The TPA comments are submitted as a result of the Pike San Isabel Law Suit, brought by the Wilderness Society and Quiet Use Coalition against the USFS.
Below is the Executive Summary, the consolidated comments can be found in the attached PDF.
Attn: Erin Connelly, Forest Supervisor
The Pike and San Isabel National Forests, Cimarron and Comanche National Grasslands
284 Kachina Drive Pueblo, CO 81008
Pike & San Isabel National Forest, Travel Management EIS Initial Comments -‐ EXECUTIVE SUMMARY
Dear Supervisor Connelly:
Please accept these comments on the Pike & San Isabel National Forest Travel Management EIS Project on behalf of the Trails Preservation Alliance (“TPA”) and the Colorado Off-‐Highway Vehicle Coalition (“COHVCO”). The TPA is volunteer organization created to be a viable partner assisting 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 works to help ensure that the USFS allocates fair and equitable percentage of public lands access to diverse trail riding opportunities. COHVCO is a grassroots advocacy organization representing approximately 170,000 registered off-‐highway vehicle (“OHV”), snowmobile and 4WD users and is a member supported 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.”
As stated in Notice of Intent (NOI) for this project, the Purpose and Need for this Action is “…to improve management of motor vehicle use…” the Organizations contend that in order to “improve” the management of motor vehicle and OHV use, an adequate and varied inventory of routes (i.e., roads and trails) that fulfills the user’s spectrum of needs (today and into the future) for variety, difficulty, destinations, challenge, terrain and scenic opportunity will lead to improved management and compliance. Closure and a reduction of recreational opportunities and the resulting concentration of the ever increasing number of users does not provide a balanced solution to meeting the needs of the recreationalists and other legitimate forest users. This stated Purpose and Need (as published in the NOI) needs to “guide” the process throughout the duration of this action and be utilized to impartially evaluate each alternative.
At this time, The Organizations generally support the proposed Alternative D with modifications. Fundamentally we support Alternative D with immediate implementation of the South Rampart Travel Management Plan (SRTMP) (specifically SRTMP Alternative – The Preferred Alternative) and consideration of our comments and modifications for specific roads and trails that we have provided for each individual Ranger District.
The economic impacts of multi-‐use and motorized recreation within the counties and communities encompassed by or adjacent to the Pike & San Isabel National Forest cannot be overlooked. Many of the visitors that choose to visit the Forest combine their recreational activities and often include using forest routes to access camping sites, setting up a camp and then employing motorized means to travel and explore the surrounding environment. Significant economic benefits are realized by all of Southern Colorado as the public travels to and from their valued destinations within the Pike & San Isabel National Forest. As an example, motorized recreational enthusiasts were responsible for approximately $1.6 billion in direct expenditures relating to motorized recreation in Colorado during the 2014-‐2015 season1 As popular as motorized recreation is within
the Pike & San Isabel National Forest, the economic benefits to local economies and nearby communities must not be undervalued.
The organizations feel that this project must work diligently to ensure that balanced continuum of opportunities are provided in the Pike and San Isabel National Forest to properly serve the diverse cross section of our population and meet their recreational needs. We reasonably expect that this project will fairly and adequately provide an Environmentally, Economically and Socially sustainable end state that supports multi-‐use recreation.
Our two organizations have solicited input, comments and suggestion from our members, supporters and diverse collection of motorized recreation enthusiasts and and have developed our consolidated comments based upon that input. The following statements summarize our comments:
- With few exceptions, the roads and trails throughout all six Ranger Districts (including the routes listed in Exhibit A of the Settlement Agreement) have been in existence and providing public benefits for decades. History has shown that each of these routes provides a level of tangible recreational, economic and/or forest access value.
- The Hayman Fire (and Waldo Canyon Fire) demonstrated firsthand the advantages of having a robust and interconnected network of routes. Continuing to have an adequate network of forest roads and trails will be truly beneficial and necessary in providing sufficient access for future timber management, continuing forest visits and recreation, emergency egress and wildland firefighting efforts.
