IMBA White River NF Comments

For Immediate Release
April 2000
Contact:
303-545-9011

Martha Ketelle, Forest Supervisor
Lyle Laverty, Regional Forester
Carolyn Upton, Planning Team Leader

Dear Forest Service officials:

The International Mountain Bicycling Association (IMBA) submits the following comments regarding the Draft Plan Revision and Draft EIS for the White River National Forest. Generally, we agree with many of the goals set forth - the draft plan represents real progress in improving recreation management on our national forests. However, we are very concerned about the proposed trail closures in the preferred alternative and the overall management approach for mountain bicycling.

These comments do not address particular trails or particular land areas, which have been discussed in detail by local cycling advocates and IMBA affiliates. IMBA endorses the comments of the Summit Fat Tire Society.

To summarize our comments:

• Although IMBA endorses the main concept of Alternative D - the idea that a higher priority be given to physical and biological resources than to human uses of the Forest. - we cannot endorse D, or any other alternative, because of the proposed extensive closures of non-Wilderness trails to bicycling and the approach to bicycling that would limit bicycle riding to only trails that are posted open. The rule that would limit motorized use to designated routes only is inappropriate for bicycles. The appropriate rule for bikes is that they may travel on all non-Wilderness system trails, unless closed for specific, justifiable reasons.

• IMBA supports the rule that would prohibit bicycle travel off of system trails.

• In the travel management plan, the lack of rationale for trail closures and lack of maps showing travel systems for each alternative has created a serious flaw that cannot be corrected in the FEIS. There must be a second process to deal with travel management on the WRNF.

• No trails should be closed to bicycling, while left open to hiking and equestrian use, on the grounds of ecological concerns. There is no science to justify such action, so it would be arbitrary and capricious.

• Closure of trails to one non-motorized user group but not others on the grounds of user conflict are rarely justifiable. Instead, the Forest Service should employ well-known techniques for resolving user conflict without closure.

• We support road mileage reduction and closure of roads that are redundant or damaging. Road-to-trail conversions are a good alternative to full obliteration. We support elimination of some redundant or damaging singletrack trails, but caution that redundancy is difficult to determine.

• We disapprove of users creating trails without agency approval. For those user-created trails that now exist, some should become system trails, and others should be obliterated. Often, user groups such as IMBA can mitigate problems on trails through volunteer labor. Problematic trails should in most cases be obliterated, not closed to one user group and left open to another.

• ATVs should be banned from singletrack because their wheelbase is wider than singletrack trail treads. The Plan and EIS need to differentiate ATVs from motorcycles, which can appropriately use some singletracks.

• The FEIS should more thoroughly investigate the subject of recreation impacts on ecosystems and wildlife, and it should compare recreation impacts to the ecological impacts of other forest uses.

• IMBA supports the preservation of the roadless character of all roadless lands. The Plan should provide more diverse management area prescriptions for roadless areas. In particular, there should be a prescription that would prohibit (as a standard) road development while allowing bicycling.

• The social/economic analysis does not adequately account for the harm to local economies that would result from the closure to bicycling of hundreds of miles of trails.

• The watershed impacts of roads and trails is a serious problem and the Plan does not propose sufficient remediation of this problem. IMBA and its affiliates can assist with the remediation of problematic trails. All forest users should be held to high standards to protect watershed health.

• The plan inadequately deals with the impacts of vegetation management on trail-based recreation experiences. There should be standards that will protect trails during timber sales and other vegetation management.

IMBA'S POSITION ON THE MANAGEMENT ALTERNATIVES

IMBA cannot endorse any of the proposed alternatives. Generally, we find ourselves more closely aligned with Alternatives D and I, but cannot support either without substantive change. We do not support the themes and objectives of Alternatives E and F.

Alternative D

We support the principle that wildlife habitat and biological diversity "be given special emphasis" and "the idea that a higher priority be given to physical and biological resources than to human uses of the Forest." IMBA is confident that bicycling can flourish in a forest managed with such emphasis, although we believe that disagreements are likely in the future regarding the application of the principle to recreation management.

