22 August 2003
Thank you for providing this opportunity to comment on the Scoping Document for the Ogden Ranger District Travel Plan Update, dated 18 July 2003. The comments herein are submitted on behalf of the Sierra Club, The Wilderness Society, and the Citizens' Committee to Save Our Canyons. As you know, these organizations represent thousands of individuals living in northern Utah who care about the resources and opportunities in our area's National Forests.
The first paragraph of the document refers to "changes in recreation demands" but does not say what these changes have been or whether the Forest Service has more than an anecdotal understanding of the changes. The third paragraph states that "motorized uses are increasing rapidly," but does not quantify this increase, nor does it mention whether nonmotorized uses are also increasing. (Even if nonmotorized uses have decreased or remained small in certain areas, any need for change would depend upon whether this is due to public lack of interest, lack of promotion of nonmotorized opportunities by the Forest Service, and/or nonmotorized users wanting to avoid areas of current motorized activity.) The next sentence mentions "new technologies," but does not state what these new technologies are or how they might be relevant to the travel plan. (For example, if new vehicles are capable of ascending 45-degree inclines, does this mean that the Forest Service will provide designated travel routes with 45-degree inclines? If vehicles are capable of traveling at 80 mph, does this mean that the Forest Service will provide designated routes that can be ridden at such a speed?) We would like to point out that mountain bikes are a relatively new technology that has become immensely popular since 1988. The need for safe trails for mountain biking, away from motor vehicles and heavy pedestrian traffic, is also relevant to the travel planning process.
From conversations with you and your staff, it is our understanding that the Forest Service has no quantitative data on current levels of dispersed recreational use within the Ogden Ranger District. To establish any need for change, the Forest Service needs to quantitatively assess the current levels of use by hikers, mountain bikers, equestrians, motorcyclists, ATV riders, HCV drivers, and SPV drivers. While it is impossible to obtain perfect data on current levels of use, nevertheless there do exist inexpensive methods (trailhead registers, trailhead vehicle counts, random spot counts along trails) that can produce useful data, and some attempt to obtain useful data needs to be made. Once current levels of use are known, any perceived desire on the part of the public for further travel opportunities needs to be assessed and documented. This assessment should include both motorized and nonmotorized travel, and the documentation should include the names of individuals or organizations whose requests the Forest Service is seeking to accomodate. Finally, because the Ogden Ranger District has not become significantly larger in acreage since 1988, the Forest Service needs to determine whether it is feasible to attempt to fulfill all of the public's desires, and if not, how to balance public desires against other uses and values of the Forest, in light of all applicable laws. For reasons discussed below, the use of and desire for dispersed campsites must be similarly assessed.
The third paragraph also refers to "current problems" and "negative impact to any and all resources," but very few of these current problems and negative impacts are specified in the Scoping Document, and it is not clear how the 28 specific travel plan amendments are intended to solve the problems or lessen the impacts. Similarly, it is not clear how the specific proposals might be motivated by the Management Prescriptions of the new Forest Plan. Rather than putting forward these "purposes" as applying to the entire proposal, the Forest Service needs to specify whether and how they apply to each of the 28 individual proposed travel plan amendments.
The second paragraph of the Scoping Document refers to the newly-revised WCNF Plan and its Forest-wide objective of updating district travel plans, including that of the Ogden Ranger District. We would remind the Forest Service that federal law requires periodic revision of forest plans, but that the recently completed planning process explicitly excluded route-specific travel planning decisions from its scope. Thus, the current travel planning process is, in a sense, a continuation of the mandatory, periodic Forest-wide planning process. As such, the scope of the current process must include potential consideration of all travel routes in the District and all related travel planning policies. To exclude certain alternatives as being "beyond the scope" of the current proposal, when they were already excluded from the Forest-wide planning process, would be an arbitrary restriction on the planning alternatives that NEPA requires the Forest Service to consider. Because route-specific travel planning was excluded from the scope of the Forest Plan, now is the time for the Ogden Ranger District to analyze the impacts of its network of roads and OHV trails, both individually and cumulatively, including both existing routes and proposed routes. As you are aware, motorized travel and recreation have significant impacts upon forest resources and values, as well as impacts upon human health and safety.
We agree that the published travel map is in many ways unclear and misleading. A more precisely drawn map (or set of maps) needs to be published as a replacement. However, the maps included in the Scoping Document are similarly inaccurate and ambiguous in many ways. We would suggest using the 7.5-minute quadrangle maps as base maps for specifying the alignments of all approved travel routes, in order to remove ambiguities in this proposal and in the final travel maps that will be made available to the public. All routes, current and proposed, should be plotted on these maps to within an accuracy of one or two millimeters on the 1:24,000 quadrangle maps, or 25-50 meters on the ground. This level of accuracy is easily obtained with an inexpensive, consumer-model GPS receiver.
As part of the environmental analysis of this proposal, the Forest Service must accurately describe the current condition of all travel routes within the Ogden Ranger District. This description should include, at a minimum, an inventory of all public-use roads, administrative roads, motorized trails, nonmotorized trails, and dispersed camping areas. Trails that have become overgrown and undefined should be identified as such or excluded from the inventory. The inventory should distinguish between trails in developed areas (e.g., Ogden east bench, Snow Basin) and trails in undeveloped areas where a more primitive recreational experience is possible. Trails that are suitable (due to grade and surface condition) for mountain bikers should be distinguished from trails that are generally unsuitable. There should be some attempt to estimate the total number of miles of routes that are currently receiving, or have recently received, unauthorized motorized use. All of this information is necessary to properly assess the impact of the proposal upon motorized and nonmotorized recreation opportunities, and to assess the cumulative impact upon the natural and human environment of the road and trail systems of the Ogden Ranger District.
