Rico West Dolores comments

June 05, 2016 7:02 AM | Anonymous member (Administrator)

The below document was submitted on behalf of the Board and Membership. Please review this document as a tool to craft your own comments from.

 

Dolores Ranger District, San Juan National Forest                                        June 2, 2016

29211 Hwy. 184

Dolores, CO    81323

Attn:  Debbie Kill, Derek Padilla

dkill@fs.fed.us dpadilla@fs.fed.us

Re:  Rico-West Dolores Roads and Trails (Travel Management) Project

       Draft Environmental Impact Statement

Ms. Kill and Mr. Padilla:

San Juan Trail Riders (SJTR) of Durango, CO representing a single-track motorized membership of over 400, wishes to comment on the proposed Alternatives presented in the recently released Draft Environmental Impact Statement (DEIS)  for the Rico-West Dolores (RWD) Project Area. 

The SJTR Organization has elected to comment briefly on each Alternative and more extensively on the one proposed Alternative (if modified slightly) that would best suit the long-term needs and expectations of our constituency. 

Alternative A

Even though this Alternative (the “as is” conditions) offers a good number of desirable existing and designated routes, it falls short of building on a key strategy needed to fully complete: “loop” opportunities, system access N. to S. and S. to N. across highway 145, access to Haycamp Mesa from Morrison 610, completed easement for the connection of Winter Trail to East and West Fall Creek Trails, the addition of Loading Pens Trail and completed connections of Spring Creek Trail and Wildcat Trails.  Additionally, the seasonal restrictions applied to this Alternative would need an adjustment of 1 June to 31 October.  SJTR believes that this Alternative, even though listed in the group, very rarely gets earmarked as a final selected Alternative.  However, if all of the above listed additions of trail segments/sections/restrictions adjustments, etc. were added to the current single-track motorized system, this Alternative could be considered supportable.

Alternative B

This Alternative would be considered totally unacceptable to the single-track motorized user group and appears to fall short of purpose and need of the project.

Alternative C

This Alternative, which offers new opportunities for increased OHV recreation by other than single-track motorized users, it falls extremely short in meeting needs and expectations of the single-track motorized user group.  There is an overall loss of single-track trail miles, it breaks connections N. to S. and S. to N. across the landscape, it places trail motorcyclists in a difficult position as to how to access trail connections other than by highway travel, it fails to provide much needed “loop” connections, it does not extend the Wildcat Trail to connect to Burnett Creek Trail, it eliminates the historically motorized designated Ryman Creek Trail, it takes a critical long- used section of Bear Creek out of the motorized system, it removes motorized access at Bear Creek trailhead, it breaks up the Winter Trail connections and it does not provide the needed access to Haycamp Mesa through the Morrison Trail 610 easement.  SJTR and the membership find themselves unable to support this Alternative in its current form.  Support of this Alternative shall be presented by SJTR and its membership as ALTERNATIVE C (modified)

In the ALTERNATIVE C (modified) version it would include the following changes to gain consideration for support.

  • 1.       Ryman Creek Trail would remain a part of the single-track motorized system. (SJTR) could support replacement of Ryman with the SJTR proposed Salt Creek Trail. 

  • 2.      Extend Wildcat Trail from its currently designated amount of trail (to the alternate suggested trail head) on to the old Railroad Grade and connect to the old Rio Grande Southern grade towards Burnett Creek Trail.  SJTR has asked the FS to consider a designation of Tenderfoot Trail as non-motorized as a trade for the full motorized designation of Wildcat Trail. 

  • 3.      If the long designated Bear Creek Trail is considered for re-designation, the trail head at Bear Creek cannot be lost to single-track motorized users and an alternate route such as the proposed Little Bear Trail (which got no analysis after being proposed by SJTR) could be accepted as a commensurate replacement connecting back to Grindstone Trail. 

  • 4.      Because of the critical importance of connections back to Haycamp Mesa, SJTR would again ask the FS to revisit the Morrison 610 easement agreement back to 610 Trail and/or provide a re-route of Morrison Trail 610 around private property across Bear Creek to the Little Bear Trail.

  • 5.      SJTR and its membership find the seasonal travel limit of June 1 to October 31 a consideration for support.

  •  

Alternative C (modified) Summary

  • ·         Ryman Creek has a very long history of motorized designation, has not required extra ordinary maintenance to keep it in reasonable condition and was not listed in any FS report or in the testimony given to the 10th Circuit that this trail should be removed from the current motorized system.

