Letter Generator for Tellico Comments - NO EXCUSE NOT TO COMMENT

Done.

Here was my letter:

Dear Ranger Lohr,

I am writing to provide comments on the scoping letter for changes at the Upper Tellico ORV Area in the Nantahala National Forest.

I would like to strongly suggest that the FS consider scoping for reopening and maintaining trails at Tellico instead of closing trails. If the purpose and need for this action is to reduce sedimentation in streams, then that should be the desired outcome of this analysis, not closing trails. If the FS were to change the proposed action to reduction of sedimentation, this would allow the FS to conduct a more comprehensive analysis under NEPA and could provide recreation opportunities to OHV community and reduce sedimentation in the Tellico River watershed at the same time.

Please don't close the trails so many of us love to enjoy. I'm 25 years old, my dad is 50, and my grandfather is in his upper 70's. Riding these trails is the only way that all three of us can enjoy the great outdoors together. Not everyone can hike the mountains and not everyone wants to travel a paved or gravel road. OHV trail riding gives a sense of adventure that so many enjoy.

I really hope that one day I'll be able to take my kids up School Bus or Slickrock and tell them stories about their great-grand-dad riding with me up those same obstacles. Please take into consideration what closing these trails really means to real people.

We live in a great country that has been blessed by God with the resources and knowledge to make this area safe and enjoyable for everyone. Let's tackle this challenge together instead of giving up at the first signs of adversity.

Thank you for your time and I hope you have a blessed day!

-phil

I sent my letter in!

My letter is in the mail. 11 pages long.

Ranger Steve Lohr
Nantahala National Forest
Tusquitee Ranger District
123 Woodland Dr.
Murphy, NC 28906-3145
828-837-5152

July 3, 2008

Dear Ranger Lohr:

I am writing to provide you with my comments to the proposed action involving the Upper Tellico Off-Highway Vehicle Road and Trail System (OHV System). These comments are provided as requested in your Scoping letter dated June 9, 2008.

My comments are below:

1)The purpose of this action stated in your scoping letter states an unproven connection between erosion from the trails in the OHV System to the cause of turbidity in the Tellico River and its tributaries. The presented studies did not use the correct procedure to determine if the OHV System is responsible for sediment in the Tellico River. Please address the cumulative impacts of development and logging in the watershed as part of your analysis.

2)The initiation of this proposed action was caused by the threat of suit by Trout Unlimited and other special interest groups in an effort to protect their native brook trout. I request that the proposed action be to conduct a watershed-wide study to assess the population condition and habitat of the brook trout.

3)The proposed action is to modify the existing OHV System with user limitations and closures. I respectfully request that you modify the proposed action to support open access to the trails and proper implementation of the existing management plan for the area.

4)As a point of fact, the North Carolina Wildlife Resources Commission (NCWRC), who completed the monitoring of the wild trout population in the Tellico River watershed, did not call for closure of trails in the OHV System, but rather recommended that actions be taken to “Design and implement a study to determine cause-and-effect relationships of environmental factors, both natural and man-caused on wild trout populations in the Tellico River watershed. The study should be designed to identify impacts to trout recruitment and be fully integrated to include measurements of sediment loading (sources, rates, and timing) and other water quality parameters”. I request that the proposed action be changed to the recommendation suggested by the NCWRC.

5)You state in your scoping letter that you would “reduce the trail system from its current 39.5 miles (all mileage figures are approximate) to 24 miles and would implement use-management techniques including seasonal and wet weather closures to reduce damage to the trail surfaces and thereby reduce sedimentation potential and long term maintenance costs.”

I respectfully request that the proposed action statement be changed to not predetermine closure of trails. The Council for Environmental Quality (CEQ) is charged with the implementation of the National Environmental Policy Act (NEPA). The CEQ regulations, specifically Section 1500.1 state that the “NEPA procedures must insure that environmental information is available to public officials and citizens before decisions are made and before actions are taken.” In this instance, your office has changed the purpose and need for an action from protecting brook trout to closing the OHV System. This change is in direct opposition to the intention of the CEQ regulations where it clearly states that the NEPA process must be conducted before decisions are made and actions are taken.

6)You stated in your scoping letter that “Many of the trail segments that are popular for high-challenge rock-crawler opportunities are heavily eroded, have high potential for contributing sediment to nearby streams, and are therefore proposed for closure and rehabilitation.”