Based on a recent conversation with Regional Forester Jack Troyer, it is our understanding that the present proposal may be motivated in part by a desire to appease OHV riders who have been slow to accept the fact that motorized travel in the Ogden Ranger District is permitted on designated routes only. According to Mr. Troyer, the strategy is to give the OHV users a trail system that is sufficiently extensive to satisfy most of their desires, and in return, expect them to honor the limitations of the travel plan, especially its lack of sacrifice areas that are completely open to off-route travel. In response, we would first point out that the designated-routes-only policy has been in place for less than a generation, and many OHV users are still totally unaware of the existence of the travel map or the policies it describes. The Forest Service has put relatively little effort into publicizing its travel policies during the last 15 years, as evidenced by the lack of adequate signing, incorrect signing, misleading signing, published maps that contradict that travel plan, and stated misconceptions of many of the OHV users with whom we have spoken. Likewise, the Forest Service has put very little effort into enforcing travel restrictions over the last 15 years. The Ogden Ranger District has stepped up its efforts at signing and enforcement in some areas during the last year, but other areas remain badly neglected, and we can hardly expect the attitudes of OHV riders to change in such a short time. Hence, it is far too soon to conclude that the OHV community will not accept the travel plan unless numerous routes are added to it. However, even if this conclusion were true, it would be inappropriate for the Forest Service to modify its policies in the face of what would amount to extortion on the part of the OHV community: we should not repeal our laws whenever criminals threaten to break them. It is especially notable that most of the routes on which motorized travel would be newly permitted under the proposed action are already receiving illegal motorized use. To make this activity legal would set a disturbing precedent, encouraging OHV users here and elsewhere to continue to travel on closed routes, in the expectation that such activity would induce land managers to eventually give in and open those routes. Finally, it seems to us that converting nonmotorized trails into motorized trails will convey to the public the message that if they want to enjoy their National Forests, they had better get an off-highway vehicle. In other words, the policies of the Forest Service do not merely accommodate recreational demands, but also play a part in creating those demands. By increasing the demand for motorized recreational opportunities, Mr. Troyer's strategy is likely to result in crowded trails that induce even more motorists to strike out across closed areas.
B. Desired future condition. This section of the Scoping Document is sufficiently vague that there is absolutely no way to tell what actions might better achieve the desired future condition. The forthcoming NEPA document should instead specify the desired future condition vividly and explicitly. For example, it should specify that ghost trails be eliminated, invasion of noxious weeds be checked and reversed, OHV trespass onto adjacent private lands be reduced, wildlife habitat be improved, and opportunities for quiet and solitude in the National Forest be maintained, despite the inevitable increases in recreational use (motorized and nonmotorized) that will occur in the next 20 years. If the Forest Service wishes to provide new looping trails for OHV's, then this should be stated explicitly, not hidden under "meeting the needs for public uses." The specific types of desired OHV opportunities should also be described. For example, does the Forest Service desire to provide sites for ATV's to ride in small circles at high speed, stirring up dust? Does the Forest Service desire to provide "challenging" ATV trails that would pose a danger to unskilled riders? Is there an approximate target for the number of miles of ATV routes and the number of looping trails in the Ogden Ranger District, or is it simply desired to provide as many routes and loops as possible?
C. Cumulative impacts. The environmental analysis of this proposal needs to include an analysis of cumulative impacts due to past actions, other current actions, and reasonably foreseeable future actions, pursuant to NEPA.
Past actions would include all prior revisions of the Ogden Ranger District travel plan since 1988. It is our understanding that none of these revisions have undergone environmental analysis: All were accomplished either via categorical exclusion or by simply amending the travel map without public notice. These past amendments added approximately 20 miles of motorized routes to the travel plan, whose cumulative environmental impacts must be added to those of the approximately 25 miles (net) of new motorized routes that are currently being proposed. Because the Forest Service has not assessed the environmental and human impacts of these unanalyzed motorized routes, the present environmental analysis must determine the impacts of these past related actions.
Present actions would include any road/trail maintenance or reconstruction planned for this season or next, including any associated gravel source use or development. It is our understanding that the Ogden Ranger District is acquiring a "trail cat" machine, which will be used to maintain and improve a number of motorized trails during this season and in the future. These improvement projects must be described, the locations must be disclosed, and the impacts of any increased use that might result from this or other maintenance must be considered.
Present actions would also include current efforts to promote motorized recreation by the Forest Service, BLM, State of Utah, Counties, and OHV advocacy groups. These promotional activities include the publishing of maps and other literature, press releases and web pages, installation of signs, and construction of trailhead facilities. It is especially notable that the Forest Service and other agencies intend to designate a large, connected system of OHV trails in this area, known as the "Shoshone Trail." According to a map dated 14 February 2003, "Phase 1" of the Shoshone Trail would include approximately 200 miles of connected routes within the Ogden and Logan Ranger Districts as well as seven new or enlarged trailhead facilities; approximately another 300 miles of "potential trails" would be added later as this becomes possible. Approximately six of the new motorized routes proposed in the current Scoping Document have also been proposed as segments of the Shoshone Trail system, while nearly all of the other new motorized routes in the Scoping Document would either connect to the Shoshone system or lie very close to it. Because of the connectedness of the Shoshone Trail system, its establishment represents a "collectively significant action" under 40 C.F.R. 1508.7. Therefore, the full environmental impact of the Shoshone Trail system needs to be analyzed before any of these new routes can be opened or constructed. This impact would include the impact of the increased use that would result from the connectedness of the Shoshone Trail system and its likely promotion by the State, OHV advocates, local communities, and others.
