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.