short of analysis and disclosure of the effects of hikers, hunters, mountain bike riders and other non-motorized recreation that tends to stress and impact wildlife. It would seem that some better level of balance in literature reviews and a fuller discloser of all user impacts would be appropriate here.

An example of a single focus on just motorized recreation is involved with the proposed closing of the Dr Park/North Bank Trail. Closing the trail to motorcycles from May to September does not impact bighorn sheep any more than dogs, kids, and hikers. The trail that is being closed is on the extreme west side of the area and only a very small and limited area. There is more access by other users. It the Page 9 of 17 CDOW wants to protect the area, it should be closed to all users including the campground at the west end of the area. We are not aware of any study or research in this area that documents motorcycle/sheep impacts.

The purpose and need statement generally orients this DEIS and analysis around the need to designate motorized recreation routes. However, the planning issues selected, the hierarchy of users established, the alternative maps that assign different user groups to a segregated road and trail system, and the nature of the conflicts that need resolution (Chapters 1 and 2) require that the disclosure of effects in Affected Chapter 3 be broadly expanded to accommodate an integrated travel management plan.

It appears that some team members were dealing with just the direction to designate motorized routes and produce an MVUM, and others were trying to produce a more comprehensive travel management plan. This planning schism creates a problem in document review where issues and effects are difficult to track.

WE REQUEST THAT THE FEIS TRY AND ACHIEVE MORE CONTINUITY AND PARALLELISM BETWEEN ISSUES AND AFFECTS, LITERATURE REVIEWS AND SCIENCE APPLIED.

28.
Page 129. Recreation Opportunity. It would be helpful if the references and citations of recreation data were included in the Appendix. They are in the text but not in Appendix E.

There is a noted statement that says that “trails within Wilderness are not within the scope of this analysis”. We understand these are by law foot and horse trails, however, they do provide opportunity in unique settings that are not available to mechanized and motorized users, and therefore are a critical part of the “balance” of opportunity discussion and disclosure that must take place in this document for areas outside of Wilderness. We understand that the Wilderness areas will not be a part of the designated routes maps required by the Travel Rule, but they play a major role in the development of a hierarchy of recreation opportunities in the Gunnison Basin area.
 
WE REQUEST THE FEIS INCLUDE THE WILDERNESS ROUTES AS PART OF THE FOOT AND HORSE TRAIL MILEAGE AND DISCUSSION.

29.
Page 131. Recreation Settings. The recreation discussions and data in the Forest Service part of the document better address and follow the planning issues. However, there is no display of roads and trails by ROS settings (urban-rural-semi primitive-primitive) to evaluate satisfaction, motivation or benefits as the author first suggested in the lead paragraph.

In trying to determine the balance of opportunities by alternative among user groups it is left to the responders to apply their own knowledge of recreation settings within the Gunnison Basin planning area. Showing mileage only by user group is short of the kind of analysis this document needs to fully respond to the issues.

The subject of satisfaction and motivation from recreation activities (Brown and Haas 1980 and Manning and More 2002) is introduced in this section. However, the discussion ends without any application of the associated science cited. Additional references should include Driver, B.L. Benefits-based Management of Natural Areas, 1996; Driver, Brown and Peterson, Benefits of Leisure; and Clark, R. and G. Stankey, 1979, The Recreation Opportunity Spectrum (ROS), A Framework for planning, management and research. USDA-FS.

There is a follow up comment in the second paragraph, page 131, that states that their are two primary goals to obtain recreation motivation and experience: one, provide opportunities for people to obtain those motivations and experiences; and, two, minimize impacts on natural resources. Again, the goal is stated, but there is no follow-up definition of experiences, motivations, benefits and more importantly no narrative or map data to display settings by activity category.

Issues associated with recreation experiences, more primitive opportunities, reducing conflicts, maintaining wildlife escape cover, etc., can not be addressed without a display of the various recreation settings available by user group. There is just as much interest and benefit to the motorized or mechanized user in a primitive alpine setting as there is to the hiker in the same setting in Wilderness. The “finding the right balance challenge” is not solved by just a display of miles; the document must include a display of associated settings by user group.