Foreseeable future actions would include construction of new trailheads or parking facilities near new or improved motorized trails; opening of new travel routes on adjacent private or state land; any travel plan revisions within the Logan Ranger District (due to the connectedness of trails between the districts); further efforts to promote motorized recreation including expansions of the Shoshone Trail system; and actions that would affect camping, campsites, and picnic areas, both developed and dispersed.
D. Impacts upon the natural and human environment. The environmental analysis of this proposal needs to take a "hard look" at the impacts of each of the proposed changes upon all of the following:
E. Range of alternatives. The proposed action would result in a net increase of more than 25 miles of travel routes open to OHV's within the Ogden Ranger District. As alternatives to this action, the Forest Service should consider at least three other alternatives:
1. The no-action alternative. Although this alternative would result in no changes to the current travel plan, it would still allow better signing, better enforcement of closures, and better public education efforts such as publishing a clearer travel map (or set of maps).
2. An OHV-restrictive alternative, which would close a number of routes to OHV's where problems are occurring or where other Forest values should take precedence over OHV use, without opening any new routes to OHV's. Specific suggestions for closures are described in Section II below. Besides solving a number of site-specific problems, such an action would send a clear message to OHV users that if they do not obey restictions and police themselves, they will lose access to roads and trails in the National Forest. We believe that such an alternative would be supported by much of the public, especially if more people were aware of the extent of OHV-related problems in the Ogden Ranger District. We also believe that such an alternative would more accurately reflect the Forest Service's mandate to manage the lands for multiple uses.
3. The Citizens' Alternative. This alternative is described in detail in Section III below. It would close a number of undesirable OHV routes but open several new loop routes for OHV's, resulting in little net change in the total number of miles of open routes. We consider this alternative to be a compromise between the proposed action at one extreme, and an OHV-restrictive alternative at the opposite extreme. Like all good compromises, it is not merely a middle ground but rather an attempt to address a large majority of the concerns of both sides.
F. Unanswered questions. The Scoping Document does not mention the following issues, which are intimately connected to travel planning and must therefore be considered in conjunction with any proposed travel plan amendments:
According to the latest NEPA quarterly, the anticipated decision date for this proposal is February 1, 2004. In order to make a decision by this date, an Environmental Assessment or Environmental Impact Statement would have to be prepared extremely quickly, and the public comment period on the EA/EIS and its range of alternatives would have to occur during the winter, when snow cover would make it impossible for members of the public to field-check the sites of any suggested alternatives to the present proposal. In order to provide a meaningful opportunity for public comments, the comment period on the EA/EIS must include several snow-free months to allow site visits. The earliest that such a comment period could occur would be summer 2004, and hence, the anticipated decision date should be delayed until at least fall 2004.
H. Need for an Environmental Impact Statement. The present proposal, together with other past, present, and reasonably foreseeable activities, clearly constitutes a major federal action that will have a significant effect on the environment. "Significant," for purposes of NEPA, is defined in terms of context and intensity.
The "context" of the present proposal is an ongoing increase in the level of motorized recreational use throughout the public and private lands of northern Utah, and steps taken by all land managers (Ogden Ranger District, Logan Ranger District, BLM, Utah DWR, Utah Division of Parks and Recreation, and Utah SITLA, in cooperation with Weber, Box Elder, Cache, and Rich Counties) to further promote and manage this recreation. The Shoshone Trail proposal, part of which is apparently scheduled for implementation this summer, is one example of this wide context: A 500-mile interconnected OHV trail system, affecting many public and private landowners, of which several of the new motorized routes described in the Scoping Document would be a part. The past travel plan revisions described in section B above are also part of the context, as are the many connecting travel routes that lie on nonfederal land. There has never been a comprehensive environmental analysis of the impacts of motorized recreation upon resources in this area. Other elements of context have already been listed and described above.
The "intensity" of the present proposal, together with past, present, and reasonably foreseeable future actions, can be summarized in a number of ways. In the Ogden Ranger District there are currently approximately 150 miles of roads and trails open to off-highway vehicles. Of these 150 miles, approximately 20 miles were added since the original (1988) travel plan, while the current proposal would add approximately another 25 miles (net). Thus, these revisions represent an increase in OHV routes of approximately 35% over a period of 15 years. However, the impact on recreational OHV use will be far greater, because nearly all of the new routes are specifically designed for this purpose (looping trails, etc.), whereas nearly all of the former routes were originally created for other purposes (e.g., livestock management). The impact upon nonmotorized recreation would be correspondingly large, as maintained, nonmotorized trails would be virtually eliminated in all portions of the Ogden Ranger District except the Mt. Ogden and Causey Reservoir areas. These two areas represent less than 25% of the District; in other words, motorized recreation would become the dominant use in approximately 75% of the District.
The Ogden Ranger District has never before undertaken the creation of a major, connected system of OHV routes that could potentially attract OHV riders from a much wider geographical area than at present. Indeed, some OHV advocates have publicly expressed the hope that these new OHV opportunities (such as the Shoshone Trail) will create an economic boom from increased tourism in local communities. In order to realize this hope, the amount of OHV use within the Ogden Ranger District would have to increase very dramatically over current levels--more than would be expected from the current rate of population increase and increase in OHV ownership. This increased use would have significant effects upon virtually all other forest resources.
