COMMENT AND ISSUES ANALYSISa123.g.akamai.net/7/123/11558/abc123/forestservic...COMMENT AND ISSUES ANALYSIS December, 2012 USDA, Forest Service Intermountain Region (Region 4) Manti-La

Moab Non-Motorized Trails Project

COMMENT AND ISSUES

ANALYSIS

December, 2012

USDA, Forest Service

Intermountain Region (Region 4)

Manti-La Sal National Forest

Moab/Monticello Ranger District


COMMENT ANALYSIS

Page 1

Section 1 .Commenters

Forty-three separate comment letters were received in response to the public scoping conducted for the Moab Non-motorized Trails proposal. Twenty-seven of the comments came from individuals, nine from

interest groups, five from local business and two from local governments/officials.

Table 1. Identifies the persons, organizations, or agencies who responded to the Scoping Letter with

comments (including letters, phone conversations, and emails regarding the proposed action.).

The reference number is used to determine who the commenter is for each of the varied comments.

TABLE 1

COMMENT

REF #

NAME/TITLE COMPANY/

ORGANIZATION

DATE RECEIVED

#1 Ashley Korenblat

Kirsten Peterson

Kimberly Schappert

Moab Trails Alliance 7/22/2011

#2 Shawn Hanka Individual 7/22/2011

#3 Kalen Jones Individual 7/22/2011

#4 Tim Peterson,

Program Director

Kevin Mulller, Utah

Environmental

Congress

Liz Thomas, Field

Attorney, Southern

Utah Wilderness

Alliance

Veronica Egan,

Executive Director,

Great Old Broads for

Wilderness

Grand Canyon Trust, Utah

Environmental Congress,

Southern Utah Wilderness, and

Great Old Broads for

Wilderness

7/22/2001

#5 Nick Sandberg,

Public Lands

Coordinator

San Juan County 7/21/2011

#6 Dennis Silva Individual 7/21/2011

#7 Kristi Jensen Coyote Shuttle 7/20/2011

#8 Paul Frank Individual 7/22/2011

#9 Brooks Carter Individual 7/22/2011

#10 Kirsten Peterson Rim Tours 7/20/2011

#11 Anne Clare Erickson Individual 7/20/2011


COMMENT ANALYSIS

Page 2

COMMENT

REF #

NAME/TITLE COMPANY/

ORGANIZATION

DATE RECEIVED

#12 Lisa Hathaway

Sam Lightner

Jason Kieth

Friends of Indian Creek

The Access Fund

7/22/2011

#13 Matt Hebbard, Vice

President

Rim Tours 7/22/2011

#14 Bill Settle Rim Tours 7/21/2011

#15 Jeremy Fancher, Policy

Analyst, In-House

Council

International Mountain Biking

Association

7/22/2011

#16 Sylvi White Individual 7/21/2011

#17 Anthony Quintile Flagstaff Biking Organization 7/19/2011

#18 Wendy Palmer Individual 7/20/2011

#19 Tracy Reed, Owner Chile Pepper Bike Shop 7/18/2011

#20 Gerrish Willis Individual 7/13/2011

#21 Leigh

Kuwanwisiwma,

Director

Hopi Cultural Preservation

Office

7/5/2011

#22 Mary Moran Individual 7/15/2011

#23 Sandy Freethy, Chair Grand County Trail Mix 7/14/2011

#24 Bill Love Individual 7/01/2011

#25 Jay Banta Utah Chapter, Backcountry

Hunters and Anglers

7/17/2011

#26 Ed Oak Individual 7/12/2011

#27 Darcey Brown Individual 7/13/2011

#28 Thea Nordling Individual 7/21/2011

#29 John Covey Individual 7/21/2011

#30 Tim Bateman Individual 7/21/2011

#31 Sue deVall Indvidual 7/21/2011

#32 Noah Bigwood Individual 7/21/2011

#33 Glen Griscom Individual 7/22/2011

#34 Zach Glover Individual 7/22/2011

#35 Ginny Carlson Individual 7/22/2011

#36 Karen Robinson Individual 7/22/2011

#37 Tom Dillon Individual 7/22./2011

#38 Laurel Hagen ,

Executive Director

Canyonlands Watershed

Council

7/22/2011

#39 Susie Harrington Individual 7/22/2011

#40 Ruth Dillon Individual 7/22/2011

#41 Whit Richardson Individual 7/22/2011

#42 Clif Koontz, Program

Director

Dale Parriot, Executive Director

Ride with Respect 7/22/2011

#43 Max Forgensi Individual 7/3/2011


COMMENT ANALYSIS

Page 3

Section 2. Individual Comment Analysis and Responses

Below are all of the comments made by the public on the Proposed Action. Each comment is followed

by a Forest Service response to the comment. Comments are grouped by category and summarized and

may not be exactly worded as they were in the comment letter.

Category- General Comments

Comment (Ref# 23 )

A complete and diverse non-motorized trail system is good for locals and visitors alike. It is good for

our local economy. We hope that additional new trails are added in the plan for hikers, equestrians and

include a variety of biking skill levels and interests.