There is no definitive proof that these trails are responsible for sediment in nearby streams. The methods for collecting samples of water were flawed in that only a downstream sample was obtained and tested. In order to prove that the OHV System is contributing to the sedimentation of the Tellico River and its tributaries, it would be necessary to take both up and down stream samples and then compare the samples. I request that the USFS conduct valid sampling that considers the cumulative impacts of human impact throughout the watershed, and the impact that impact has on aquatic species.

7)“Sediment, or particles of soil and other material that settle out in streams, is a major concern in forested watersheds in the Southeast (Coats and Miller, 1981). Excess fine sediment in stream systems fills interstitial space between larger rocks and can smother fish eggs and the aquatic insects they feed on. This can also deprive small fish of cover from predators, since their hiding places among the small rocks become filled by sediment.”

Studies within the watershed have not been completed to determine if the habitat or populations have been impacted specifically by the OHV System. In addition, your analysis takes into consideration only one issue that is impacting native trout. The Eastern Brook Trout Joint Venture also cites Climate Change, Acidic Deposition, Water Temperature, Urbanization, Invasive Species, and Habitat Degradation and Fragmentation (including physical barriers to breeding areas and chemical pollution). I request that the analysis of impacts to native trout include all relevant parameters and be completed. At this time, closing trails on the area without this analysis is unfounded.

8)The Nantahala and Pisgah Land and Resource Management Plan (the Forest Plan) standard for soil and water management states: “Prevent visible sediment from reaching perennial and intermittent stream channels….”

This can be done with mitigation methods and preventative maintenance that the USFS has deferred for many years. The lack of implementation of a viable maintenance plan in the area has allowed for some degradation of the area that can be remedied. I respectfully request that you consider the maintenance of the area to reach a sustainable balance while remaining open for use. I also request that you provide an economic analysis of the amount of volunteer time and money, and grant time and money that could be available for this effort.

9)Please see the following table for comments to table of “trail specific finding from the condition surveys along with my proposal based on these findings” that appeared in the June 9, 2008 Scoping Letter.

(In the letter this is a table, and much more impressive, but I only included the comment here because I can't paste a table)

Trail 1 – In your analysis, please include an analysis of the potential increase in traffic over a newly created paved road.

Trail 2 – Tipton Knob - I strongly opposed the removal of this section from the OHV System. The FS states that they are going to close this section of trail because they do not know how to properly maintain it for use as an OHV trail. Grant money, volunteer labor, and expertise are all available to the FS to maintain this area properly. I contend that the FS is not considering all viable options to closure. Specific alternatives for this section of trail should include a binding agreement with local volunteer organizations to effectively maintain this area. The FS should also include analysis of an alternative that would harden the trail up to the “rock garden” and then creation of a less challenging access trail to be built for ATV bypass. It is my opinion that the silt trap at the base of the “rock garden” is effective in preventing silt from traveling offsite. In addition, your analysis should consider hardening of the Upper part of Trail 2 and closure of the area to ATV’s.

Trail 3 - Bearpen - No substantive comments.

Trail 4 – Fain Ford - I oppose the closure of Trail 4 as proposed. It is my belief that the area in question can be stabilized and maintained for continued OHV use with appropriate engineering methods including and anchored gabien wall system, surge stone, and proper sloping of the roadbed. I support trail maintenance and rerouting to reduce potential impacts when the fundamental nature of the area is not compromised by the proposed action. I respectfully request that the FS include alternative routes, maintenance plans, and their specific analysis in the NEPA document.

Trail 5 – Tellico River - I support trail maintenance and rerouting to reduce potential impacts when the fundamental nature of the area is not compromised by the proposed action.

Trail 6 – State Line Loop - I support trail maintenance and rerouting to reduce potential impacts when the fundamental nature of the area is not compromised by the proposed action.

Trail 7 – Peckerwood Connector - I support trail maintenance and rerouting to reduce potential impacts when the fundamental nature of the area is not compromised by the proposed action.

Trail 8 – Bob Creek - It seems the only reason for closure of Trail 8 south of the intersection with Trail 7 is due to the closure of Trail 4 in that area.

