Badger Flats Management Project

Badger Flats Management Project #48069
Attn: Josh Voorhis, District Ranger
South Park District Ranger
P.O. Box 219
Fairplay, CO 80440

RE: Badger Flats Management Project

Dear Ranger Voorhis:

Please accept these comments on the Badger Flats Management Project on behalf of The Trails Preservation Alliance (“TPA”) The Colorado Off-Highway Vehicle Coalition (“COHVCO”).   The TPA is a volunteer organization created to be a viable partner to public lands managers, working with the United States Forest Service (USFS) and the Bureau of Land Management (BLM) to preserve the sport of trail riding.  The TPA acts as an advocate for the sport and takes the necessary action to insure that the USFS and BLM allocate a fair and equitable percentage of public lands access to diverse trail riding opportunities. COHVCO is a grassroots advocacy organization representing approximately 150,000 registered off-highway vehicle (“OHV”) users in Colorado seeking to represent, assist, educate, and empower all OHV recreationists in the protection and promotion of off-highway motorized recreation throughout Colorado. COHVCO is an environmental organization that advocates and promotes the responsible use and conservation of our public lands and natural resources to preserve their aesthetic and recreational qualities for future generations.  TPA and COHVCO are referred to collectively in this correspondence as “The Organizations.”  The Organizations offer the following comments and concerns regarding this project.