Forest Service Response

The Proposed Action and Alternatives include a wide range of trails for hikers, equestrians and

bikers. The Forest Service understands the importance of developed trails to the local economy and

will take that and other concerns into consideration when preparing a decision.

Comment (Ref# 4 )

Recreational opportunities abound on the Moab Ranger District and there is enough room for wide range

of experiences-traditional foot and horse use and extreme mountain bike downhill. Both uses are not

necessarily compatible on the same trails however.


The Proposed Action and Alternatives provide for the full range of trail based recreational

opportunities and includes options for separating uses by zoning areas for specific types of trail use.

Comment (Ref# 21 )

Support the identification and avoidance of prehistoric archaeological sites, and consider the prehistoric

archaeological sites of our ancestors to be Traditional Cultural Properties.


An inventory of cultural sites and potential impacts from the Proposed Action and Alternatives will be

conducted in the Environmental Assessment for the project.

Comment (Ref# 25)

All currently unrecognized trails being suggested for formal recognition and all new trail areas being

proposed for construction should be subject to a survey of potential biological impacts and that

information provided to the interested public for review and further comment before any new

designation takes place.


COMMENT ANALYSIS

Page 4


Appropriate biological surveys have been conducted and the information will be used in the analysis

of potential effects from the Proposed Action and Alternatives. The analysis will be presented in a

Biological Assessment/Biological Evaluation and Wildlife Report which will be available to the

public, and will be utilized in the Environmental Assessment.

Comment (Ref# 25 )

Known and projected use data should be made available to the reviewing public. A little used trail has a

much different impact on both wildlife and the quality of experience that non-mechanized users have

than one that is getting heavy traffic from mountain bike users


Trail use data is collected at trail head registers. Trailhead register use numbers were used in the

analysis of the Proposed Action and Alternatives and are available for public review the EA.

Comment (Ref# 27, 28 )

I hope your plan puts preservation and restoration of US natural resources ahead of local business and

biking interests.


As a multiple use management agency the Forest Service will be considering both the impacts to

natural resources, recreation opportunities and to the local economy in the Environment Assessment.

Comment (Ref# 4)

If the Forest Service were to include language in the decision and trail maps suggesting route

designations are provisional, and should abuse occur, than the Forest will close routes accordingly, the

recreating public would be much more likely to respect route designations.


New trails will be monitored as required by Forest Service policy and unacceptable environmental

and public safety issues will be dealt with through the trails management program.

Comment (Ref#4)

Need to consider the Unified Forest Wilderness Proposal for the La Sal Mountains when making the

decisions


The Environmental Assessment will analyze potential impacts to the wilderness character of

Inventoried Roadless Areas (IRAs) and those lands included in the draft Unroaded and Undeveloped

inventory conducted for the Forest Plan Revision.


COMMENT ANALYSIS

Page 5

Comment (Ref# 5, 6, 8, 11, 12, 22, 43)

Support the proposed changes and approach


Support for the project noted

Comment (Ref#7, 19)

The Proposed Action has left out many suggestions and solutions offered since 2003 from Trail Mix and

the cycling community. (See Trail Mix Letter)


The referenced Trail Mix Letter lists 18 separate trail related proposals for the Moab/Monticello

Ranger District. Of those 18 proposals, 5 of them have already been implemented, two more are

included in the Proposed Action and portions of the other proposals will be analyzed as alternatives in

the planning process.

Comment (Ref#7)

The Forest Service has the opportunity to take the bull by the horns and create an infrastructure of trails

and hubs that will support an ever growing number of recreationalists in the La Sals.


The Forest Service does anticipate increased recreation use in the La Sals. Anticipating this increased

use and the additional management issues it may cause is a primary reason for this project.

Comment (Ref#7)

In addition to creating new trails, restrooms and parking areas, the Forest Service needs to consider the

impacts these destinations will have on the existing road system and the feasibility of sending people to

areas where, at this point, only a short trail can be enjoyed.


The Purpose and Need for the project is to create a more sustainable trail system and provide for a

variety of trail opportunities. Increased recreational use can have an impact on the existing road

system, however it would be difficult to determine those impacts at this point without knowing the

levels of use that the new trails may receive. As is standard practice all roads on the Forest System

will be monitored and maintenance will occur when needed.

Comment (Ref# 10, 13)

The approach is incomplete in addressing the different users of the trail system. The proposal recognizes

the conflicts that are occurring but rather than delve into what each user group is looking for and trying

to provide for those experiences, the proposal simply attempts to separate use in a disjointed way that

doesn’t solve the basic problem which is trying to make a trail system work that is ill suited for most of

the use that is occurring.


COMMENT ANALYSIS

Page 6


In response to public comments that the Proposed Action did not provide the differing trail users

desired experiences, Alternative 3 was created that included a wider variety of trails and experience

opportunities. The option for separating uses to deal with some of the existing and potential conflicts,

and the impacts from separating these uses will also be analyzed in Environmental Assessment.