I oppose the closure of Trail 4 and Trail 8 in this area. It is my belief that the area in question can be stabilized and maintained for continued OHV use. Please include and engineering, environmental, and economic study to explore maintenance options at this location.

(continued in next post)

I sent my letter in! (continued)

...

Trail 9 – Mistletoe Connector - I disagree with the assessment and believe that qualified engineers can devise a way to mitigate any potential damage to streams from Trail 9.

I strongly opposed the removal of Trail 9 from the OHV System. The FS states that they are going to close this section of trail because they do not know how to properly maintain it for use as an OHV trail. Grant money, volunteer labor, and expertise are all available to the FS to maintain this area properly. I contend that the FS is not considering all viable options to closure. Specific alternatives for this section of trail should include a binding agreement with local volunteer organizations to effectively maintain this area.

Trail 10 (ATV Only) – Round Mountain - Please consider an alternative action to repair the trail and open it to full size OHV use. This is a low gradient trail that would be maintainable if accessible to equipment.

Trail 10A (ATV Only) Round Mountain Spur - Please consider an alternative action to open it to full size OHV use. This is a low gradient trail that would be maintainable if accessible to equipment.

Trail 11 – Chestnut Mountain - I support trail maintenance and rerouting to reduce potential impacts when the fundamental nature of the area is not compromised by the proposed action.

However, this is not one of those cases. The challenge areas are the focus of these areas and should remain for those that desire more difficult terrain. I support the construction of bypasses and request that representatives from SFWDA be included in the process to determine feasibility and construction of the alternative routes.

Trail 12 – Hawk Knob Trail - I disagree with the assessment and believe that qualified engineers can devise a way to mitigate any potential damage to streams from Trail 12. In addition, please consider an alternative that would reroute the bottom of Trail 12 along the top of a small ridge that crosses Trail 3 on the Trail 10 side of Trail 12.

I strongly opposed the removal of Trail 12 from the OHV System. The FS states that they are going to close this section of trail because they do not know how to properly maintain it for use as an OHV trail. Grant money, volunteer labor, and expertise are all available to the FS to maintain this area properly. I contend that the FS is not considering all viable options to closure. Specific alternatives for this section of trail should include a binding agreement with local volunteer organizations to effectively maintain this area.

10)“When and how OHVs use the system can influence the potential for erosive runoff to reach the Tellico River and its tributaries. Vehicles on trails after rain events will churn up more mud than vehicular traffic during dry times. Similarly, traffic during the winter period of freezing and thawing of the road surface can increase sedimentation potential and damage the trail surface. Two-wheel-drive use of the system can churn up soil when tires spin to gain traction. Eliminating wet weather use, winter use, and two-wheel-drive use would hopefully allow the system to stay in acceptable condition much longer than is currently the case, thus reducing annual maintenance costs from what they would be otherwise.”

The unspoken implication of this paragraph is that the FS is suggesting the permanent closure of trails, the seasonal closure of trails, and the weather dependent closure of trails as a way to manage costs of maintaining the area. The motorized recreating public will not accept monetary constraints as an excuse for trail closures, especially at the Upper Tellico OHV System. The Southern Four Wheel Drive Association (SFWDA) has been on the ground working with FS personnel for over 20 years to maintain and improve the trails at Tellico. There are several grant and volunteer programs available, and the OHV community is committed to help provide the tools to address legitimate concerns about route maintenance. Therefore, my comment is that you address any legitimate maintenance concerns by incorporating a training protocol into your plan that would train agency staff on how to apply for grants, use the available ICE-T Money, effectively manage volunteer programs, and learn about and apply for other funding sources. In addition, you might consider MOUs or other similar agreements with recreational groups, such as the SFWDA.

11)Your scoping notice states:

“Following are the proposed actions to manage OHV use:
1. Seasonal closure of the entire OHV System from January 1 through March 31 each year.
2. Short term closures as necessary following high rainfall events.
3. To facilitate temporary closures, camping adjacent to the trail system would be eliminated.
4. OHVs (other than vehicles with two wheels) must have 4-wheel drive locked in. [Motorcycle and dirt bike use remains the same as now.]

As I have written in the above specific comments, I would request that your proposed action be modified not to “manage OHV use,” but to manage sedimentation occurring in the Tellico River and tributaries and to assess potential impact of that sedimentation on trout species in the waterbodies. If the perceived problem is an impact to fish species, then the appropriate action is to determine if there is an impact, and the cause(s).