  • ·         Wildcat Trail is currently designated (by ½ the length) as motorized.  A complaint from a grazing permitee in the Wilcat Trail area hypothetically portrays motorcycle use of the lower half of this trail as devastating to the “scattering” of his herd of cattle.  SJTR contends that there has been no evidence documented anywhere across the San Juan National Forest that motorcycle use or any other motorized use “scatters” cattle unacceptably.  Additionally, this trail has been identified as having steep grades and it does.  However, other motorized trails across the SJNF exhibit very similar grades and soil conditions and have maintained their sustainability over many decades.  This trail is a critical “loop” connection for trail motorcyclists so that highway 145 travel is not required to keep trail travel by single-track motorized users within the system.

  • ·         Bear Creek Trail has been a motorized single-track route in the system for more than 5 decades.  This can be validated by existing FS maps used for many years.  SJTR, its membership and other constituents cannot accept removal of this trail from the motorized system along with the highway 145 trailhead without some commensurate replacement.  Little Bear Trail (although not nearly as challenging and enjoyable) seems to be the only reasonable replacement for the highly valued Bear Creek Trail.  We therefore submit a request that the FS revisit our recommendation of the Little Bear Trail replacement for the main section of Bear Creek Trail.

  • ·         SJTR has long requested the reinstallation of the Morrison Trail 610 easement to the main trail.  This trail has been used by motorcyclists for more than 3 decades before it was re-designated a few years ago because of a bullying effort by the landowner that the easement passes through to do so.  We believe, in a parallel analysis of the easement agreement, that the FS has every right to allow motorcycle travel through this easement.  There are no restrictions identified on the easement documents and the public has no restrictions on Stock Driveway use.  We also believe that the District Ranger has a right to decide in favor of the general public to maintain this easement as an important access to Haycamp Mesa for single-track motorized users and others.

  • ·          We believe that the District Ranger also has a second option to provide access for motorcyclists to the main Morrison Trail through a lower section of Morrison Trail re-route (very short section) around the private property across Bear Creek to Little Bear Trail.   We respectfully request that a new consideration be given to these options for Morrison Trail 610 access. 

  • ·         SJTR, its members and other constituents concede that an adjustment to a motorized access time period June 1 to October 31 would not seriously degrade the riding experience of the upper RWD motorized trails if it is imposed by this project.  However, it should be noted that nowhere in the ID Team Analysis does the use of motorized travel on these upper trails appear to negatively impact game in the area to any large degree.   Nor does the proposal to limit the use of single-track motorcycles on trails for specific times of the season yet at the same time extending ATV vehicle use for longer seasonal periods seems highly unjustifiable and somewhat discriminatory.   Therefore overall there really seems to be no justification for the seasonal travel restrictions.  Weather has historically provided restrictions of motorized travel and it has no history of not being respected.  Elk herds are maintaining and even increasing their levels and game harvest has not shown to be decreasing relative to licenses purchased.  No other resource issues were noted by early entrance into the area by motorized travel. 

Alternative D and E

These alternatives, if either would be selected, would so devastating to the future of single-track motorized recreation and the entire current single-track motorized system, that SJTR could not support either unless they were reconstructed in a highly modified form.

Summary

SJTR, its members, other constituents and support organizations applaud the work completed by the Interdisciplinary Team on this project.  Through their analysis of the resource and any associated social issues the conclusions are clear that there are few major concerns that should significantly alter the current use of the single-track motorized recreation system in the RWD Landscape other than to add a very few short trails and sections of trails to enhance the system.    The single-track motorized system use in the RWD Landscape has been rated by the FS as low to moderate, few resource issues have been identified and general cooperation by user groups of the trails prevails.  Increasing opportunity for other OHV users makes perfect sense in light of the increasing demand across the Southwest and the Nation as a whole for more motorized routes.

 However, many of the conclusions that the ID Team makes regarding “quality vs. quantity” of trails, how trail rides might be taken by riders to optimize their pleasure, etc. are a complete disconnect from what single-track motorized users actually prefer in their riding opportunities.  SJTR sees no evidence that the FS has the expertise nor have they enlisted trail riding motorcycle experts to help make any valid conclusions in some of their assessments included in the analysis.  

SJTR has requested on multiple occasions any evidence that would document safety, social or individual conflict issues that might “red flag” problems throughout this current motorized system.  Nothing has been provided.  We profess that the District is being pressured (bullied) by a handful of individuals who in most cases have never been seen on these trails at any time by motorized user groups.  In addition some of the registered complaints regarding motorized trail use are being raised by those who do not even live in this area and/or those who expect to gain financially by restricting motorized trail use in, around or near their private holdings.  The presented Alternatives in the DEIS have created the appearance of a deliberate attempt to segregate and isolate the single-track motorized user group from non-motorized users where possible in the RWD trail system.  We respectfully request that the District Ranger reject this pressure and focus on the protection of the resource as a basis for all Travel Management decisions in the final project decisions.

Respectfully,

San Juan Trail Riders Board of Directors and Membership

  

 

 

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