Comment (Ref#10, 13, 29)

The La Sal trail system needs a major overhaul. Trails need to be designed to be sustainable, user

friendly and meet identified needs. Doing this would go a long way to solving our current trail

problems.


The purpose for the project is to design sustainable trail system in the La Sals that provides for a

variety of trail experiences.


If the Forest Service doesn’t meet the needs of different users of our resource, the users are going to be

motivated to create their own solutions which might take the form of more user created trails and more

negative interactions between users.


The purpose of the project is to provide for a wide variety of trail experiences while minimizing

impacts between users and impacts on other forest resources. While providing for a wide variety of

experiences, providing trails that maybe too difficult or technical for the majority of users is not the

best use of limited funding and not all types of trail experiences maybe appropriate for Forest Service

managed lands.

Comment (Ref# 10)

I would like to see the Forest Service work hand in hand with Trail Mix, MTA, and IMBA to solve

problems that present themselves and find creative solutions.


The Forest Service is dedicated to involving all stakeholders in making sustainable decisions for the

Moab/Monticello Ranger District. District recreation staff have worked closely and will continue to

work with Trail Mix, MTA and IMBA on trail management.

Comment (Ref# 31)

We need more dedicated trails for hikers and horses.



COMMENT ANALYSIS

Page 7

A variety of trails for hikers and horses will be analyzed in the Proposed Action and Alternatives.

Comment (Ref# 14)

Closing trails {to mountain bikes} should be a last resort. More and more people are coming to Moab to

bike and closing any trails will only lead to bootleg trails and will require unreasonable policing.


Sharing trails between all non-motorized users has been generally successful in the La Sals.

However, with the increase in use and the expected further increases some conflicts are beginning to

occur between users. Separating uses by zoning the trail for different types of trail use is one way of

minimizing these conflicts and will be analyzed in the Environmental Assessment.

Comment (Ref# 14)

Need to give people options in key over congested areas not criminalize specific users.


The purpose for the project is to design a sustainable trail system in the La Sals that provides for a

variety of trail experiences and options for trail users. The Forest Service views mountain biking as a

legitimate use of National Forest lands and an important part of the local economy. The Proposed

Action is an attempt to balance many different demands from recreational users as well as the needs

of other important forest resources, not to criminalize any specific user group .The Proposed Action

and alternatives are designed to give the biking community other options for enjoyable and

sustainable riding in the La Sals.

Comment (Ref# 15)

The Purpose and Need identifies visitor safety and user conflict as the primary reasons for the action,

and the action relies primarily on separation of uses to address those concerns. Separation of uses is one

way to address concerns, but where it is done with strokes that are too broad it can cut off meaningful

experiences. There are several alternatives to zoning that IMBA would like to see as alternatives. The

first is the overall design of the trail system. Secondly, individual trails or trail segments can be designed

and built to manage trail user interactions. Lastly, management regiments such as alternating use,

directional travel and other outside the box solutions can ensure quality experiences across the user

spectrum.


The Proposed Action and Alternatives use a variety of techniques in resolving user conflicts

including; zoning in a variety of areas, seasonal closures, creating “bypass” sections of trail on

heavily used trail sections and creating new trail opportunities.

Comment (Ref# 15)

When developing alternatives we suggest a two step approach, First identify experiences that users are

seeking from any given route. Second, design the trail system, individual trails, and trail segments to

accommodate those experiences.



COMMENT ANALYSIS

Page 8

Two alternatives were created in response to public comments received on the Proposed Action. A

wide variety of desired trail experiences were expressed by the public. The desired experiences were

taken into account and played a large role in the preparation of the alternatives.

Comment (Ref# 15)

Individual trails could be designed to reduce the perception of conflict. Features such as longer sight

lines and choke points to control speed should be used.


Several trails in the Proposed Action and Alternatives were designed to reduce the perception of

conflict. Longer site lines and choke points are specific features that may be incorporated into the

actual trail design.

Comment (Ref# 16)

I am disappointed and personally offended by the Proposed Action. Your plan clearly discriminates

against mountain bikers.


The Forest Service views mountain biking as a legitimate use of National Forest lands when

conducted in a sustainable manner in an appropriate location. The Forest Service also recognizes

that mountain biking associated business is an important part of the local economy. It is not the

intention of the Forest Service to discriminate against any user group. The purpose of the project is to

provide for a wide range of trail opportunities and experiences. Some users have felt that the amount

of use on some trails from bicyclists has an impact on their experience. The Proposed Action and

Alternatives are designed in part to deal with this perceived conflict while also providing for a wide

range of trail opportunities for cyclists.

Comment (Ref# 16)

Your plan claims to address the change in use, but you are doing the exact opposite. The change in use is

this: mountain bikers are now the primary user group, by a huge margin. The Proposed Action

represents us as if we barely exist.


All forms of trail use are increasing both motorized and non-motorized. The Proposed Action and

Alternatives provide a wide range of options for dealing with this increasing use and potential impacts

and conflicts from that increase.

Comment (Ref#16)

I would strongly urge the Forest Service to allow the mountain bike riders and skilled trail builders of

Moab help you decide which mountain bike trails to include in your plan because you have clearly

shown that you do not understand our needs adequately enough to create a plan that meets them.