In addition, I am opposed to your proposed actions 1, 2 and 4 above for these specific reasons:

1.Please provide evidence that this approach will reduce the amount of sediment and benefit the native brook trout population in the upper reaches of the Tellico River watershed. If that evidence is not available, then seasonal closures are not appropriate at this time.

2.Please provide evidence that this management approach will reduce sedimentation in the waterbodies in the area. Short term wet weather closures will make planning to come to the area impossible for those that travel to get there. It will be costly and difficult to schedule a vacation to the area if people have no idea if the trails will be open. In addition, it will be increasingly difficult to schedule special events (fund raisers, work days, clean up days) that benefit the area.

3.Please be specific about removal of camping. Which areas would be removed? How many campsites would these removals effect? The FS recently improved the Stateline Campground at a great expense. How much money would be wasted if that campground was closed?

4.Please define OHV. Is that full size OHVs (like Jeeps) or ATV’s and UTVs? How to you propose to reduce the impact of motorcycles with their narrow wheels and knobby tires?

11) Your scoping notice states that the “Forest Plan standards for OHV trail “levels of challenge” and “miles per square mile” (trail density) are inconsistent with both the existing trail system and the proposed trail system”.

Please explain why, if you are proposing to change the language on Pg. III-11: a. from “Designate routes that will:- provide easy to moderate levels of challenge;…” to “Designate routes that will: - provide “various levels of challenge:,” you are eliminating all “challenge areas” that would provide anything other than easy to moderate levels of challenge.

In addition, you are proposing removal of the language in the Forest Plan from “Provide opportunities in response to identified needs to an approximate density of 2 miles per square mile in any management area unit.” You go on to explain that “Removing the OHV opportunity density standard: The current Upper Tellico OHV System trail densities are approximately 4.2 miles of trail per square mile for most of the area. The proposed action would reduce those densities to approximately 2.8 miles per square mile. This still exceeds the Forest Plan standard of approximately 2 miles per square mile. By removing the density standard we can tailor the density for a given trail system to a wide variety of site-specific resource- and user-related variables, such as habitat for particular species, proximity to water, topography, vehicle types and seasonality of use. A standard density is not an established measure of trail system success either regionally or nationally. The proposed Forest Plan change would achieve greater consistency with national guidance on OHV trail system management.”

Please provide justification of your calculation that the trail density is 4.2 miles of trail per square mile for “most” of the area. Also please define “most” in acres. Page III-54 of Amendment 5 of the LRMP for the Forest states that Unit 1B (where the OHV System is located) is 38,498 acres. In the NCWRC document entitled “A Summary of Wild Trout Population Monitoring in the Tellico River Watershed, 1994-2006” it identified the area s 2,023 hectares (approximately 5000 acres). It is my understanding that there are no other approved OHV Systems in the management unit and therefore the density would be well under the threshold, for either of these area measurements. Again, please explain your reasoning and provide your calculation and justification of these numbers for public comment.

12) You stated that the decision criteria for the proposed action and any alternatives will be especially important in deciding on a course of action. I agree with that and ask the following regarding those specific criteria.

1.The road and trail system cannot continue to contribute additional visible sediment to the Tellico River and its Tributaries.

In order to make this a decision criteria, first there must be proof that the OHV System is the cause of “visible sediment” over the background. Please provide scientific evidence that this is the case. In the event that you can not provide this evidence, please revise criterion #1.

2. The road and trail system cannot repeatedly incur excessive maintenance and reconstruction costs.

Please provide a detailed accounting of all the user fees, grant money, and internal budget for the maintenance of the Upper Tellico OHV System. In addition, please provide a listing of the deferred maintenance and the reasons for the deferrals. Also, please provide the requests that have been made of SFWDA and any other user groups to assist with maintenance at the OHV System. Finally, please provide the completed assessment of current and future needs of the OHV system. It is unacceptable and presumptive at this stage in the NEPA process to make statements that assume non-availability of assistance from private partner groups.

In conclusion, I want to thank you for your time to review my comments. I am looking forward to participating in the NEPA process.


Sincerely,


Heather Royston
Norcross, GA