Margaret Taylor and the State Trails Committee
State Trails Program
13787 South Hwy 85 N.
Littleton, CO 80125

Thank you for the opportunity to comment on 2017 Non-motorized Recreational Trail Grant proposals. I am submitting my comments on behalf of the Colorado Chapter of the Backcountry Hunters and Anglers. I represent our State Chapter as the Habitat Watchman for the Uncompahgre and as the Regional Director for the Central Western Slope. Backcountry Hunters and Anglers is a grass roots organization of sportsmen and women who strongly believe in the principals of the North American Wildlife Conservation Model and the value of our public lands for fish and wildlife habitat and the traditional fishing and hunting opportunities that are available to all sportsmen. As a group of sportsmen, we are highly dependent upon our public lands to support the fish and wildlife species we all enjoy. We believe in the conservation and management of fish and wildlife habitats on our public lands, and in providing undisturbed backcountry areas for fish and wildlife and the opportunity for traditional methods of hunting and fishing that challenge us physically and mentally and emphasize the principals of fair chase.

Our membership can also be characterized as families who enjoy undisturbed backcountry for reasons other than hunting and fishing. We cherish the opportunity to venture into areas free of the noise and activity of OHV’s and bicycles to enjoy the peace and solitude of the outdoors with our friends and family on river trips, day hikes, backpacking trips, and horse pack trips. We also strongly feel that these opportunities should not only be available to us now but to our future generations as well.

Magic Meadows Trail – Norwood Ranger District, GMUG National Forest
The Norwood Ranger District is applying for State grant funding to implement a combination of new trail construction and decommissioning to provide a single-track connector trail between the existing Sunshine trail and the Prospect Basin/Boomerang road in the vicinity of Alta Lakes just south of the Telluride Ski Area. This portion of the National Forest has a long history of unauthorized trail development and trespass upon private lands by former outfitters based at the Skyline Ranch, and subsequent unauthorized use by local mountain bikers. The configuration of private land inholdings within this area of the Forest recently changed as a result of the Wilson Peak Land Exchange (2015), which has raised concerns from the local mountain biking community over maintaining the system of trails they have become accustom to riding. Now the Forest Service is faced with adopting, modifying, and maintaining this trail system to meet the demands of the people who created them.

This portion of the National Forest provides high quality summer range for elk and mule deer. Prospect Basin within the permit boundary of the Telluride Ski Area is a significant elk calving area. The Forest Service has protected this calving area through implementation of a seasonal closure to public recreation from the time the ski area closes in early April through the first of July. This closure includes all mountain bike trails within Prospect Basin, which is accessed in part from the Boomerang Road. This portion of the National Forest is also extremely important habitat for the Canada lynx. Lynx travel frequently between Lizard Head Pass to the south and Prospect Basin within the ski area.

Although there may be a legitimate need to create a sustainable connector trail in this area, I seriously question the Forest Service meeting the requirement to complete sufficient site-specific NEPA analysis and CPW/public involvement prior to project implementation. The Uncompahgre National Forest finalized a Travel Management Plan for the Forest in 2002, and has been implementing those decisions as funding is available. The unauthorized trails within the boundaries of this grant application were not approved or included in this management plan. In fact, within the grant application the Forest Service states that it “plans to conduct a travel management analysis for the greater Alta Lakes area in 2017” (Selection Criteria 2c), which indicates to me that additional travel management planning is necessary.

It is wrong to assume that responding to an issue within the EA for the Wilson Peak Land Exchange is sufficient to cover travel management within the Alta Lakes area or the actions proposed for the Magic Meadows trail. When I review the project application and portions of the Land Exchange project record provided in the application, it is obvious that the Forest Service limited their outreach and responses to public comment on trails to those who were concerned over losing their access to the unauthorized trails following the exchange. The project record is limited to those groups and individuals only. There is no record of input from the local District Wildlife Manager or CPW Area wildlife biologist included in the application. There is also no acknowledgement of the wildlife resource values of the area, or reference to the existing elk calving seasonal closure in Prospect Basin that could affect use of the proposed Magic Meadows trail.

Based upon these issues, I request that the application for the Magic Meadows trail grant be denied by the committee until the Forest Service can demonstrate they have thoroughly reviewed the proposal with the local District Wildlife Manager and CPW Area wildlife biologist, provided opportunity for public comment on travel management from all interested parties, and completed the proper site-specific NEPA for the project to ensure wildlife values and mitigations have been incorporated in to the design and use of the trails.

Uncompahgre ST Plan - COPMOBA
There is an approved EA for the Dry Creek travel plan (BLM Uncompahgre Field Office) and implementation has been initiated on the project area. The Dry Creek EA very clearly identified big game winter range concentration areas within the Dry Creek analysis area and mitigated the impacts of motorized and mechanized travel with a seasonal closure from December 1 through April 30. However, implementation and compliance with this seasonal closure has been ineffective at meeting this resource objective. Last year COPMOBA submitted an application for construction of 50 miles of new mountain bike trails in this same winter range that focused solely on the physical features and limitations of the landscape. Fortunately this proposal was rejected by your committee based on wildlife values and concerns for redundant trails.

Since that time COPMOBA has worked in cooperation with the BLM and local CPW wildlife managers to revise their proposal, and is now requesting State grant funding to develop a detailed trail plan that would supplement the existing travel plan analysis. This comprehensive trail plan would include the construction of a reduced number of additional single track non-motorized trails, decommissioning unnecessary duplicate routes, and installing locking gates to improve the effectiveness of seasonal closures designed to protect big game winter range.

The results of the trail planning would be brought forward to the BLM to initiate additional public review and comment to complete site-specific NEPA for implementation within the Dry Creek project area.

This is exactly the kind of cooperative review and planning that should be taking place before any trail construction projects are considered or approved by the State trails grant committee, and we support their application to do so. We believe that the work that COPMOBA has done in cooperation with the local District Wildlife Manager and CPW Area wildlife biologist should be the standard method of developing project proposals on our public lands prior to the federal agency conducting their site-specific NEPA. Before any projects are considered for State grant funding (motorized or non-motorized) the applicant should demonstrate that they have included meaningful involvement of CPW District Wildlife Managers and Area wildlife biologists in their project design, and that the use of those trails will not adversely impact the long term productivity and capacity of the habitat to sustain wildlife populations.

On a larger scale, we would like to see State grant funding used in a proactive way to prevent the continued degradation of wildlife habitats on our public lands from prolific recreational trail development. We feel there is a need for a Statewide comprehensive analysis or plan where CPW and federal agency wildlife managers work with trail user groups to map out areas of greatest concern that need to be avoided by further recreational development to protect wildlife. This type of analysis is currently lacking in Colorado and would help provide a balance between developing recreational trails and maintaining the long-term viability of our wildlife populations.

Respectfully,

Craig Grother

Craig Grother
Backcountry Hunters & Anglers
12/22/2016