COMMENT ANALYSIS

Page 9


Forest Service Recreation Staff have worked closely with local mountain bikers to formulate the

Proposed Action and Alternatives. Several public meetings have been advertised and held to illicit

ideas from all trail users. In response to public comments two new alternatives have also been created

and will be analyzed in the Environmental Assessment. It is also important to realize that while the

needs of recreationalists are an important part of designing the trail system there are many varied

opinions from within the recreation community as well as other resources that the Forest Service

must take into account when managing trail use.

Comment (Ref#20)

Establish a trailhead parking area at the forest boundary in Beaver Basin.


Currently the Beaver Basin area receives relatively little use and no trails exist (except the road) at

the forest boundary that would require a trailhead. A parking area could be considered in the future

if use increased.

Comment (Ref#17)

Please include an Alternative in the EA that shows all trail additions proposed in response to the

Proposed Action, and the maximum number of trails open to mountain bikes.


Alternative 3 allows all forms of non-motorized travel on all designated trails and would designate an

additional 38.5 miles of trails open to all non-motorized uses

Comment (Ref#17)

Strongly consider kiosks and signage that outline an appropriate share-use trail ethic.


Trailheads have been constructed at all major trails and include appropriate trail sharing

information. Any new kiosks will also include appropriate trail sharing information.

Comment (Ref#36)

Kiosks, additional trail markers, advertising of trails, are not desired by hikers. Trails should not be

marketed.


Any additional trail designations will be signed to Forest Service standards. Some trails will be signed

more than others depending on the Trail Class and Trail Use types.

Comment (Ref#27)

Hunting dogs above Brumley very intimidating and lots of campers in trailers stay well beyond their

time limit.


These issues are outside the scope of this project and will be handled with existing regulations


COMMENT ANALYSIS

Page 10

Comment (Ref#35)

I am opposed to any trails included in your plan which were created by users without prior authorization.


The majority of new trails being considered for addition to the trail system are new trails that are not

currently being used. A few of the proposed new trails were created by the passage of livestock or

recreation users. None of the proposed trails have been constructed by recreational users.

Comment (Ref#36, 38)

Cumulative effects of the trail system, not just the length of trails themselves should be considered. An

example is that an EA is not sufficient to assess the cumulative effects of the PBR/Burlfriends trail. See

Washington Trails Association v. US Forest Service (1996)


Cumulative effects from the trail system and from other reasonably foreseeable actions will be

analyzed in the Environmental Analysis.

Comment (Ref# 38)

We see little need for putting effort into constructing, signing or maintaining foot trails.


While hikers can travel off trail throughout the La Sals, many hikers have requested the construction

of additional foot trails to peaks and other destinations. Some areas where large amounts of hikers

are travelling off trail have begun to show signs of impact such as vegetative trampling and erosion.

The proposed new foot trails in the Proposed Action and Alternatives are designed to deal with these

areas where impacts are already occurring and need to be managed to reduce future unacceptable

impacts.

Category- Need for additional trails

Comment (Reference #1, 2, 10, 13, 17, 19)

Would like to see additional trails designated focused on shared use, connectivity, trail hubs and

efficient use of existing facilities and providing loops (many new proposals from different parties).


Alternative 3 was designed primarily around the idea of using existing infrastructure to create “trail

hubs” and connectivity.

Comment (Ref# 1, 10, 13)

Propose a Fisher Mesa Trail Hub proposed (see maps for details)

- Potential for stacked loop system in area with BLM lands - Propose the opportunity for additional trails looping off the existing trail



COMMENT ANALYSIS

Page 11

The Proposed Action and Alternative 3 would create additional trail opportunities in the Fisher Mesa

area, including stacked loop opportunities.

Comment (Ref#1, 10, 13, 19, 23, 30, 34, 37, 40)

Propose a Jimmy Keen Flat Trail Hub (see map for details)

- Area is ideal for moderate stacked loop opportunities


A Jimmy Keen Trail Hub (including stacked loops and intermediate level trails) will be analyzed in

Alternative 3

Comment (Ref# 1, 2, 9, 10, 13, 19, 23, 34, 37, 39, 40)

Proposed Warner Lake Trail Hub (see maps for details)

- Need a Enchilada by-pass trail to route bikes around the heavily used Warner Lake area

- Need to develop an easy family friendly loop in the area

- Designate a moderate trail using contours around Bald Mesa starting at Hazard County TH

- Designate a trail that parallels the Oowah Lake road to divert bike traffic off the heavily used road

- Designate the “Needle in the Haystack” Loop (not #39)

- Designate a connector hiking trail from Mountain View down into the Dry Fork

- Support Designating a trail to Horse Mountain

Forest Servie Response

Alternative 3 will analyze many of these suggested trails around the Warner Lake area.

Comment (Ref# 2, 9)

Need to open the canal trail by pass on the Whole Enchilada; it makes for a better alternative than

climbing the hill back to the lake.