The intensity of the impact of the present proposal upon wildlife habitat is also potentially severe. Many of the proposed new motorized routes lie within a recognized regional wildlife migration corridor. Most of this corridor provides suitable habitat for Canada lynx, a species now listed as Threatened under the Endangered Species Act. Every effort must be made to understand the impact of the proposed action upon wildlife in general and lynx in particular.
The significance of the proposed action is furthermore documented by its highly controversial nature. OHV-related issues are probably the most controversial issues dealt with by the Forest Service in northern Utah, as evidenced by the extensive press coverage of these issues in the local newspapers. The present proposal was covered in a story at the top of the front page of the Ogden Standard-Examiner on August 5. The context and intensity of this proposal, as described above, make it especially controversial among local residents and the many citizens elsewhere who are concerned about increasing levels of OHV use in America's public lands.
Because of the significance of this action, NEPA regulations require that the current proposal be analyzed in an Environmental Impact Statement, not merely in an Environmental Assessment.
1. The purpose and need for this new road need to be described, as does its current status (whether it is already receiving motorized use, and if so, for what purpose).
2. The purpose and need for this new road need to be described, as does its current status (whether it is already receiving motorized use, and if so, for what purpose).
3. We support closure of this unneeded road. The alternative of a total closure, even to administrative use, should be considered. Any need for continued administrative use needs to be described, including an explanation of why nonmotorized access would be insufficient.
4. The purpose and need for this new road need to be described, as does its current status (whether it is already receiving motorized use, and if so, for what purpose).
5. We support the closure and obliteration of these unneeded roads.
6. The proposed action needs to be clarified to specify the exact spot where this road would be closed; there is an apparent contradiction between the text of the Scoping Document and the attached map. We support the closure of this unneeded road segment which could otherwise threaten the integrity of the Mollen's Hollow Roadless Area. However, leaving the eastern half of the road open as a dead-end road would still pose a threat, especially to the riparian area around Zion Spring itself. The alternative of closing the entire road should be analyzed, as should the possibility of also closing the dead-end road located approximately 1.5 miles north of the Zion Spring road.
7. This proposed new trail would lie within an Inventoried Roadless Area, MPC 3.2u, and would convert approximately six miles of existing trails from dead-end trails into a loop. This loop would probably attract many new ATV riders to this area which currently receives very little use. The environmental analysis must take a hard look at the likely effects of this ground disturbance and increased motorized use on wildlife habitat, noxious weed invasion, user safety, and opportunities for nonmotorized recreation, not just on the new trail but elsewhere on and near the loop. The existing routes that would make up the rest of the loop were closed in the 1988 travel plan and opened via the 1991 travel map without public notice or environmental review; their full impact upon the environment must therefore be analyzed at this time. The burden of proof is on the Forest Service to explain why so many ATV trails are needed in a roadless area whose primary emphasis under the Forest Plan is not for recreation but for wildlife habitat protection. The mapped alignment of the new trail segment ascends a very steep grade; the 0.83 mile length estimate needs to be increased to reflect the need for switchbacks. The likelihood of users shortcutting switchbacks also needs to be considered. As an alternative to this proposed loop, the Forest Service should consider simply closing the Tilda Spring and Boundary Spring ATV trails to motorized use. Such an alternative would protect the Mollen's Hollow roadless area from further motorized abuse (e.g., extension of several existing ghost trails), eliminate the need for costly trail reconstruction where the routes are overly steep and unsafe, protect wildlife habitat within this important area, slow the invasion of noxious weeds which are already growing in the Tilda Spring area, lessen the likelihood of trespass problems where these trails cross onto private property, and create some much-needed opportunities for nonmotorized recreation in the Monte Cristo range. Another alternative would be to close these trails, but replace them with a new ATV loop elsewhere in the Curtis Creek area, outside of inventoried roadless areas. It appears that with a small amount of new trail construction, two or more new ATV loops could easily be created in the vicinity of Spencer Basin and Six Bit Spring. In general, the Forest Service should be trying to divert motorized recreation out of roadless areas and into areas that are already roaded. Because so much of the Curtis Creek area is already roaded, such an approach should impose no hardship upon motorized recreationists.
8. This route currently exists on the ground, but its northern half can hardly be called a "road." It lies in an area whose management emphasis under the Forest Plan is for wildlife habitat protection (3.2u). Due to the scenic view from the end of the route, the Forest Service needs to estimate the number of OHV riders who might be attracted to this spot on busy weekends, and describe how space to park this many OHV's will be created at the overlook. It is doubtful whether a fence would be effective at keeping OHV's on the designated route; the environmental analysis needs to describe this fence in detail, with an explanation of how users will be kept from going around it. The proposal should state whether the fence would be built before or after the route would be opened to motorized use, with the environmental effects of each sequence analyzed. The effect of diverting resources to this remote fence construction, away from other needed projects, should be evaluated. Turning this nonmotorized trail into a motorized route would take away an outstanding opportunity for quiet and solitude in this area, and indeed, would eliminate a unique nonmotorized recreation opportunity (hiking or bicycling a well-defined trail on a high plateau, away from motor vehicles) from the Ogden Ranger District. (On the other hand, motorized routes along high plateaus are ubiquitous in the Monte Cristo Range.) As an alternative, we suggest reclassifying this route as a nonmotorized trail and investigating the possibility of opening one or more new routes in the Spencer Basin area, as described in number 7 above.