WE REQUEST A COMPREHENSIVE ROS ANALYSIS PER THE ABOVE DISCUSSION.

30.
Page 140. Chapter 3 Recreation. Table 3-33. We are, of course, disappointed in the loss of motorized routes for jeeps, ATV’s and motorcycles in the Proposed alternatives. Overall, this represents an 8% reduction in opportunity from the historic (Alternative 1) from 525 miles to 481 miles. While this may seem like “not much”, it is the cumulative effects of years of losses on this forest, and the associated losses on other forests and public lands that keeps this issue unresolved and out of balance with demand and demographics. It is exacerbated by the fact that historic routes in semi-primitive settings are being substituted by miles in less satisfying settings.

It is clear that in order to minimize conflict on single track trails, these trail opportunities are being redistributed from the hiker/horse and motorcycle single track inventories to mountain bike use. We are supportive of a managed trail system that requires more tolerance for the sharing of access opportunities. We think the efficiency of shared trail systems and the lower associated costs for maintenance and enforcement would be of great benefit to the federal agencies.

WE REQUEST THAT MULTIPLE USE BE THE BASIS FOR THE FEIS, NOT SEGREGATION OF USES.

31.
Page 158. Affected Environment-Recreation on BLM Lands. The loss of 590 miles of road representing 35% of the opportunity for motorized recreation in the Proposed Alternative is a very significant change from historic use opportunities. It is another statistic that should be a part of a more fully disclosed Cumulative Effects analysis. Even though some of these routes were lightly used, they were apart of a unique opportunity for a certain segment of motorized users and hunters.

In addition to the loss of hundreds of miles of road the effect of an area-wide closure of 191,000 acres is another significant change to recreation opportunities. We fully support the objectives of the Gunnison Sage-grouse Conservation Plan (page 119). However, we hope that the monitoring component in this plan will objectively evaluate the buffer areas needed for breeding and nesting requirements. In particular, a 4.0 mile from lek (8 mile diameter) buffer to provide adequate breeding habitat seems on the surface as excessive. We will take a look at the science and management alternatives associated with this Conservation Plan.

WE REQUEST THAT THE FEIS REFLECT BOTH A CUMULATIVE EFFECTS ANALYSIS AND A MONITORING COMPONENT THAT ALLOWS FOR A PERIODIC ADJUSTMENT OF THE SEASONAL CLOSURES ON BLM LAND.
 
32.
Page 176. Table 3-34. Comparison of Alternatives. We would prefer to have the historic levels of motorized use under Alternative A, the No Action alternative. However, we recognize the efforts by the BLM to put together a responsive motorized Alternative 4, especially for the single track routes that help provide a continuity of loop routes.

33.
Page 182. Cultural Resources. Like other resource discussions in Chapter 3, this section address impacts of motorized routes only. Our concerns remain the same. The assignment of trail opportunities by user group via this DEIS and travel management process strongly suggests that a broader discussion of effects and risks on Cultural Resources by all users.

The Cumulative Effects section (page 183) avoids any discussion about displacement of user, by saying “it is based on social, economic, physical and personal preferences that are unknown in the context of the analysis”. This is a convenient way to avoid a social-economic assessment, which is already lacking in this document as a whole.
 
WE REQUEST A COMPREHENSIVE SOCIAL-ECONOMIC ASSESSMENT IN THE FEIS.

34.
Page 184. Societal Values. Noise, dust and vehicle speed are very non-traditional “societal value” subjects. They are generally outside of a discussion about social effects in more traditional social-economic discussions. These subjects or issues are more appropriately considered in discussions about air quality, transportation safety, or recreation user conflicts. By including those subjects here it distracts from the need to disclose the effects by alternatives on individual and community needs and benefits. The motivational and satisfaction of leisure time (see comment # 30) and the associated benefits to family and community relationships should be the focus of this section.

The economics analysis should include a more thorough expansion and discussion of existing data that can come from Gunnison County, the regional economic development and planning groups, and the expanded results of the Forest’s own National Visitor Use information. The scoping comments submitted by COHVCO and the TPA provided information on the 2000 Colorado OHV Economic Impact Study, which documents $500M in economic impact. This appears to have been ignored. An updated study will be available in the summer of 2009, and the Planning Team will be provided a copy.

