Commenting on an Environmental Assessment (EA)

The Mountain Bike Advocate's Guide to Planning and the United States Forest Service

Woody Keen
(address)

Mae Lee Hafer
USFS Pisgah District
1001 Pisgah Highway
Pisgah Forest NC 28768

To whom it may concern,

Please accept my comments concerning the EA for the Bent Creek Complex. I am opposed to the Alternative A (preferred by USFS) as proposed in the EA document. My objections are as follows:

1. The EA only gives 2 alternatives, not a range of alternatives as called for by NEPA. A more complete range of alternatives should be studied and presented to the stakeholders before any decision on this project moves forward.

2. The information in the EA is confusing, not detailed enough and certainly not site specific enough for stakeholders to understand the impacts of proceeding with this project. The confusion lies in that the EA contradicts itself when talking about the mileage of roads to be upgraded.Page 4 reads " Harvesting and demonstration access will require approximately five miles of existing road reconstruction". Page 7 reads "Harvesting and demonstration access will require approximately three miles of existing road reconstruction". Which is it, 3 or 5 miles? The USFS owes it to the stakeholders to provide accurate information on proposed projects and this clearly has not happened with this EA. The EA certainly is not detailed enough (or site specific) in that it does not give specific information on which trails would be effected in this project. Though there is a map indicating trails to be upgraded, there is no list with trail names specified.

3. The EA fails to effectively identify the impacts on the human environment in terms of visual impacts perceived by recreational users and the economic losses related to mountain biking. Though the EA speaks of recreation, it certainly glosses over this without a sincere effort. In fact, no USFS recreation staff was consulted in the development of this EA. This is observed by seeing no credits to USFS recreation staff in the Appendix A, and through a conversation with Recreation Staff Officer for Pisgah District Dianne Bolt and Trails Manager Ronnie Cairns. Recreation is very compatible with Bent Creek and other USFS lands; the LRMP and a Recreation DN that was released last year that established the trail system in Bent Creek have identified this. More research on the possible impacts to recreation needs to be studied before moving forward with this project. One suggestion would be a trail user survey performed on site asking questions that pertain to the effects logging would have on trail use in Bent Creek. Page 37 of the EA states, " Impacts on other resources (particularly recreation) would not result in a noticeable change in the economy of the region". I would argue that this statement is false and the EA researchers have no backing for such a statement. If all the bike shops in Asheville were polled, I would guess that all of them would respond that turning 5 miles of trail into roads would have an negative impact on their business, both that coming from local sources but also from out of town tourist. Bent Creek is a destination mountain bike area and the loss of trails will no doubt result in the loss of revenue thereby negatively affecting the local economy.

4. In the Code of Federal Regulations 36CFR212.1, unclassified roads are defined as" Roads on the National Forest System lands that are not managed as part of the forest transportation system, such as unplanned roads, abandoned travel ways and off-road vehicle tracks, that have not been designated and managed as trails....". The EA refers to upgrading "old unclassified roads"in some sections of the EA, and other places it refers to "5 miles of existing low standard road". Again this is very confusing to the reader and it almost seems, as that was the intent. You have to look hard to find that we are really talking about turning trails into roads. Page 34 reads," By far the most notable effect on recreation will be the permanent change of five miles of currently designated horse-bike-hike trail to five miles of closed multi purpose and passenger vehicle road". Though the EA does identify that these trails started as management roads (page 33), they have in fact turned into nice single-track trails that most users prefer (not just hikers) over system type roads. The USFS always seems to find money and be able to pass through the NEPA process for building more roads, and yet never seems to have time, money or energy to create new trails.

5. The EA identifies that the USFS will lose money on this project. I strongly object to the selling of timber off of public lands at a net loss to the taxpayers. This fuzzy math has gone on way too long on USFS lands and must stop now.

6. The need established for the project is questionable. One of the needs states," Provide access in all weather conditions while protecting environmental quality". Researchers can in fact access all areas in question in all conditions via foot or bike. Perhaps traveling in one of these modes of travel (instead of a truck) would give a greater appreciation of the forest for the qualities that recreation users see i.e. standing trees in forest instead of board feet of timber products. If motorized travel must be used to provide access, perhaps the FS should invest in a small vehicle such as a John Deer Gator. Such an investment would be way cheaper(and still provide all weather access) to the tax payers than upgrading 5miles of trail turning them into improved surface roads.

7. Blue Ridge Bike Club has countless hours of sweat equity in the form of volunteer work to maintain the trails proposed to be "improved" turning them into roads. Does this sweat equity not count for anything? By moving forward with the proposed projects, the USFS in some ways jeopardizes a long-standing relationship with a volunteer group responsible for some of the best trail maintenance on the Pisgah District. In fact, BRBC is the only volunteer group performing any volunteer trailwork in Bent Creek complex. The USFS is justifying these "upgrades" by stating that these are old "management" roads; this means they are old timber extraction routes. Many trails (most) in Pisgah are leftovers from the timber industry, some roads, some skidder trails and some old railroad grades. Are all of these trails in jeopardy as well? The more of these trails that get turned into roads, the less I want to volunteer my time working on such trails.

8. The USFS issued a DN and FONSI 2 years ago establishing 25 miles of gated roads as LWOs. The decision was made to exclude mtn bikes (and horses) from these roads citing damage to resources. Now the USFS has issued an EA that will turn nice single-track trails into "system" roads and seems to be comfortable with that level of impact to the resources in the proposed project. I simply fail to see the logic. The impacts (to the natural ecosystems and landscape) that would occur in this Bent Creek project are far beyond what bikes could have ever imparted by riding on the LWO roads. How can the USFS justify this project in that light?

In closing, I am adamantly opposed to Alternative A for this project. The only acceptable Alternative in this EA is the No Action Alternative.

I realize that this comment letter comes across as adversarial. Proposed projects to turn 5 miles of trail that I have invested time into maintaining warrants such a response. I value my relationship with USFS personal and enjoy working with many staff on a range of district projects. I look forward to continuing my volunteer work on USFS Pisgah District lands but as noted in this letter the moving forward of this proposed project would diminish my desire to continue my hard work.

Thank you for your consideration of my comments.

Sincerely,

Woody Keen