9. Of the three trails mentioned, the southernmost does indeed exist on the ground and has seen recent use; the northernmost exists on the ground but is becoming overgrown and easy to overlook; and the middle trail has become completely overgrown and nearly impossible to find. It is unclear why the Forest Service is proposing to open these dead-end trails to motorized use, given the likelihood that users would continue past the dead ends as has happened so often elsewhere. The purpose and need for these trails need to be described, and their environmental effects on wildlife habitat, roadless character, and other forest resources need to be evaluated. Again, this is a roadless area whose management emphasis is for wildlife habitat protection (3.2u), not recreation. We suggest dropping this item from the proposed action.
10. The effects of this new ground disturbance need to be critically evaluated. The likelihood of users accessing closed routes (Monte Cristo Peak, Middle Ridge) from this trail also needs to be evaluated. The exact alignment of the route needs to be specified: would it lie above or below the steep cut-bank that parallels much of the highway? If new ATV loops are created in this area, parking space for large vehicles with trailers will have to be provided somewhere adjacent to these trails; the locations of proposed parking areas must be specified, and their impacts analyzed. Because this trail would close a loop for ATV's that includes the Dairy Ridge, Baldy Ridge, and Wasatch Ridge roads, the Forest Service must carefully analyze the likely impacts of increased OHV use on those roads. Some measures should be taken to prevent the creation of ghost trails branching off of those roads, especially into the adjacent Sugar Pine and Upper South Fork roadless areas.
11. Not all of this trail exists on the ground as claimed in the scoping document. According to the map provided, the southwestern end of the route would coincide with the Neponset Spring road, FS road 188. This road is currently open for approximately 1/4 mile, then continues as an unauthorized ATV trail for approximately another half mile before it ends. The Dairy Ridge quadrangle map shows another route branching north from the Wasatch Ridge road, approximately 0.15 miles east of the Neponset Spring road, connecting to the Silvia Hollow trail as is apparently intended; however, we were unable to locate the southern end of this route on the ground during a recent visit. The precise alignment of this trail needs to be specified, including an accurate estimate of the length of trail that would need to be newly constructed or reconstructed. In any case, we could probably support the concept of this new proposed ATV trail, provided that it lies mostly along the power line corridor as proposed, and provided that it is opened in a context of shifting motorized use into this area from other areas that would be closed.
12. For purposes of NEPA, this proposed road is a "connected action" to the proposed gravel pit development. The environmental impacts of the road and the gravel pit should be analyzed together, not separately. The purpose and need for public access to the road and gravel pit must be described. An obvious alternative would be to make this an administrative road, closed to public motorized use.
13. The more northern of these two roads is connected to the trail proposed in number 11 above, and should be treated in the same way. If this route is opened, it should be restricted to ATV's, rather than being opened to larger vehicles--otherwise it will be difficult to keep larger vehicles off of the connecting ATV trails. The southern road is already signed as the Bluff Spring road and posted as open to all motorized travel, in violation of the current travel plan. It forks into two roads. While there are some dispersed campsites along these roads, there are also some fragile meadow areas, and neither fork terminates at a decent campsite. The best alternative would be to simply take down the signs and manage this area as closed. If any portions of these routes are opened, they should terminate at the desired campsites, and a plan must be put in place to protect the meadows.
14. This route is also currently signed as open, in violation of the current travel plan. Because this is an unauthorized travel route, we believe that it and the land to the northwest should have been included in the Upper South Fork roadless area. At least one ghost trail already branches eastward from this route, into the roadless area. In order to preserve the integrity of the roadless area, this route should not be opened to motorized use. If an ATV loop is desired in this area, then we would suggest as an alternative the existing trail along the power line, combined with an existing trail along the south side of the highway. A short segment of additional trail along the highway would need to be constructed to complete the loop, but the negative effects of this ground disturbance should be offset by the relative ease of signing, enforcement, and weed control in the proximity of the highway. Another alternative would be to convert the Mitchell Hollow ATV trail into a loop, either by connecting one of the branching ghost trails back to Dry Bread Pond, or by connecting two of the branching ghost trails to each other.
15. This closure sounds like a good idea, though we are not familiar with the route. There is no point in encouraging OHV use along such a short, isolated road segment, especially in camping area that is often crowded.
16. When this trail was first proposed, the NEPA documents indicated that it would be a nonmotorized trail, and a categorical exclusion was issued with that understanding. Hence, according to NEPA regulations, the analysis of the current proposal must also include the cumulative effect of the past trail construction upon the environment. Even more importantly, the present environmental analysis must take a hard look at the likely increase in motorized use of the Ben Lomond and Lewis Peak segments of the Skyline Trail that would be facilitated by motorcycle access to this trail. Obviously, such an analysis needs to be preceded by a quantitative assessment of current levels of use, both motorized and nonmotorized. We suggest placing trailhead registers at North Ogden Pass to assess current use, supplemented by occasional vehicle counts at the parking area and counts along the trails. Based on our experience, both segments of the Skyline Trail currently attract very large numbers of hikers and bicyclists; motorcyclists are only a small fraction of the users. (For example, during two recent hikes from North Ogden Pass, one of us counted 26 other hikers, 15 mountain bikers, three equestrians, and no motorcyclists on the trail.) Increased use of these trails by motorcycles would cause crowding, safety problems, noise, and pollution, leading to a significant loss of high-quality nonmotorized recreation opportunities within the Ogden Ranger District. Furthermore, past experience has shown that motorcycle trails in the Ogden Ranger District are frequently used by ATV's and tend to be converted into ATV trails over time (e.g., in Willard Basin). We therefore strongly oppose this proposal. As an alternative, we suggest closing the entire Skyline Trail to motorized use, or limiting motorized use of the Skyline Trail to alternate days.