Our main problem with Alternative D is its proposal for extensive closures of non-Wilderness trails to bicycling. Bikes would not be allowed on at least 586 miles of trails outside Wilderness, according to Table 3-73 in the DEIS. This is the second highest closure total of any alternative, and no justification is provided in the DEIS or Draft Plan. Without justification, such a proposal is arbitrary and capricious.

There are a number of other aspects of D that we support: It would increase the use of prescribed fire. It would give emphasis to improving watershed conditions; close redundant or damaging roads; reduce the number of road stream-crossings, and rehabilitate a high number of dispersed camping sites.

Alternative I

Alternative I might have been IMBA's preferred alternative, but its emphasis on making roadless areas into Wilderness precludes our endorsement. IMBA supports additional Wilderness designation where appropriate, but Alternative I proposes to close some trails that are important to bicyclists.

Table 3-73 (DEIS 3-255) indicates that Alternative I would close 681 miles of non-Wilderness trails to bicycling, more than D. But I proposes to close to bicycling fewer trails outside of proposed Wilderness than does D.

The DEIS language explaining Alternative I states that "mountain bike use and other mechanized travel is very limited in primitive areas." (DEIS 2-16) This anti-bicycle attitude seems foreign to the alternative, because the Alternative is based on a "Citizen's Management Alternative" submitted by Aspen Wilderness Workshop and endorsed by various conservation groups. The CMA specifically disclaims any attempt to diminish opportunities or separate mechanized recreation from hiking and equestrian recreation. We quote from the CMA (pg. 52, in the Recreation section):

"Though tempting to separate mechanized recreation from non-mechanized recreation, this alternative won't and instead promotes an ethic of courteous sharing. Promoting separation would set a precedent with far reaching implications. Virtually no users are 100% compatible thus once the designation of resources for particular uses begins, it could snowball to a point where all users would no longer feel compelled to 'get along' and begin clamoring for their own separate trail networks. ... This would lead to heavy pressure for the Forest Service to develop extensive single purpose trail networks leaving very little of the Forest undeveloped and wild...."

We encourage the Forest Service to rewrite the summary of Alternative I to remove its anti-bicycling tone.

TRAVEL MANAGEMENT

Problems with the travel management process

IMBA, and the public generally, had difficulty understanding the Draft Travel Management Plan because the Forest Service did not provide sufficient information for us to make informed comments. The problem comes in two areas: lack of rationale for individual trail and road decisions, and lack of maps.

Lack of Rationale

No rationale has been provided for any proposed trail decisions. Without a rationale, we cannot effectively respond. We cannot agree or disagree with the agency if we don't know the basis for trail decisions. When we discussed this issue with Planner Carolyn Upton on March 16, she did not know whether such rationale was ever expressed in writing. At the date of these comments, we still had no information about the availability of written rationale for proposed trail closures.

Lack of Maps

The DEIS does not graphically indicate which trails will be closed and open in each alternative. Many of the trail names in Appendix O are confusing or not common, so we sometimes don't even know the trail location.

In our March 16 conversation with Ms. Upton, she informed us of sets of maps that we could purchase and cited the high cost of planning as the reason the maps were not generally distributed. However, calls to the forest informed us that the total cost of purchasing the travel map for each alternative for each district would be $225, which is prohibitive for most non-profit organizations and individuals.

For comparison, we see a much more effective communication process underway in the Uncompahgre National Forest, where the 1998 Draft EIS and Plan for travel management discusses each and every trail and road system and provides clear maps of the systems that would exist under each alternative.

The public cannot effectively comment on travel management without clear rationale for each route decision, and without maps that indicate patterns of decisions by alternatives. Because this information has been lacking during the public comment process on the Draft, the process seems to be fundamentally flawed and potentially legally vulnerable. This flaw cannot be corrected simply by providing the information in the FEIS, because the public does not have adequate information for comment on the Draft.

We join with many other citizens and groups to request a second process to deal with travel management on the WRNF. If this means that the Forest Plan and Travel Management Plan are issued at different times, so be it. The high volume of information presented in the two plans can overwhelm even people with insight and experience in forest planning. The two processes ought to be performed separately.

