April 16, 2012
South Platte Ranger District
Trail Creek Road and Trail Work
19316 Goddard Ranch Court
Morrison, CO 80465
RE: Trail Creek Watershed road and trail project
Dear Planning Staff;
Please accept this correspondence as the initial joint response to the above public notice of the open scoping period. This is a joint response from the Trails Preservation Alliance (TPA) and the Colorado off highway Vehicle Coalition (CORVCO). For purposes of these comments, CORVCO and TPA will be collectively referred to as “The Organizations”. The Organizations represent the majority of the off road vehicle users in the state and have a long history of working with the USFS and BLM on off road recreation issues. The history and work of the TPA can be accessed at www.coloradotpa.org, COHVCO can be found at www.cohvco.org. Our remarks are consolidated to allow the USFS to understand the severity of our concerns about the above public notice.
ORV recreation is a growing sport in Colorado, and actions to reduce existing areas to ORV recreation, will only result in over use of the remaining areas. As a result, the Organizations believe it is critical that ORV resources in this area do not drop below levels provided prior to the Hayman Fire. The TPA and CORVCO are willing to work with the FS on all issues in the “717” area.
Length of initial comment/scoping period
The Organizations had initial concern regarding the exceptionally short notice 14 day period provided in the initial scoping notice published in The Gazette. While 14 days is theoretically enough time to comment, actual notice of the comment period was not brought to our attention until hours before the technical comment end. While the Gazette is read by our members, the review is often less than complete when notices are reviewed. Please don’t interpret our members lack of interest in the notice as a lack of interest in the riding opportunities that were lost as a result of the fire.
Our concerns on this issue were mitigated by the fact that the District is willing to accept comments submitted after this comment period. Our concerns are further mitigated by our understanding that an additional 30 comment period is going to be provided for scoping in the near future. Our involvement in numerous Forest Service plans throughout the state, has highlighted one critical issue in the scoping process. If there is even the possibility that the public has not been aware of the project form the beginning, any closure, no matter how minimal will be viewed by certain groups as closing public lands to the public. This perception, no matter how incorrect it is or good the plan is overall, can be very hard to remove from any plan. Without true public comment and involvement in the planning process, a quality result simply cannot be developed.
As noted above, knowledge of the scoping period was somewhat limited. The Organizations learned of the comment period when a member of our Organizations forwarded his proposed comments to us for reference. We totally support the attached letter from Mr. William Alspach, his engineering expertise and detailed knowledge of the “717” area are such that the USFS should take notice of his recommendations for both the technical engineering aspects of the FS plan, and also for his comments on the proposed OHV closures and re routes. Instead of rewording the detailed remarks of Mr. Alspach, our comments are going to cover the real world ramifications of the proposed FS plan. The entire “717” area is a prime OHV recreation area for all types of OHV’s (ATV, Me, 4wd). It is heavily used by all, year round, and is a great positive economic factor to the local mountain communities.
The “717” was dealt a drastic destruction during the Hayman fire. (USFS personnel started). A significant portion of the area was destroyed and closed to OHV recreation. And the majority of it remains closed today. These closures only increased the recreation use on the remaining areas that were left open. Many meetings and discussions have taken place since the fire, about when will areas be re opened, trails rebuilt, etc. Most discussions on these topics ends up in a discussion about lack of resource of the FS to reopen to the original OHV recreation routes.
You combined this with the fact that the “717”, is a primary beneficiary of significant State Parks OHV funding, for both the maintenance of the area and also for the inventory of the area. And now you are proposing major closures of areas that have benefited from the OHV funding. Please keep in mind that we are the only recreation group that pays for our form of recreation. The Organizations both request that the FS provide detailed explanations of why this work is needed. We also request that NEP A be conducted for all closures, decommissioning actions and any re routes. You current plan and limited explanation of the proposed work is not acceptable.
Route specific concerns
The Organizations believe that most route specific concerns are addressed in Mr. Alspach’s correspondence. The Organizations are vigorously opposed to the fact that under the current preferred alternative of the plan, FSR366 will simply dead end north of Trail 717, rather than connect to Route 3. Both FSR 725 and 366 are closed without exploration of possible reroutes in the area to maintain this connectivity and loop opportunities. This is simply unacceptable and will create a trail that will be ripe for closure in future planning efforts since it is a dead end.
Conclusion & Recommendations
The Organizations look forward to partnering with the FS to maintain access to the recreational opportunities that were provided before the Hayman Fire. This access will be critical to quality recreational opportunities for all forest users. With this in mind, the Organizations propose the following:
1. No decomissioning, closures, reroutes in the “717” area be conducted until all original “717′ OHV recreation routes destroyed by the Hayman fire are returned to a standard that will allow complete OHV recreation access;
2. For any closures or existing OHV reroutes, that a mile for mile exchange be made, you close one mile of OHV routes, then the FS open up an equivalent mile of OHV routes;
3. FSR 366 must not be decommissioned in such a manner as to leave a dead end trail;
4. The FS should hold public meetings on this issue, and form an ad hoc committee of local OHV recreation personnel ( ATV, Me, 4wd) to work with the FS. This will allow public “buy in” and understanding of what issues the FS has and what actions can be taken other than closures of routes; and
5. Since State Park OHV funds have been spent in this area, no trails or roads that have benefited
6. We request a complete listing of all “non system” routes that are going to be closed with this planned action, and that they remain open until the entire pre fire OHV routes are reestablished. Please accept our comments. Any questions should be directed to the below, and will be disseminated as needed.
note: see attached PDF for referenced letter from Mr. William Alspach