  1. We acknowledge that the South Park Ranger District has struggled with the proliferation of non-system trails in the Badger Flats area and the increased demands for camping.  However, we feel much of this stems from an increasing need and demand for motorized recreational opportunities on public lands in general and especially near urbanized areas along the Front Range of Colorado.  Badger Flats is unique in that it is within 60 miles of Colorado Springs, the second largest city in Colorado with a population well over 400,000.  As the State of Colorado’s population has grown, so have the sales of Off Highway Vehicles (OHV’s), camping units and other forms of outdoor recreation increasing the demand for recreation sites like Badger Flats.  Because of the flat and rolling terrain of the Badger Flats, this area offers very unique opportunities for beginner riders, families with children and groups wishing to ride together.  The opportunities available in Badger Flats are truly unique and are unmatched by any other location within the Pike San Isabel National Forest. We would offer that much of the increase in illegal user-created routes, braided routes & trails and large unauthorized group campsites are a result and reflection to inadequately meet the needs and demands of the public and the recreational users who choose this area.  An adequate and varied inventory of routes and trails that fulfills the user’s spectrum of needs for variety, difficulty, destinations, challenge, terrain and scenic opportunity will lead to improved compliance and less off route travel.  Closure and reduction of recreational opportunities and the resulting concentration of the ever increasing number of users, has shown again and again that the desired results are not obtained.
  2. We applaud the South Park Ranger District’s goal (as conveyed in the public Open House, on December 17, 2015 in Woodland Park) to maintain a “system” network of roads and trails with a similar total aggregate mileage.  That the length of closures will be approximately equal to the length of new roads and trails added to the system.  However, we are concerned that there will be a significant loss of road and trail opportunities when a large number of the “non-system” roads and trails are closed or decommissioned.  Once again the proliferation of these non-system roads and trails is likely linked to an ever increasing demand for multi-use recreational opportunities.  We would encourage the South Park Ranger District to consider inclusion and adoption of more “non-system” roads and trails to help meet the area’s recreational needs and demands.  This adoption of previous non-system trails would not be unprecedented as demonstrated by the recent proposal by the Pikes Peak Ranger District to adopt the Buckhorn Trail in the Bear Creek Watershed area from a “user created” trail to a “system” trail.  We would also question if any of the “non-system” routes designated to be closed or decommissioned were indeed historic routes that existed prior to 1984, and may have been omitted from the Motorized Vehicle Use Map (MVUM) development process.
  3. The economic impacts of recreation within the Badger Flats area cannot be overlooked and is certainly important to Park County and the surrounding Counties.  Significant economic benefits are realized by all of the nearby communities such as Lake George, Woodland Park and Divide among others as the public travels to and from the Badger Flats area.  Badger Flats provides unique opportunities for motorized recreation because of its terrain and close proximity to the Front Range.  Both residents and non-residents travel to this area to participate in the unique OHV opportunities afforded by the Badger Flats area.  As an example, motorized recreational enthusiasts were responsible for $990 million in direct expenditures relating to motorized recreation in Colorado during the 2012-2103 season.1   As popular as the Badger Flats area is, the economic benefits of this area to the surrounding local economies of nearby communities cannot be undervalued.
  4. Below are specific comments relating to the proposed action:
    1. Road and Trail Comments:
      1. The closure of Forest Service Road (FSR) 704 (vic US 24 and PRK-90) appears to leave only an isolated section of FSR 704 open to use?  How will this trail segment be accessed?  Will public access to St. Joe Tunnel still remain?
      2. Suggest considering a connection and road/trail loop development between the FSR’s on the south side of US 24 (e.g. FSR 860) across US 24 to FSR 704/704.C.  Re-evaluate closure of FSR 860.A as there are several select camping sites along that road.  Rather consider a connection from the intersection of FSRs 860 and 860C northward to tie into FSR 860.A.
      3. We would encourage more opportunities like the proposed FSR 247 & 259 loop.
      4. Please clarify intentions for changes to the FSR 213 corridor between PRK-31 and PRK-77.  The depictions on the map do not adequately convey the intentions of the combined closure and adjacent proposed new FSR.
      5. Reconsider keeping the FSR 214.B loop open.  This adds opportunities and loop opportunities for OHV recreation in and around the proposed designated dispersed camping areas along FSR 214.C and 206.A1
      6. We understand the need to close FSR 44 (along with FSR 44.2C, 44.2B and FSR 280) on the west side of La Salle Pass is due to an existing eagle’s nesting area.  Closure of this road eliminates the small loop and option for alternate routes to La Salle Pass.  We would offer that this closure should be temporary, and in the future if the eagles are no longer in the area, that this road be reopened.
      7. Consider creating & enhancing a larger loop opportunity as follows:
        1. Begin near the intersection of FSR 313 and PRK-31, travel east on FSR 313 to PRK-77
        2. North along PRK-77 (as proposed)
        3. Along FSR 212.A to FSR 212
        4. Consider a new connection from the intersection of FSR 212 and PRK-77 west to the intersection of PRK-31 and FSR 231/230
        5. This enhances the opportunities with the proposed FST 230 and FSR 237 changes
      8. Consider a parallel OHV route along PRK-31 to connect the proposed designated dispersed camping areas near Round Mountain with FSR 213 and the associated routes north of FSR 44
      9. The steep section of FSR 295, just north of the gate near the intersection of FSR 295 & 296 could use some maintenance and or consideration for re-routing to increase sustainability of the road
    2. Camping Comments:
      1. How will enforcement and signing of newly designated dispersed camping areas be accomplished.  The localized and specific limits of the proposed designated dispersed camping areas appears to be more difficult to enforce and maintain then designating simple corridors (e.g. 300-ft each side of a road)
      2. What are the proposed limits (i.e. how many feet) for the proposed designated dispersed camping areas from the edge of the roads?
      3. Since the choices of locations to camp are being curtailed, how will the proposed designated dispersed camping areas be maintained for safety, such as hazard trees, location of camp fires, shooting, etc. to name a just a few?
      4. How has the capacity of camping sites/opportunities been impacted by the proposed changes?  What are the approximate numbers of camping opportunities/sites lost or eliminated versus new ones created?  There appears to be a significant loss of camping opportunities?
  5. Conclusion

The Organizations generally support the proposed action for the Badger Flats Management Project.  We acknowledge the need by the USFS to improve the management of recreation in this very popular and unique area.  However, we would offer that better compliance and improved management stems from adequately meeting the recreational needs and demands of the users.  We fully understand and support your mission to protect and preserve our precious forest resources, to manage all of the competing uses of the forest, but that mission must be fulfilled while simultaneously providing the resources and recreational opportunities for the public to enjoy in a manner that fulfills the needs and demands of the public.  Solely reducing or curtailing OHV recreational opportunities in Badger Flats will likely not achieve the management objectives for the area, but a comprehensive approach to provide an adequate and varied inventory of routes and trails, that fulfills the OHV user’s needs for variety, difficulty, destinations, challenge, terrain and scenic opportunity will improve compliance and less off route travel.

The Organizations would welcome a discussion of these comments at your convenience.  Please feel free to contact Bill Alspach at 675 Pembrook Dr., Woodland Park, CO 80863, 719-535-0291 or Cell 719-243-7361

D.E. Riggle, Director of Operations
Trail Preservation Alliance

cc Scott Jones, COHVCO
Jerry Abboud, COHVCO

1 Economic Contribution of Off-Highway Vehicle use in Colorado, August 2013