Designating the Warner Lake ditch line as a trail will be analyzed in Alternative 3

Comment (Ref#1, 2, 10, 13, 19)

Proposed Geyser Pass Trail Hub (see map for details)

- Designate a loop from the Geyser Pass winter trailhead (Trail would parallel the Geyser Pass Road

link to Moonlight Meadows and return via the Boren Mesa extension)

- Designate the Round the Mountain Loop including a new Round the Mountain west. - Designate the Burro Cut-off from the Geyser Pass trailhead to the Burro Pass TH

- Support the Brumley Falls hiking trail.


Alternative 3 will analyze many of these suggested trails around the Geyser Pass area.


COMMENT ANALYSIS

Page 12

Comment (Ref#1, 2, 19, 18, 30, 34, 37, 40, 43)

Support the addition of the Moonlight to Burro (Burro Cut-off) from Geyser Pass TH to the Burro Pass

TH. This is an important connector and provides a single track, non-motorized loop.


The Burro Pass Cutoff trail will be analyzed in Alternative 3

Comment (Ref# 19, 18, 23, 30, 34, 37, 40, 41)

The single track trail adjacent to Oowah Lake Road which would connect to the Boren Mesa Trail

should be considered.


A trail connecting the Boren Mesa trail and the Oowah Lake road will be analyzed in Alternative 3

Comments (Ref #1, 10, 13, 18)

South Mountain Trail Hub proposed (see map for details)

- Support the designation of the Hells’ Canyon connector (Terraces Trail)

- Designate a “Ice Cave” trail for hiking from the South Mountain hub

- Designate a new Bear Park trail

- Support designating the PBR trail to provide connections with state lands

- Maintain the South Mountain trail as open to mechanized use

- Support the designation change of Pole and Doe Canyons as open to foot and horse only

- Support designating the Medicine Lake Loop


Alternative 3 will analyze many of these suggested trails around the South Mountain area. The

Proposed Action and Alternative 4 will analyze designation changes on the Pole and Doe Canyon

Trails.

Comments (Ref #2, 23)

Support adding the Burlfriends trail or PBR to the system, open to mechanized use.


Both of these trails will be analyzed in the Environmental Assessment and considered for designation

Comment (Ref# 1, 9, 10, 13 )

Support the Fisher Mesa Extension Trail


The trail will be analyzed in the Environmental Assessment and considered for designation


COMMENT ANALYSIS

Page 13

Comment (Ref#4, 11, 23, 28, 38)

Support adding the Laurel Highway foot and horse trail to the system



Comment (Ref#4, 11, 23, 28, 38)

Support adding the Gold Basin foot and horse trail to the system



Comment (Ref# 1, 9, 10, 13, 19, 41 )

Need more moderate (beginner and intermediate) trail riding experiences


Several moderate trails will be analyzed in the Environmental Assessment and considered for

designation.

Comment (Ref# 42, 19, 18, 17)

The USFS should continue planning for the emergence of downhill mountain biking, by constructing

one or two additional downhill routes.


Additional downhill oriented trails will be analyzed in the Environmental Assessment and considered

for designation

Comment (Ref# 1,3,7, 10, 13 )

Designate a connector hiking trail from Mountain View down into the Dry Fork


The Forest Service did consider a connecting trail in this area, but dropped it from further

consideration due to the extremely steep nature of the terrain.

Comment (Ref# 3 )

Connect the Laurel Highway and Gold Basin Trails to make a loop or perhaps the trails should not be

designated as there is not an overuse problem





COMMENT ANALYSIS

Page 14

Concerned that the creation of a new downhill trail will create more use in the area, but if needed the

Squaw Springs (exit) seems like a more appropriate place than Hells Canyon


The Squaw Springs Exit trail will be analyzed in the Environmental Assessment and considered for

designation. Prohibiting bikes on the Hells Canyon trail will also be considered in the assessment.

Comment (Ref#4, 11, 23, 28)

Support designating the Gold Knob Trail to the system




Support designating the Tuk Trail to the system



Comment (Ref#1, 2, 4, 23, 30)

Support adding the Terraces Trail to the system




Support adding the Sheepherders Trail to the system




Support adding the Medicine Lake Trail to the system



Comment (Ref#23)

Support adding the Mann’s Peak Trail to the system




COMMENT ANALYSIS

Page 15


Support adding the Upper Brumley Climbing Access trail to the system



Comment (Ref#7)

Considering the turn out to meetings and the number of bicycle specific business in town, there is a huge

need for new trails for mountain biking.


Providing a range of trail opportunities in appropriate locations is one of the purposes of the

proposal.

Comment (Ref#7)

The La Sals need trails for two main reasons, first, mountain biking in the mountains is impossible

without a trail and second it is required by law to travel on one.


Providing a range of trail opportunities for mountain biking in appropriate locations is one of the

purposes of the proposal.

Comment (Ref#7)

A Forest Service Road is not a viable replacement for a trail (for hikers or bikers) and few trails have

been constructed by and for mountain bikers. Building sustainable trails designed with the identified

needs of a biker in mind would reduce environmental impacts and social impacts.