The Designated Trails Rule

IMBA endorses the principle that bicycles should not travel cross-country, off of roads and trails.

However, IMBA does not support the Forest's proposal to restrict bicycles to designated routes. Bicycles should be treated like hikers and equestrians because we are non-motorized and have relatively low impact. Our non-motorized character is much more significant than our vehicular character. Lack of motors makes the impact of bicycles inherently much lower than OHVs, and similar to the impacts of other non-motorized recreationists.

Like hikers and equestrians, bicycling should be allowed on all non-Wilderness, system roads and trails, unless closed for specific, justifiable reasons. We support the travel management process in which land managers, with input from the public, decide which uses are appropriate for individual routes. That process should begin with the assumption that bicycles are allowed on non-Wilderness system trails and roads.

In areas of high use or sensitive habitat, all recreationists should be limited to travel on designated routes only. We find it irresponsible that the WRNF has not even considered restricting hikers and equestrians to designated routes on any areas of the Forest. All recreational use has an impact.

Bicyclists, as well as hikers and equestrians, should be prohibited from system roads and trails under special circumstances where segregation is clearly warranted.

Road and Trail Reductions

Generally, bicyclists prefer trails to roads. We believe that some of the decline of trails on the national forests has been a result of road construction. We understand that roads can cause significant ecological harm and they are expensive to maintain. There are many miles of unnecessary roads on the WRNF. Therefore, we support efforts to close, obliterate and recontour unnecessary or damaging roads. We are disappointed that the preferred Alternative D would eliminate only 22 miles of roads per year. We support the 43 miles per year of road elimination proposed in Alternative I.

In many cases, roads can be converted to trails rather than simply eliminated, thus maintaining public access and making make road reduction more politically palatable. Although it would not satisfy the desires of full-size 4WD enthusiasts, road-to-trail conversion can reduce the impact of roads while providing routes for hikers, equestrians, bicyclists, ATV drivers, and/or motorcyclists. The DEIS and Draft Plan make no mention of road-to-trails conversion. This should be an integral element of WRNF transportation planning.

Although singletrack trails are a precious resource that ought to be conserved, IMBA supports the principle that some trails should be removed because they are redundant or poorly designed. We caution that redundancy is not a simple, obvious characteristic. What may be redundant for transportation, may be an important additional opportunity for recreation, wherein enjoyment of the travel is more important than efficiency.

IMBA does not approve of users creating trails without agency approval. Recreationists will be less likely to construct illicit trails if there is an official trail system that is well planned and meets most users' desires. Recreation advocacy groups such as IMBA and Summit Fat Tire Society need such a system if we are to influence our constituents to not create trails outside the agency process. Also necessary is an attitude by the agency that the trails system can change, that new routes can be built if adequately justified. The travel management plan makes no mention of such flexibility.

Some of the user-created trails on the Forest should be incorporated into the official trail system, and others should be eliminated. When the WRNF is considering elimination of user-created trails because of poor design that has resulted in erosion, the agency should also consider the possibilities for rectifying the problems. Trail users - especially bicyclists - will often offer volunteer trailwork to relocate or reconstruct problematic trail sections.

Trails that are slated for elimination should not simply be closed to one user group and left open to another. If trails are causing ecological damage, they should be closed to all uses and obliterated. Often, the damage is caused by the mere existence of the route. There is insufficient science to justify discrimination among user groups for the purpose of ecological protection (see section titled "A Discrimination Issue: Ecology").

ATVs

IMBA is concerned about the widening of singletrack trails by the travel of all-terrain-vehicles. ATVs are too wide for singletrack trails. Their wheelbase is typically 50 inches, whereas the tread width of most Forest Service singletrack is 12 to 36 inches. Bicyclists highly value this narrow character of singletrack and strongly object when ATVs cause such routes to widen into what is essentially a road. This problem applies to any singletrack trail, not just those within roadless areas.

The EIS and Plan need to better differentiate ATVs from motorcycles. Because motorcycles have only two wheels, their impact on trails is fundamentally different from the impact of ATVs. Bicyclists may be able to share trails with motorcycles, but we cannot accept the destruction of singletrack by ATVs. The Forest Supervisor should rule that ATVs may not travel on singletrack trails.