WE REQUEST THAT A THOROUGH SOCIETAL VALUES ANALYSIS, INCLUDING OHV ECONOMIC IMPACT, BE INCLUDED.

35.
Page 203. Transportation System Effects. There is good recognition that “there will be a continuing demand for quality experiences by all travelers regardless of mode of travel”. The discussion follows on with a statement that says: “All alternatives address to varying degrees quality of experience”. We did not find the discussion about the components of quality experiences or the application of management techniques to supply the settings for enhanced recreation experience in most of the Chapter 3 Alternative discussions. The Chapter 3 discussions by resource area were generally about the effects of motorized routes on natural resources, and not about the effects of route selection to provide quality recreation experiences.

WE REQUEST THAT RECREATIONAL EXPERIENCE BE INCLUDED IN THE FEIS ANALYSIS.

36.
Page 208. Comparison of Maintenance and Decommissioning Costs. Table 3-41 is a handy chart that gives some good insight into costs. Our concerns are about the federal agencies being able to develop the congressional support for the needs outlined. This is true for both the maintenance needs of existing systems, as well as the costs associated with implementing a decommissioning program. A review of the Table suggests that there is $1 million savings per year if both agencies are combined. It has been traditional that any savings are not rewarded back to complete other work. Losses have been traditionally absorbed and high priority re-investment and maintenance work continues to be deferred.

This section does give recognition to the opportunity for grants, cooperative maintenance programs, and volunteer assistance. However, from an agency point of view, and with the exception of the Colorado State OHV Program, these resources are not predictable and are generally route or trail specific. We have enclosed, as an attachment to this response, a report that shows the level of funding and assistance that State OHV and club programs have provided since 1992. This report details what trails have been supported and shows $1.6 million has been awarded to Gunnison area trail programs. State registrations and permits are currently generating over $3 million per year and will continue to be available to roads, trails and programs for a variety of management needs. The No Action alternative shows annual maintenance costs of $92k/yr, and the current Good OHV Management grant is $60k/yr, without any route specific competitive grants. We think the display of this level of funding in the FEIS would help public understanding of the kind of support that is not only available, but received.

We are very concerned that there may be budget alternatives, and grant programs that will shift limited resources to restoration programs and further neglect the maintenance and recapitalization of the designated road and trail systems. A balanced budget strategy by the agencies is critical is this area to both rehab those areas of unacceptable resource damage and to maintain a road and trail system that serves both visitor and resource management needs.

It is our contention that the majority of routes slated for closure have not received any maintenance in the past 5-10 years, and maybe much longer. This is certainly the case for virtually all of the spur routes of short distances. The records of maintenance should be easily obtained and reported.

WE REQUEST THAT: 1) THE PLANNING TEAM UNDERTAKE AN EFFORT WITH COHVCO, AND THE TPA TO ADDRESS ANY MOTORIZED ROUTES THAT ARE BEING CONSIDERED FOR PROHIBITION TO MOTORIZED USE DUE TO MAINTENANCE/FUNDING, TO PROVIDE AN OPPORTUNITY TO MITIGATE THESE ISSUES PRIOR TO DECISIONS IN THE FEIS; and 2) THAT THE AGENCIES PROVIDE DOCUMENTATION ON THE MAINTENANCE EXPENSES FOR ALL ROUTES PROPOSED FOR CLOSURE IN ANY OF THE ALTERNATIVES.

37.
An analysis of roads and trails in Appendices A and B, and matching up the routes on the appropriate Alternative Maps shows significant deficiencies. The first issue is the inability of the public to identify many of the routes. Most of those that are designated with ‘UT’ prefixes, are not depicted on the Alternative maps, which is a clear failure in the NEPA process. The INFRA database numbers also do not have a direct relationship with the adjoining trail numbers. Dennis Larratt spoke to 3 other people in the USFS before being put in touch with Garth Gantt in Gunnison, who did a great job of providing Dennis with a map with the UT trails identified. This aided in our comments, but doesn’t help the rest of the public.