Providing a range of trail opportunities for mountain biking in appropriate locations is one of the

purposes of the proposal.

Comment (Ref#7, 19)

If offered a similar experience to the Whole Enchilada Trail, riders would use it and it would disperse

impacts.


The “Whole Enchilada” is a very unique trail and the terrain and infrastructure for another trail like

the “Whole Enchilada” may not be available in the La Sals. There is however several additional

downhill, long distance trails that will be analyzed in the Environmental Assessment.

Comment (Ref#7)

La Sal Pass would make a good area for new loop trails for biking.



COMMENT ANALYSIS

Page 16

Several loop trails will be analyzed in the Environmental Assessment and considered for designation

in the La Sal Pass area.

Comment (Ref#7)

Need more loop trails for hiking and horseback riding


Several loop trails for hiking and horseback riding will be analyzed in the Environmental Assessment

and considered for designation

Comment (Ref#11)

Support the new hiking/horse only trails because for the most part the new trails indicated on the maps,

user trails already exist. These places are getting enough hiker traffic to warrant making them official

trails.


Almost all of the proposed foot and horse trails are in areas that are currently receiving use and the

trails would assist in managing the existing use and mitigating potential impacts.


To achieve recreational diversity, motorized singletracks should be constructed within the “roaded

natural” corridors of Geyser Pass and La Sal Pass roads.


Designating new motorized trails is outside the scope of this project. The designation change on the

existing Carpenter Basin trail is being considered as it involves an existing trail.

Comment (Ref#42)

Propose a new non-mechanized route to be constructed to connect the base of Lackey Basin with Pole

and Doe, and avoiding most of South Mountain Trail.


A connector trail from Lackey Basin to Pole and Doe Canyons will be analyzed in Alternative 3

Comment (Ref#2, 30, 34, 41)

Propose the addition of the Top Shelf trail, a connector from Geyser Pass around back side of Peale to

connect to La Sal Pass area trails.


The Top Shelf trail will be analyzed in the Environmental Assessment and considered for designation.

Comment (Ref#31)

Separate trails for bikers and hikers work well in Telluride and everyone likes it.


Separating uses will be analyzed in the Environmental Assessment.


COMMENT ANALYSIS

Page 17

Comment (Ref#2, 42, 30, 34, 37, 40, 41)

Propose a loop system near the toilet and parking area on Geyser Pass Road.


A loop trail will be analyzed in the Environmental Assessment and considered for designation at the

parking lot on the Geyser Pass Road.

Comment (Ref#23)

Propose adding the Bachelor Basin to Horse Mountain trail to the system



Comment (Ref#23)

Propose adding a loop trail from Mtn View trail to Miners pass, hiking only.


This proposal was not carried forward into the Alternatives


Propose developing a few short, “accessible” loops around destinations like Warner Lake and Pack

Creek.


Several short accessible trails will be analyzed in the Environmental Assessment.

Comment (Ref#24)

Additional trails in the forest will cause erosion, silting of streams, and reduction of forage for livestock.

New trails that allow bicycles can easily result in erosion similar to Moonlight Meadows. The new trails

for bicycle use need restricted use in high elevation areas such as the La Sal Pass, until the mud has time

to harden.


Seasonal closures on high elevation trails will be analyzed in the Environmental Assessment. All

designated trails will be constructed to Forest Service standards to mitigate any potential impacts.

Comment (Ref#17)

It is also important that the District recognize the need for additional mountain bike routes presented by

the proximity of these trails and proposed trails to one of the most popular mountain biking destinations

in the WORLD.


The Forest Service recognizes the importance of tourism and biking to the local economy and the

status of Moab to the cycling world. The Forest Service is also mandated to manage wildlife, soil,


COMMENT ANALYSIS

Page 18

watersheds, cultural resources, and many other forest resources and must balance recreational needs

with other these other resources.

Comment (Ref #23)

Propose the following trails to be added as alternatives with the following designations

Boren Mesa: Change the designation from a two-track to a single track (mechanized)

Base of Mellenthin (foot and horse)

Laurel Highway to Horse Creek Branch Loop (foot and horse)

Brumley Creek: Change the designation from two-track to a single track (mechanized)

Gold Basin Via Pre-Laurel (Northwoods Loop) (foot and horse)

La Sal creek Crossing from So. Mnt Loop to RD 4727 (mechanized)

Beaver Basin to Mann’s Peak (foot)

Adobe Mesa-Fisher Mesa Rim (mechanized)

Brumley Ridge Trail (mechanized)

Bald-Hazzard Loop (mechanized)

Single track parallel to Oowah Lake Road (mechanized)

Boren Mesa Loop connector trail (mechanized)

Squaw Bypass trail (mechanized)

Dorry trail (mechanized)

Terraces trail to Hells canyon trail (mechanized)…new alignment for #029

Carpenter Basin connection to Kane Springs Canyon (mechanized)


Many of these trails will be analyzed in Alternative 3, others were not included. Converting Forest

Service roads to non- motorized trails is outside of the scope of this project, but may be looked at

during the motorized travel planning in the future.