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- In general we encourage and support the decisions to convert most any existing National Forest Service Road (NFSR) to Full Size Trail or another trail designation (e.g., Trail open to Motorcycles, or open to Vehicles 50” or less in width). We encourage the use of conversion techniques contained in Chapter 17 of the National Off-‐Highway Vehicle Conservation Council’s (NOHVCC), (2015) Great Trails: Providing Quality OHV Trails and Experiences. Conversion of roads to “multi-‐use trails” will also make those routes eligible for Colorado Parks and Wildlife OHV grant funds.
- We encourage this project to consider the inclusion and adoption of more “non-‐system” roads and trails to help meet the Forest’s ever increasing demands and needs such as timber and fuels management, fire mitigation work, fishing, driving for pleasure (including OHV’s), viewing scenery and wildlife, utilizing developed and dispersed camping sites and picnicking. (This adoption of previous non-‐system trails would not be unprecedented as demonstrated by the recent action by the Pikes Peak Ranger District to adopt the Buckhorn Trail in the Bear Creek Watershed area from a “user created” trail to “system” trail).
- In general the Organizations d not support the conversion of routes to “Administrative Use Only”.
- Properly constructed roads and trails within the forest coupled with sensible timber management will all help to mitigate any effects of climate change both today and into the future. Minor adjustments to USFS design criteria can also be used to mitigate more extreme weather events and any increased runoff that might be attributed to climate change.
- By providing an adequate and varied inventory of routes and trails that fulfills the multi-‐use and motorized user’s spectrum of needs (today and the future) for variety, difficulty, destinations, challenge, terrain and scenic opportunity will lead to improved management and compliance requiring less expenditures on maintenance, signage, enforcement, etc.
- The roads and trails in Hackett, Longwater and Metberry Gulches along with Coral Creek (AKA The Wildcat Canyon Area) have long been enjoyed by enthusiasts and recreationists and were a longtime favorite for access to and across the South Platte River. Rather than allowing the Hayman Fire to permanently take away a treasured resource from public use, the Organizations strongly support the reopening of these routes (e.g. as Full Size Trails) between all of the adjacent Ranger Districts and Counties. Deliberate efforts need to be made to provide environmentally friendly and sustainable crossings across the South Platte River. Technical, engineered solutions to cross the river are indeed possible and must be explored, planned, designed and implemented.
- The public will be solely dependent upon the Pike & San Isabel National Forest Staff to ensure that any and all requirements and recommendations for seasonal closures are fair, reasonable, rational, unbiased and in the very best interest of the spectrum of users. Natural route closure generally occurs during the winter season due to snow. Wherever possible, if the seasonal conditions on the ground are likely to represent an effective barrier to travel, the Forest should avoid implementing seasonal closures that create confusion and create an unnecessaryenforcement and financial burden. Seasonal closures that affect only motorized users, are inconsistent with the best available science for protecting habitat and seasonal closures should be made universal to all users.
- Closing routes to OHV use does not eliminate the need for maintenance, but makes those routes ineligible for Colorado Parks and Wildlife OHV grant funds, one of the available funding sources and tools that can be used to provide needed operations and maintenance resources. The lack of fiscal capacity by the USFS should not be criteria for, or lead to closures and reductions in public recreational opportunities, closure of routes or elimination of public access to the National Forest.
In conclusion, the Organizations are pleased to offer our collective assistance and expertise to this extremely important project. We firmly believe that multi-‐use access and motorized recreation within the Pike & San Isabel National Forest is, and will continue to be, vitally important to the economic vitality of Southern Colorado and an expected component of the recreational experiences provided by our public lands. We stand behind sustainable and robust network of multi-‐use/motorized routes and trails that sufficiently serve the needs and demands of all forest visitors. Finally, we feel it is obvious but important to acknowledge that as the population along the Colorado Front Range continues to grow, the needs and demands for multi-‐use and motorized recreation will only escalate and that it will be imperative that the Pike & San Isabel National Forest works diligently to serve the public by professionally managing and providing the necessary recreational opportunities that support multi-‐use and motorized recreation.
We thank you for reviewing and considering these comments and suggestions. The Organizations would welcome a discussion of these opportunities at your convenience. Our point of contact for this project will be William Alspach, PE at 675 Pembrook Dr., Woodland Park, CO, 719-660-1259.