17. These dead-end trails serve no purpose, and no reason has been offered for opening them to motorized use. (The fact that they adjoin other motorized trails is not a reason--just think of the implications if this criterion were used elsewhere.) We are unaware of any significant desire on the part of motorcyclists to have access to these trails; even the Lewis Peak trail itself receives relatively little use by motorcycles at present. These two trails should be kept closed, in order to preserve opportunities for nonmotorized recreation in the Lewis Peak roadless area. The alternative of closing the Lewis Peak trail to motorcycles should be analyzed, as should the alternative of closing the Lewis Peak trail to motorcycles on alternate days.
18. This dead-end trail serves no purpose, so we support the proposal to close it. However, another alternative would be to convert the upper portion of the trail into a loop, by constructing a new connecting trail back to the nearby road. Such a loop would provide an alternative to the loops proposed in item 20.
19. This route is currently closed to all motorized uses, not open to motorcycles as claimed in the Scoping Document. It lies in an area classified as MPC 2.7 in the Forest Plan, implying that new trail construction is strongly discouraged. From the map in the Scoping Document, it appears that the proposed trail would follow the ridgeline. At present, only the northern half of the trail along the ridgeline is a double-track. The double-track then drops below the ridge on the western side, eventually reaching a dead end as shown on the Mantua quadrangle map. A foot trail does continue south along the ridge to join the Skyline Trail, but this foot trail has a steep, rocky segment that would not be safe for ATV's or even for motorcycles. Any new motorized uses or new trail construction along this ridge would cause severe damage to fragile alpine vegetation, and facilitate illegal ATV use of the Skyline Trail to Ben Lomond, which is already occurring as evidenced by the fact that that trail is turning into a double-track. Letting ATV's up onto the ridge would also be likely to increase the amount of foot traffic to the Willard Peak summit area, causing further damage to alpine vegetation. The Forest Service should determine whether Willard Peak and the surrounding area provide suitable habitat for Burke's draba or other rare alpine plants, and assess the full impact of this proposal on alpine plant communities. The impact of motorized use upon existing hiking opportunities must also be analyzed. During a recent visit, we observed far more hikers (15, including our own party of five) than motorists (five, including three on ATV's who violated the current trail closure) using the trails in the Willard Basin area. Several of these hikers were small children. Clearly, there is a strong burden of proof upon the Forest Service to justify a new ATV trail in this unique, fragile area. We strongly oppose this proposal because the impacts just described are likely to be severe.
20. The routes shown on the map in the Scoping Document do not coincide with what currently exists on the ground; the Forest Service needs to clarify exactly what routes are part of this proposal. Also, a portion of this system of trails is already open to motorcycles, contrary to what the Scoping Document states. Most of this area is classified as MPC 2.7, implying that trails should be intended for the appreciation of the special resource (in this case tall forb plant communities), not for high-speed vehicular play. ATV access to this area would perpetuate the denuded condition of the ground around the pond and much of the surrounding area, and encourage ATV riders to continue southward along the Skyline Trail toward Ben Lomond. The impact upon nonmotorized recreation opportunities would be severe, as described in number 19 above. We strongly oppose this proposal. The Forest Service should instead mark the route that is open to motorcycles, erect barriers and signs to keep motorcycles and bicycles on this route, and give the rest of the area a chance to recover. Alternatively, the Forest Service should consider closing the motorcycle trail and permitting only nonmotorized travel on these trails. Another alternative would be to permit motorcycle access only on alternate days.
21. Because the first mile of road 220 was opened in 1991 via a categorical exclusion, while the next two miles were apparently added to the travel map without any public notice at all, the environmental analysis of this proposal must at this time examine the impacts of the entire road, not just the extension that is currently proposed. This road has proved very difficult to maintain and provides access to several miles of additional ghost trails within a roadless area, for example, the mile-long ghost trail that goes to the summit of peak 7328. The open terrain would make it virtually impossible to keep vehicles on the designated route. Trespassing on private property would be another inevitable result of extending this route. Based on our experience, it appears that most OHV users who use the Public Grove area are not looking for a through-route to Mantua; they are instead looking for short loop rides and challenging terrain near the Liberty-Avon road. As an alternative to this proposal, the Forest Service should consider simply closing all of road 220 into Public Grove Hollow. The opening of this route in 1991 was simply an experiment that failed, as evidenced by the rutted, widened, and eroded condition of much of the route, despite heroic efforts on the part of the Forest Service including fence building, revegetation, user education, and attempted seasonal closures. The Forest Service should also analyze the alternative of redesignating road 220 as an ATV trail, closing it to larger vehicles. This alternative would lessen the rate at which the condition of the route is deteriorating, but still facilitate ATV access to many illegal ghost trails and private property. A third alternative, which we support, would be to close road 220 to all motorized use but investigate the possibility of opening or constructing a short ATV loop somewhere else near the Liberty-Avon road. One possible alignment for such a loop would be along road 114 for 1/4 mile, then northeastward for 1/2 mile, then northward or northwestward to reconnect to the Liberty-Avon road. Other alignments may also be possible and should be thoroughly investigated. If a suitable alignment for such an loop can be found, it could solve some of the problems in this area while fulfulling the intent of the 1991 decision to open the existing two-mile loop road. On the other hand, if the Liberty-Avon road itself is to be closed to OHV's as indicated on the current travel map, then there is no sense in maintaining any OHV routes in this area. The status of OHV use on the Liberty-Avon road must be clarified. If road 220 remains open to OHV's but the Liberty-Avon road is closed, it would be necessary to provide parking space for several large vehicles and trailers at the start of road 220; the impact of such a parking area would have to be analyzed at this time.