Category- Concern over Potential New Trails

Comment (Ref# 4 )

We hope the Forest is coordinating with BLM on the undesirable trail proposals starting on Adobe and

Fisher Mesas.


The Forest Service has coordinated their proposal with local BLM offices.

Comment (Ref# 28)

Please keep the irrigation ditch route from Warner Lake toward Burro Pass closed to bicycles. There is

no room for bikes and pedestrians to pass each other along this narrow trail.



COMMENT ANALYSIS

Page 19

The trail and its potential impacts will be analyzed in the Environmental Assessment and considered

for designation.

Comment (Ref# 28)

The Warner Lake area would be appropriate terrain for some new cross-country ski loops, but how

would you access the area safely?


Winter trails were considered in the original proposal, but were dropped from further consideration

due to issues that need to be resolved (such as plowing access roads etc...)Winter trails will be

evaluated in future winter recreation management planning.

Comment (Ref#25)

Many of the trails proposed as well as some of the trails proposed for construction, appear to be in

Inventoried Roadless Areas (IRA’s). Establishing trails that are to be used by mountain bikers should be

very thoroughly considered…b/c of it would no longer meet the minimum criteria for a wilderness area.


Impacts to roadless and wilderness characteristics will be considered in the Environmental

Assessment. Designating a non-motorized trail open to bikes would not exclude the area from being

considered for wilderness designation in the future.


Great caution should be taken in designating the Fisher Mesa Extension and Spur trails as it is rewarding

lawlessness. The Fisher Mesa Extension may make sense as part of a longer bike ride but future trail

segments must be planned and built using public process. The Fisher Mesa trail should be designated

provisionally. If riders cannot stay on trail or build new illegal trails then the trail should be closed and

removed from the system.


The Fisher Mesa Trail extensions will be analyzed in the Environmental Assessment and considered

for designation. Closing trails is always a possibility when unacceptable impacts or illegal use is

occurring.

Comment (Ref#9)

The Proposed Action lists the Fisher Mesa Extension as a “New Mechanized” trail. How can it be new if

it was built and is being used for non-motorized uses? The trail should remain a single-track and not be

changed to a “mechanized” trail.


Currently only the southern portion of the Fisher Mesa single-track is an authorized system trail.

When the Fisher Mesa single-track was originally added to the trail system the Fisher Mesa extension

was not authorized. The Forest Service is now proposing to add the Fisher Mesa Extension to the


COMMENT ANALYSIS

Page 20

system to be consistent with the designation on adjacent BLM lands, thus it is a new trail. The trail

will remain single-track. In Forest Service trail terminology “Mechanized” refers to bicycles.

Comment (Ref#9)

The Proposed Action includes a new mechanized trail leaving the Squaw Springs trail. This seems odd

as the mechanize users will be encouraged to use the non-motorized Squaw Springs trail.


In Forest Service trail terminology “Mechanized” refers to bicycles, so the proposed new trail would

be open to the same forms of non-motorized transportation as the existing Squaw Springs trail

currently is.

Comment (Ref#4)

Support not adding the Adobe Mesa Trail to the system


Comment noted.

Comment (Ref#4)

Support not adding the Fisher Falls Trail to the system


Comment noted. The trail was considered but not carried forward into the analysis due to issues with

private property and the extremely steep terrain in the area.

Comment (Ref#4)

Support not adding the Jimmy Keen Flat Loop Trails to the system


Comment noted. The trail will be analyzed in the Environmental Assessment and considered for

designation

Comment (Ref#4)

Support not adding the Bald Mesa Hazard Loop to the system


Comment noted. The trail will be analyzed in the Environmental Assessment and considered for

designation

Comment (Ref#4)

Support not adding the Mountain Valley (Mountain View?) Loop to the system


Comment noted.


COMMENT ANALYSIS

Page 21

Comment (Ref#4)

No need for two routes to the top of Manns Peak, choose the one with the least resource damage and

choose it


Only one trail would be designated to Manns Peak

Comment (Ref#4)

Support not adding the Boren to Schumann Loop to the system


Comment noted. Potential impacts from this proposed trail will be analyzed in the Environmental

Assessment.

Comment (Ref#4)

Support not adding the Boren to Loop Road Trail to the system



Assessment.

Comment (Ref#4)

Support not adding the Geyser Pass Road Single-track Trail to the system



Assessment.

Comment (Ref#4)

Support not adding the Top Shelf and Round the Mountain Trails to the system


Comment noted. Potential impacts from these proposed trails will be analyzed in the Environmental

Assessment.

Comment (Ref#4)

Support not adding the Brumley Ridge Trail to the system



Assessment.


COMMENT ANALYSIS

Page 22

Comment (Ref#39)

Support not adding the Laurel Ridge Trail to the system



Assessment.

Comment (Ref#4, 35)

Support not adding the Megladon Trail to the system


Comment noted. The Megladon trail was considered but not carried forward into the analysis due to

issues with rare plants, private property, and BLM WSA issues.