WE REQUEST THAT MAPS THAT CONTAIN THESE ROUTES BE PROVIDED TO THE PUBLIC IN A SUPPLEMENTAL EIS, SO THAT THE PUBLIC CAN COMMENT IN A MEANINGFUL AND COMPLETE MANNER.

37.
Table 1 below provides a summary of the impacts of the various alternatives on the different types of recreation. At first glance it appears that there is some semblance of balance amongst the various recreation types. However, these values are quite misleading, based on the multiple use concept, and the fact that lower types of travel are granted access to those above, e.g. Horses get to use Mountain Bike, Motorcycle and ATV routes.

Table 1, Calculated Trail Mileage by DEIS Method
    Existing (1) Preferred (2) Alt.3 Alt. 4

Sum 1429.58 1429.58 1429.58 1429.58
ATV ATV 164.94 84.95 46.94 120.52
Motorcycle MO 336.83 256.16 170.24 305.86
Mountain Bike MB 84.31 131.24 158.64 196.37
Horse HO 737.86 670.79 718.48 601.81
Foot F 8.77 8.77 6.18 8.77
Not Existing NE 60.75 34.01 34.01 0
Snowmobile SNO 3.28 3.28 3.28 0

Currently De-

commissioned

 DE 4.76 1.66 3.59 0.39
Decommission D 0 115.77 169.35 79.73

Unmanaged,
non-system

 U
100.6 103.12 96.72
All Other
categories 		  28.08 22.35 15.75 19.41

 

Table 2, Available Trail Mileage by Recreation Type
    Existing (1) Preferred (2) Alt.3 Alt. 4

Sum 1429.58 1429.58 1429.58 1429.58
ATV ATV 164.94 164.94 164.94 164.94
Motorcycle MO 501.77 341.11 217.18 426.38
Mountain Bike MB 586.08 472.35 375.82 622.75
Horse* HO 1323.94 1243.74 1197.42 1321.28
Foot * F 1332.71 1252.51 1203.6 1330.05
* includes the "unmanaged recreation" routes

 

Table3, Available Trail Mileage by Recreation Type,
with Wilderness
    Existing (1) Preferred (2) Alt.3 Alt. 4

Sum 1429.58 1429.58 1429.58 1429.58
ATV ATV 164.94 164.94 164.94 164.94
Motorcycle MO 501.77 341.11 217.18 426.38
Mountain Bike MB 586.08 472.35 375.82 622.75
Horse* HO 1863.94 1783.74 1737.42 1861.28
Foot * F 1872.71 1792.51 1743.6 1870.05
* includes the "unmanaged recreation" routes AND Wilderness routes

The differences by trail mileage shown in Tables 2 and 3 highlight the restrictive nature of the Travel Management Plan on motorized recreation, and how much more trail mileage is available to non-motorized recreation forms. The impact needs to be taken into context of how many miles per day these types of users travel. As an example, it becomes clear that ATV’s get about 3 days of opportunity (50 miles/day), while motorcycles get about 5 days of opportunity (100 miles/day), mountain bikes get about 24 days (25 miles/day), horses get about 65 days of opportunity (20 miles/day), while foot travelers get about 130 days of opportunity (10 miles/day). When the 540 miles of Wilderness trails are included, equestrian recreationists get over 90 days of opportunity and hikers get between 180-190 days of opportunity!

The point of this exercise is to remind the authors that additional mileage is warranted for motorized recreation, based on equitable need, financial support through grants and volunteer efforts. The continual decline in available trail mileage continues to show a bias against motorized recreation. It also results in concentrated use on the remaining routes, which provides fodder for the restrictive use groups to object to trail impact. Greater dispersion would result in less impact and happier recreationists.

WE REQUEST THAT AN ANALYSIS IDENTICAL TO, OR VERY SIMILAR TO THIS BE INCLUDED IN THE FEIS.

38.
Literally hundreds of routes are slated for decommissioning in Alternatives 2, 3, and 4. Because in most cases, this requires ground disturbing changes, NEPA requires that site specific analysis.

WE REQUEST THAT NO DECOMMISSIONING THAT REQUIRES GROUND DISTURBANCE BE CONDUCTED WITHOUT SITE SPECIFIC NEPA ANALYSIS.