UNDERSTANDING THE IMPACTS AND CHARACTER OF BICYCLING

Recent joint principles document

During the winter of '99-'00, IMBA participated in a collaborative process with various conservation and non-motorized recreation groups to adopt jointly held positions with regard to management of the White River National Forest (WRNF). With this reference, we incorporate those principles into our comments. A copy is attached.

We support the goal stated in Alternative D of placing a high priority on restoring the health of ecosystems. Bicyclists care about protecting wildlife and ecosystems, and we know that Nature must come first. We want to recreate in healthy forests.

IMBA also supports the joint principles because they recognize two important management approaches: 1) Non-motorized recreationists generally should share non-Wilderness trails, rather than having separate trails for each type of use. 2) The science of ecology today does not demonstrate a need to exclude cyclists from trails while allowing hikers and equestrians. We're pleased that the conservation groups have recognized these principles, which are vital to good management of mountain biking and directly relate to White River travel management decisions

We encourage the WRNF to more thoroughly consider the art of sharing trails and the lack of science to make rational discrimination among trail users.

A discrimination issue

The plan is commendable in its effort to deal with mountain bikes separately from motorized travel, but problematic in the way it attempts to deal with mountain bikes separately from hiking and equestrian travel. All alternatives in the DEIS propose to prohibit bicycles from some non-Wilderness trails, while allowing horses and hikers. The whole notion that bicycling must be managed separately from hiking and horseback riding is questionable. We see no justification for this approach.

Examples of this problematic approach include:

• Alternative D proposes to close 586 miles of trails outside of Wilderness to bicycling, but not to foot and horse travel.

• All alternatives would prohibit cross-country travel by bicycles - a decision IMBA supports - but no alternatives give consideration to any restrictions on foot and horse travel.

• The DEIS, 3-260, in the section "Effects on travel management from wildlife mgmt," states: "Generally, motorized and mechanized access is reduced as wildlife habitat is emphasized." Why are cyclists restricted for wildlife habitat emphasis, and hikers and equestrians not restricted?

• Horses are permitted on ALL routes (DEIS 3-254), yet horses often cause more damage to trails than bicycles, and have more possibilities for introducing foreign organisms, trampling ground while grazing, and eating vegetation. Why are bikes treated differently from horses with regard to non-Wilderness system trails?

• The proposed plan would prohibit mechanized travel in MA 1.41core areas (LRMP 3-15) and MA 2.2 Research Natural Areas (LRMP 3-23), but allow hikers and horses. To IMBA, it would seem more sensible to allow bikes in core areas, and to prohibit all public use in RNAs.

We surmise that the reasons for this discrimination among non-motorized users stem from two concerns, ecology and user conflict. In both cases, we believe that discrimination among non-motorized trail users is not justified.

Ecology: Almost no empirical research has been performed to differentiate the ecological effects of the three primary non-motorized trail uses. So any decision made for the purpose of protecting wildlife and ecosystems that would prohibit bicycling, while allowing hiking and equestrian uses, is arbitrary and capricious.

Supporting this idea, the DEIS at 3-19 notes, "There is little information available regarding differences in impacts between motorized and non-motorized trail use."

IMBA believes that such research is necessary. We are not facing a situation where information is somewhat inadequate. Rather, there is almost no science on this subject, so science provides little, if any, guidance regarding managing for the differences. We encourage the Forest Service to support research on this topic.

IMBA accepts that trail use affects wildlife. If agency managers believe that a conflict exists between trail users and wildlife in a particular area, then the trail should be re-routed, or seasonally closed to all users, or obliterated. Such non-discriminatory actions are more likely to resolve the problem, since the numbers of hikers are likely to grow as much as the numbers of bicyclists.

User conflict: If the rationale for discriminating between bicycles and horses and hikers is user conflict (as suggested at the end of DEIS 3-253), then WRNF planners are being short-sighted. While some pedestrian-only trails are appropriate, agency policy states a preferences for shared-use trails. As noted in Appendix B of the proposed Forest Plan (LRMP B-12), the Forest Service Manual, section 2300, states that the trails system will "not be dedicated to single use unless clearly necessary to resolve conflicts or create unique opportunities."