22. Only the first 1/3 mile of road 115 is currently open, so the proposed closure would affect only about 1.3 miles of routes, not 1.6 miles as stated. We support these closures but we wish to point out that obliterating the routes will also eliminate opportunities for nonmotorized recreation, especially mountain biking. The alternative of maintaining a nonmotorized trail along road 115, connecting via an existing trail to road 220, should also be considered and analyzed. As mentioned in the previous paragraph, we could in principle support the creation of a short ATV loop off the Liberty-Avon road, if an environmentally suitable alignment can be found and if other ATV routes are closed.
23. In addition to the looping road shown on the map in the Scoping Document, there is a dead-end trail branching westward (onto state land) to what appears to be another spring development. It is unclear whether this branching trail would also be open, and if so, for what uses. Portions of these roads would need to be reconstructed or realigned to prevent erosion and water pollution, given the proximity of the creek. If the road to the southeastern spring development is opened to public motorized use, it will be necessary to find a way to keep vehicles off the adjacent meadow, especially during wet conditions. Dyer's woad is already a very serious problem in this area, and there are numerous ghost trails branching off the main road. Any decision to open routes in this area to motorized use by the public must specify whether the problems just mentioned would be remedied before or after the routes are opened; both sequencing alternatives should be considered and analyzed. We believe that all roads and trails in this area should be closed to motorized access by the public, in order to facilitate the closure of nearby ghost trails, protect the watershed, slow the invasion of noxious weeds, and provide opportunities for nonmotized recreation.
24. In principle we could support such a trail if it can be prevented from expanding into a network of ghost trails, and if it is created in a context of shifting ATV use out of other areas. However, the northern portion of the proposed route passes through a large dispersed camping area and meadow where undesirable off-route travel would need to be prevented somehow. From the topo map it appears that a portion of the route would be quite steep, probably necessitating switchbacks which would increase the stated mileage. Shortcutting switchbacks could become a problem. We would need to walk the entire proposed alignment of this route before commenting on any further site-specific concerns. The speculation that construction of this route would reduce conflicts along the main road needs to be substantiated--it seems equally likely that this route would simply attract additional ATV riders and perhaps even lead to an increase of ATV traffic on the road which would still be used to close the loop. Besides the alternative of not providing such a loop at all, the Forest Service should analyze the alternative of putting the loop trail on the west side of the road, possibly along an existing trail that parallels the road on that side for about a mile.
25. While the northern portion of this proposed trail does currently exist on the ground, the southern portion is too narrow and too steep for safe ATV use, and follows a creek bed for much of its length; it would have to be reconstructed along a more suitable alignment. The realigned route would probably have to be longer than stated. We oppose this proposal because it would violate the integrity of an inventoried roadless area (MPC 3.1w), facilitate access to a much larger network of ghost trails, accelerate the invasion of noxious weeds in the area, endanger the health of the watershed, and eliminate opportunities for nonmotorized recreation. If a looping ATV trail is desired to the west of the WIllard Basin road, the Forest Service should consider the alternative of using the existing trail mentioned in number 24 above.
26. The analysis of this proposal must include consideration of the entire route between Dock Flat and Brigham City, including the portions of the route that would be on non-federal land. The mapped alignment of this route is incomplete, unclear, and in some areas, impractical; a better map must be provided before an adequate analysis can occur. While a route along the approximate proposed alignment does exist on the ground, it was never designed as a motorized trail and contains lengthy segments that are far too steep for safe motorized use. To reconstruct the entire trail to appropriate standards would entail a great deal of ground disturbance and would lengthen the route considerably beyond the stated mileage. Such a properly graded trail would greatly facilitate access to numerous connecting ghost trails, resulting in deterioration of the watershed in an area classified as MPC 3.1w in the Forest Plan. Also, as is apparently hoped by Brigham City officials, this trail could attract very large numbers of ATV riders who would use this trail as an entry point into the Shoshone Trail system. The cumulative effects of this increased use on the entire Ogden and Logan Ranger Districts, and on the Brigham Face Wildlife Management Area, must be considered. If a connection between Brigham City and the Willard Basin Road is desired, a less destructive alternative would be to avoid Balsam Basin entirely, instead constructing a new trail descending eastward from the saddle at the top of Dunn's Canyon down to a point somewhat south of the Box Elder Campground. From there, an ATV trail could be constructed alongside the Willard Basin road southward to Dock Flat. A number of variations on this alignment might also be possible. Such an alternative would offer the advantages of less new trail construction on steep, remote terrain, fewer connecting ghost trails that threaten the watershed, a longer riding season with reasonably dry conditions, less fragmentation of wildlife habitat, and the chance to preserve some opportunities for nonmotorized recreation in the Box Elder Creek and Balsam Basin areas.
27. The precise location of the proposed closure is unclear; the portion of this route that lies "below the ridgeline" is shorter than the stated 0.57 miles. In order to prevent unauthorized travel beyond the dead end, and provide opportunities for nonmotorized recreation, the entire Grizzly Peak road should be closed to motorized use and designated as a nonmotorized trail for hikers, mountain bikers, and equestrians. Such a trail would provide a much-needed opportunity for a relatively easy "family" hike along a ridgeline in the Wasatch front range. It is our understanding that the Box Elder Access Management Team has also recommended this entire route for closure, because it is a dead end. The classification of this area as MPC 2.6 and 2.7 would seem to indicate that motorized travel is not a priority here.
28. Due to the poor quality of the current travel map, it is unclear whether the route along the west side of Perry Reservoir was ever open in the first place. But we support closing and obliterating it. A better alternative would be to close the entire road leading to Perry Reservoir from the Willard Basin Road. A total closure would be the most straightforward solution to the considerable OHV problems that have occurred around the reservoir.