39.
Route Summary Attached to these comments are Appendix II, Roads, and Appendix III, Trails. These spreadsheets highlight the motorized routes that are impacted by the DEIS in any of the Alternatives other than the Existing Condition. A Legend Page precedes the remainder of Appendix II, and provides the color code for route changes. These pages highlight the dramatic impact that the TMP is having on motorized recreation. Because the Roads section is 64 pages long, and many are unidentifiable UT routes, only the first 14 pages are provided in the printed version, but all are on the electronic version. We ask that these routes ALL be maintained open to motorized recreation, per the Existing Condition. We consider the following routes to be the most critical:

• All motorized routes that were not indicated for change in any DEIS Alternatives

• Agate Creek

• Lime Creek   

• Baldy Branch

• Crest Trail

• Quakey Mtn. West

• Napolean Pass

• Roaring Judy

• Teocalli Mountain

• Teocalli Ridge

• Eyre Basin

• ‘Spring Creek Trail’, from 759 South toward 880, UT-8282

• Star Trail connector to Spring Creek, UT-8283

• Grassy, 562

• Green Lake

• Mount Tilton Spur

• Waterfall Trail

• Crystal Peak

• Reno Ridge

• Cement Creek

• April Gulch – Beaver Creek

• Ferris Creek – Strand trail systems

• Matchless Mountain

• Lower Doctor Park to North Bank Campground

• Spur Trail and connectors

• Trails 559 and 560

• Route 243.3E

• 584.1A provides non-motorized access to the historic Enterprise Mine

• 410.0A

• 580

• 499/878

• 465/472

• 538 to 913

• 677.3 and 677.3C

• 461

• Sawtooth Trail System, per Item 25, Appendix IV a. County Road (Vulcan Rd) connect to FS trails 806 and 807, to County Rd. 149

• East – West Corridor FS 4WD 807 to BLM West Roads

• FS 4WD 808 to FS 4WD 821

• Gulch. Route 858 to 858.1 to Ohio Pass Road

• Low Line Trail Area 438 to BLM 818 (concern of illegal Wilderness buffer)

• 807 to 559

• 854 to 806

• Unnamed trail E. of Pearl Pass, past Friends Hut •

• Maintain all routes identified in Charles A. Wells “Guide to Colorado Backroads & 4-Wheel Drive Trails”, 2nd Edition, FunTreks, Inc.

• Currently single track, numbered as 499 and 878 on one set of maps, and 749 on the UT map, is slated for conversion to mountain bike use. But this trail continues in the Rio Grande NF as Trail 787. We request that this stay open to motorcycles.


40. We also question the legality and legal status under NEPA of the new designation of ‘unmanaged recreation’ routes that are de facto a creation of the publication of the MVUM under the Travel Management Rule of 2005. Under current Forest Planning Rules, and general USFS guidelines, we find no legal authority for maintaining routes for any form of recreation that are non-system routes or have no NEPA and are only identified as closed to motorized. What is their legal status? It runs counter to the rhetoric of user created trails to leave these routes in unmanaged limbo.

WE ASK THAT THE UNMANAGED RECREATION TRAILS BE RECONSIDERED FOR MOTORIZED RECREATIONAL USE, OR PROHIBITED FROM ANY USE. . IN THE ALTERNATIVE, ANY ROUTES NOT CONSIDERED AT THIS TIME FOR MOTORIZED TRAVEL SHOULD BE CLEARLY IDENTIFIED AS AVAILABLE FOR FUTURE MOTORIZED SYSTEM DESIGNATION.

Summary
We have enumerated nearly 40 points of weakness or failure in the DEIS. We feel that only Alternative 1, the No Action Alternative, is a viable alternative in the FEIS. While we feel this is the only viable alternative, we understand from senior sources in the USFS and BLM that these No Action Alternative options are NEVER selected. Therefore, we offer to continue to work with the planning and recreation teams to come up with a viable alternative that is not punitive to the motorized recreation community, takes into account the issues we have raised, and utilizes multiple use and mitigation as primary tools, rather than last resort efforts. While our scoping comments, Appendix IV were largely overlooked, we thank you for your serious consideration of these comments and hope to work together to come up with a workable plan.