User conflict is usually manageable without resorting to closures. IMBA points to two very relevant documents. Andy Kulla, a planner with the Lolo National Forest, wrote a paper titled, "A hierarchy of options for managing trail user conflicts" (attached). It notes that closure of trails to a user group in an endeavor to resolve user conflict typically results in alienation and non-cooperation by that group. He lists many management actions that can usually resolve user-conflicts without closing trails. Moore, in "Conflicts on Multiple User Trails," written for the US Department of Transportation, expands on that principle. Moore offers additional insight and suggestions for user conflict resolution that do not lead to discrimination among trail users.

ECOLOGY: COMPARING IMPACTS

IMBA commends the Forest Service for an excellent job of analyzing and providing information regarding the ecological problems of the White River National Forest. Mountain bicyclists generally are very concerned about the deterioration of Earth's ecosystems. Fragmentation and perforation, along with decreases in wildlife populations, appear to be the most serious problems at hand.

We note that Appendix N of the DEIS, "Biological Assessment - Biological Evaluation," does not list trail use as an important factor in the decline of any mentioned wildlife species. The DEIS at 3-19 notes, "Generally, most species are able to move through areas with trails with little problem. The White River NF has not identified any species for which a trail would be considered to be a significant fragmenting effect."

The DEIS identifies major highways, including I-70 and CO Highways 82 and 9, along with urbanization, as serious threats to ecosystem integrity due to the habitat fragmentation caused by their construction and use. However, the Plan proposes no remedies for these problems.

Some remediation is possible. Wildlife overpasses or underpasses can re-link wildlife populations across transportation corridors. Better private land use regulation, combined with more money flowing to land acquisition processes, can contain sprawl.

While the Forest Service does not have authority over these issues, the agency can influence them. The Forest Service can communicate with the Federal Highway Administration and the Colorado Department of Transportation regarding the need for wildlife overpasses. Similarly, the agency can communicate with local governments regarding the ecological effects of sprawl.

Since many environmental groups share our concern with the possible ecological impacts of recreation, IMBA suggests that the Final EIS more thoroughly investigate the subject of recreation impacts on ecosystems and wildlife. In addition to studying differences among trail and road users, noted above, we recommend that you compare the effects of recreation to the effects of other Forest uses and problems. We suspect that the problems of noxious weeds, fragmentation from highways and logging, urban sprawl, and sedimentation from roads, are more significant than the impact of trail-based recreation, probably by orders of magnitude.

WILDERNESS AND ROADLESS AREAS

IMBA believes that it would be appropriate to designate some new Wilderness on the White River National Forest, but we cannot at this time endorse any particular areas. We do not support the extensive new Wilderness proposed in Alternative I.

On the other hand, we strongly support the preservation of all Roadless Areas and the Forest Service's intent that Alternatives C, D, E and I entail no construction of roads into roadless areas (Table 3-110, DEIS 3-387).

Bicyclists wish to travel in wild lands, and there should be management options, such as Roadless Areas, for protecting lands from development while allowing more diverse recreation than allowed in Wilderness. Management areas 1.31 (Backcountry recreation - non-motorized), and 1.32 (Backcountry recreation - non-motorized with limited motorized) come close to fulfilling this objective. The descriptions of 1.31 and 1.32 state the no road building would occur. However, Table 3-1 of the Proposed Plan (LRMP 3-3) indicates that timber harvest, oil and gas leasing, and developed recreation would be allowed there. Those activities usually require building roads.

While some Roadless Areas should be recommended for Wilderness, other should receive a protective management status that prohibits new roads and other developments, while allowing mountain bicycling. The prohibition on road building in Management Areas 1.31 and 1.32 should be strongly affirmed as a standard, rather than merely a description.

We would accept in some Roadless and unroaded areas a management area in the #1 category that allows motorcycle use on singletrack trails, but none of the #1 management area descriptions allow this use. IMBA opposes the use of all-terrain-vehicles in Roadless Areas, which are by definition the realm of singletrack trails.