B. Other routes shown on maps in the Scoping Document
The maps that accompany the Scoping Document show a number of "system road" and "ATV trail" segments that are closed according to the current travel map. Any proposal to open these road segments would need to be explicitly stated and analyzed as part of the current process. The segments are as follows:
We are calling this alternative the "Citizens' Alternative" because it has been developed by private citizens, acting as volunteers. Despite the brevity of the Scoping period, we have made considerable efforts to solicit input into this alternative from all interested citizens. These efforts have included numerous private conversations and one public meeting, announced in the Standard-Examiner, held on August 19. In general, we have found very broad support for this alternative among both OHV users and people who call themselves environmentalists. Those OHV users who also call themselves environmentalists have been especially supportive. We expect several other individuals and organizations to endorse this proposal, once they have had sufficient time to review its details. However, we have also received a number of negative comments from extremists on both sides: environmentalists who feel that no new ATV trails should be constructed anywhere in the National Forest, and OHV users who are unwilling to give up any potential places to ride. Unfortunately, there is no proposal that will be acceptable to all citizens.
The general goals of the Citizens' Alternative are as follows:
A. Implement the following items as described in the Scoping Document: 1, 2, 3, 4, 5, 10, 11, 12, 15, 18, 22, 24.
B. Eliminate the following items from the proposal: 19, 25.
C. As an alternative to item 6, close the entire Zion Spring road to public use, and close the other dead-end road that lies 1.5 miles north of it.
D. As an alternative to items 7 through 9, close the Tilda Spring and Boundary Spring ATV trails to motorized use, and replace them with two or more looping ATV trails, mostly along existing routes, in the vicinity of Spencer Basin and Six Bit Spring.
E. As an alternative to item 13, open only the more northern of the two roads to motorized use, and limit this use to ATV's and motorcycles.
F. As an alternative to item 14, keep this particular route closed to motorized use but establish one or more looping ATV trails in this area that incorporate the existing routes along the power line, along the highway, in the Dry Bread Pond area, and along the Mitchell Hollow ATV trail.
G. As an alternative to items 16, 17, and 20, continue to prohibit ATV use in the Willard Basin area (except on the road), permit motorcycle use only on the Skyline Trail and the Lewis Peak spur (as at present), and limit this motorcycle use to alternate days.
H. As an alternative to item 21, close all of road 220 to motorized use, but identify a suitable alignment for a looping ATV trail connecting to the Liberty-Avon road, preferably on the east side of the road.
I. As an alternative to items 23 and 26, permit only administrative use of the roads to the spring developments, and route the ATV trail between Brigham City and Dock Flat along a more northerly alignment that avoids Balsam Basin.
J. As an alternative to items 27 and 28, close the entire Grizzly Peak and Perry Reservoir roads to all motorized use.
K. Follow the recommendations in section II.B above for the various minor routes that are shown as open on the Scoping maps but are closed according to the current travel map.
L. Implement the further travel plan changes suggested in section II.C above.
Like the proposed action, this alternative would result in the addition of approximately ten looping ATV trails to the Ogden Ranger District. It would also preserve other motorized recreation opportunities along approximately 130 miles of existing routes that serve a reasonably well-defined purpose. However, unlike the proposed action which would increase the number of dead-end OHV routes, this alternative would significantly decrease the number of dead-ends. The Citizens' Alternative would open approximately 20 miles of new routes to OHV use, while closing approximately 20 miles of routes that are currently open, resulting in essentially no net change in total mileage relative to the current travel plan (but a gain of 20 miles relative to the 1988 travel plan). However, whereas the routes to be closed are mostly dead-end trails with little recreational value, the routes to be opened would create many new loop opportunities as desired by OHV riders.
We also recommend the following changes in travel management and related activity:
M. Implement seasonal closures of all motorized routes along unimproved surfaces, the dates of closures to vary from one area to another, depending on elevation. Prohibit all travel during wet conditions that would produce ruts more than two inches deep, at all times of year.
N. Prohibit over-snow travel by all vehicles, including OHV's on designated routes, when the snow depth is less than one foot.
O. Incorporate a list of designated dispersed camping sites and other off-road parking areas into the travel plan, and prohibit all off-road camping, parking, and vehicle use except in these designated sites. Prohibit vehicle travel within the sites except to enter and exit. (Once we see a proposed list of designated sites, we would like the opportunity to suggest alternatives prior to the environmental analysis of the proposal.)
P. Convert the Dock Flat and Dry Bread Pond dispersed camping areas into developed campgrounds, revegetating damaged areas that are not incorporated into designated campsites.
Q. Develop a policy by which OHV abuse in an area would automatically trigger a temporary emergency closure of the area. Install gates where necessary to facilitate such closures.
R. Increase the amount of signing, user education, and law enforcement pertaining to dispersed motorized recreation. Signs must be unambiguous. Educational efforts must emphasize that unauthorized use will result in emergency closures of motorized routes. Law enforcement must focus more on citing users for travel off of designated routes, not just on making sure that vehicles are registered.
Dan Schroeder, Chair
Sierra Club, Ogden Group
1444 Binford Street
Ogden, UT 84401
Assistant Regional Director
Four Corners Office of The Wilderness Society
7475 Dakin Street, Suite 410
Denver, CO 80221
Gale Dick, President
Citizens' Committee to Save Our Canyons
P.O. Box 112017
Salt Lake City, UT 84147
Photo essay on Ogden Ranger District travel plan update
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Last modified on 26 January 2004.