Potentially relevant to protecting Roadless Areas, but less valuable, are the management areas in the #2, #3 and #4 categories. The standards and guidelines for these management areas do not preclude the construction of new roads.

Generally, all management areas should have standards that specify whether or not new roads will be allowed, and if allowed, what road densities will be allowed. Lower road density is preferable for mountain bicycling.

SOCIAL AND ECONOMIC SETTING

We question the data presented for the category "other recreation" on tables 3-163 and 3-164 (DEIS 3-163 & 164). Alternatives D and I would entail very significant decreases in trail miles available to mountain bicycling, yet the tables state that employment and income from "other recreation" (which includes bicycling, but not skiing, and fish and wildlife use) would significantly increase. Trail closures would likely have a significant negative effect on mountain bike tourism, and thus would strongly affect employment and income of bicycle shops, bike rental centers, and bike guides. It would also negatively affect tourism-based income to services such as restaurants and gasoline stations. Did the calculations for these tables consider the decreases in mountain bike tourism that would occur as a result of trail closures?

WATERSHED MANAGEMENT

IMBA and its members care about water quality. In the White River NF, water quality depends on the health of the watershed. The DEIS notes, "Nearly all of the management activities proposed in this revision have the potential to affect water resources." (DEIS 3-64) Dispersed recreation occurs on roads and trails, and these routes can cause sedimentation into waterways.

IMBA supports plans that would seasonally close roads and trails for legitimate environmental reasons. This is particularly important during the late fall, when rain and low temperatures make unsurfaced travelways particularly sensitive to rutting and erosion. The Forest Plan should set a policy that would allow the Forest Supervisor to make temporary emergency closures of roads and trails when rainfall is extremely heavy. Temporary emergency closure of trails in July, '99, could have prevented much wear and tear.

But seasonal closures will be insufficient to fully address the watershed management problem because most sedimentation results from poor road design and maintenance.

The DEIS notes that watershed conservation practices can adequately mitigate road and trail impacts. "However, bringing roads into compliance with these new protection measures is a major challenge because 70% of the current transportation system on the Forest has not been maintained to the full standard. ...Future road and trail management should consider bringing existing roads into compliance with the new standards and guidelines." (DEIS 3-58)

The goal that forest managers "should consider" bringing roads into compliance is inadequate. There must be a stronger commitment on the WRNF to bringing the existing road system into compliance with contemporary watershed conservation standards. The Draft Plan should include a specific goal stating how many problematic stream crossings, eroding roads, and improperly located trails will be corrected each year.

IMBA and its affiliate clubs can assist in the effort to correct problems of trails eroding into streams. Through our Trail Care Crew, Trailbuilding Schools, and general trailwork programs, we address this problem frequently on public lands across the country. The White River NF already has a cooperative trailwork relationship with IMBA's affiliate, the Summit Fat Tire Society. The Forest Service should maintain and enhance this relationship, and seek to form new partnerships with mountain bikers and other trail users in the other communities on the Forest.

The combining of construction and reconstruction of trails into one statistic in Table ___ can be problematic. In general, trail reconstruction ought to have a higher priority - the need is high on the WRNF because most trails were constructed without the benefit of modern standards for water control. The preferred alternative proposes the lowest number of miles of trail construction/reconstruction.

IMBA strongly disagrees with the statement in the last paragraph of DEIS 3-60 that "...routes for motorized and non-motorized off-highway vehicles should terminate a distance from water bodies to avoid adverse impacts to riparian zones and water quality." We can only assume that "non-motorized off-highway vehicles" refers to bicycles. If so, this sentence presumes that bicycles have a high erosive power, which is false. Horses cause more erosion per user than bicycles and motorcycles. Furthermore, bicycles are not off-highway vehicles and there is no such thing as a "non-motorized OHV." We recommend that the sentence not refer to any user group, since all users have the potential to cause trail erosion that can harm water bodies.

We must note that not all trail erosion is harmful to watersheds. Most miles of trail are sufficiently distant from water bodies that their erosion - while cause for concern - causes no sedimentation. Upland trail erosion damages a human transportation system, much like potholes in roads, but does not create significant ecological impact.

FORESTRY: TIMBER AND FIRE MANAGEMENT

The proposed plan does not adequately deal with the impacts of vegetation management on recreational trail experiences. The DEIS (3-291) notes that logging affects recreation experiences in several ways. "These include increased noise and dust levels; the sight of landscapes altered by clearcutting; the presence of slash piles, burned areas, and roads constructed for timber sales; conflicts with logging truck on roads used by other drivers or by bicyclists..." But the Proposed Plan contains no standards to avoid or mitigate these impacts. The closest the plan comes is in the Guidelines for Scenery Management (LRMP 2-27). The guidelines might alleviate some of the visual impacts of logging, but do not reduce the effects of roads, logging trucks, dust and noise. The Plan should include specific standards that will address all of the impacts of vegetation management on recreation experiences. Such standards should include 100-foot buffer zones along sections of trails where logging does not occur.

IMBA accepts logging as a legitimate use of public lands and understands how it can positively affect wildlife habitat and other values. However, given the long record of problems with logging on the national forests, we question whether logging will effectively achieve D's goal of rapidly restoring diverse, healthy ecosystems.

As noted in our comments on Intermix, below, logging ought to be used as a tool more often on lands near developments, and ought to be used less often in forest interiors and unroaded areas.

IMBA supports more use of prescribed fire. Bicyclists find a burnt forest more aesthetically appealing than a logged forest. After the Buffalo Creek fire on the Pike National Forest, cyclists participated in restoration activities and today enjoy riding in that burnt area.

The DEIS statistics regarding prescribed fire are confusing. In the introduction to the subject, it states that about 3,200 acres are burned each year (DEIS 3-153). But Table 3-43 indicates that 5,700 acres are burned each year in Alternative B. Narrative at DEIS 3-162 states that all alternatives will burn 7,500 acres/year, but Table 3-43 lists burning ranges from 3,750 to 6,200 acres/year.

INTERMIX MANAGEMENT AREA

IMBA encourages more use of the 7.1 Intermix Management Area on the WRNF. The private lands around WRNF are rapidly urbanizing and this trend will continue.

Stand thinning to reduce fuel loading is particularly valuable in Intermix zones. Fire is most problematic at the wildland/urban interface, and suppression efforts are logically directed to that area first. IMBA supports more use of prescribed fire and this will be more possible in forest interiors if forest exteriors are better managed to prevent wildfires.

MISCELLANEOUS CLARIFICATIONS

• The DEIS (3-243) states that bicyclists would like to see more trails specifically designed and managed for mountain biking. Bicyclists do want more trails open to bicycling, but we want trails shared with hikers and equestrians. We don't seek bicycling-only trails.

• The DEIS uses confusing language to describe the rule that would prohibit cross-country travel by motorized vehicles and bicycles. The DEIS (3-255) refers to a low public desire for "off-road" motorized travel. However, there is a high demand for travel on trails, which are by definition off of roads. What was probably meant is that there is a low desire for travel off of trails and roads. The Forest Service should never equate the term "off-road" with "off of trails and roads."

• The DEIS, in the section on National Trails, poorly characterizes the effects of recreational use on trails. It states (3-431), "Recreation use affects trails through compaction and damage to drainage structures, leading to increased erosion." The mention of compaction is improper there, because compaction actually leads to reduction of erosion. Compaction of soil is highly undesirable on natural surfaces, but exactly what is needed to make a trail surface more stable and sustainable. Recreation use of trails contributes to erosion by damaging drainage structures and by shearing trail soils, not by compacting soils.

• We do not understand how reconstruction of a trail increases perforation (DEIS 3-19). Construction of new trails causes this effect, but reconstruction often involves simply constructing new tread on an existing corridor. Why does reconstruction cause an ecological impact? The discussion on page 3-19 needs to separate trail construction from reconstruction.

Thank you for your consideration of these comments.

Sincerely,

Tim Blumenthal,
IMBA Executive Director

Attachments:
"Joint Principles for Management of the White River National Forest"
"A hierarchy of options for managing trail user conflicts"
"Conflicts on Multiple-Use Trails - Executive Summary"
"The Importance of Singletrack"