Comment (Ref#4, 38)

Do not support the designation of a new downhill oriented trail in the Squaw Springs/Dorry Canyon

area. Two heavily used downhill trails already exist in the La Sals and a third trail is unnecessary. The

downhill/adrenaline experience of these trails makes them single use trails.


Several new downhill oriented trails will be analyzed in the Environmental Assessment and

considered for designation. Impacts to other users from those types of trails will be considered.

Comment (Ref#24)

The Forest Service needs to look at the cumulative effects of creating small connecting trails that open a

much longer loop trail. A small connecting trail may open a very large area of the forest to increased

usage that will be detrimental to wildlife and other users several miles distance.


Potential impacts from the trail system as a whole will be considered in the Environmental

Assessment.


The Forest Service should not consider any new downhill trails that can be used for commercial bike

trips. The problems with the Burro Pass and Moonlight Meadows Trails should not be duplicated in

another section of the forest because of dislocation of wildlife, erosion of hillsides and mud holes in wet

areas, safety issues with horses and all other problems associated with high use commercial bike trails

should not be allowed in the few areas still available to wildlife and other users in the forest.


Restrictions on commercial use in portions of the La Sals will be analyzed in the Environmental

Assessment.

Comment (Ref#4, 24, 36, 38)

Support not adding the Peale Blue Ribbon Trail or Burl Friend’s Trail to the system


COMMENT ANALYSIS

Page 23



Assessment.

Comment (Ref#4, 38)

Support not adding the Terraces Connection Trail to the system



Assessment.

Comment (Ref#4)

Do not support designating the Sheepherders and Burlfriends Trails to the system. These trails tie in

with trails on SITLA lands that did not go through a full public process and designating these trail could

causes a significant increase in mountain bike use in the area which would necessitate a thorough

cumulative effects analysis of mountain biking on the Moab District.



Assessment.


Do not support adding the Medicine Lake/South Mountain Trail to the system



Assessment.

Comment (Ref#4)

Support not adding the South Mountain to FR 4727 Trail to the system



Assessment.

Comment (Ref#4)

Support not adding the Carpenter Basin to Kane Springs Trail to the system



Assessment.

Comment (Ref#6)

Do not support adding any new trails as it is not in the best interest of the forest and wildlife.


COMMENT ANALYSIS

Page 24


The Forest Service manages multiple uses including both recreation and wildlife habitat. Trails and

wildlife are not necessarily mutually exclusive resources. Trails in appropriate locations and built to

Forest Service standards can provide sustainable recreation opportunities while not impacting

wildlife populations.


Do not support encouraging horses using the high alpine, such as on the Tuk Trail.


Horses are not currently prohibited from the alpine areas in the La Sals. The Tuk trail is not expected

to receive heavy equestrian use due to its steep nature. If horse use in the alpine zone of the La Sals

results in unacceptable impacts in the future their use could be restricted.

Comment (Ref# 10)

Why develop trails (i.e. Medicine Lake) that would enhance trail opportunities and then close the

existing trail to mountain bike use.


The proposed Medicine Lake trail would be open to mountain bikes. Under the Proposed Action the

South Mountain Trail above the junction with the Medicine Lake trail would be closed to mountain

bikes, but a loop with the bottom portion of the South Mountain trail would still be possible. Under

Alternative 3 all of the South Mountain trail system would remain open to mountain biking use.

Comment (Ref# 36)

Do not support construction of any trails in the mountains that would parallel existing roads. Trails near

the road further isolate wildlife corridors and create unnecessary disturbance to the forest.


Potential impacts from the Geyser Pass single-track proposed trail will be analyzed in the

Environmental Assessment.

The Geyser Pass single-track (which would parallel the Geyser Pass Road) was included in

Alternative 3 and was analyzed in the EA prepared for the project.

The Forest Service understands that the Geyser Pass Road is receiving increasing use and that a

change in management will be necessary to make the road safer and more enjoyable as recreational

use in the area continues to increase. At this time the Forest Service feels that a broader overall

approach to the management of the road corridor is necessary and that the Moab Non-Motorized

Trail Plan is not the appropriate process for that decision.

Category-Trail Designation changes

Comment (Ref# 3, 4)


COMMENT ANALYSIS

Page 25

Hell Canyon Trail should be designated foot or horse only (REF #24) or redesigned to be sustainable for

bike use.


Both of these options and their potential impacts will be analyzed in the Environmental Assessment.

Comment (Ref# 3, 4, 6, 8, 11, 22, 24, 28, 35, 38)

Support changing the Doe, Pole and South Mountain Trails to foot and horse only


Potential impacts from these designation changes will be analyzed in the Environmental Assessment.

Comment (Ref# 10)

Support changing the designation of Doe and Pole Canyons to foot and horse only


Potential impacts from this proposed trail will be analyzed in the Environmental Assessment.


Support the designation changes on Warner/Beaver Basin, Manns Peak/Deep Creek Trails to foot and

horse only


Potential impacts from these designation changes will be analyzed in the Environmental Assessment

Comment (Ref#39)

Support the designation changes on the Dry Fork section of the Warner/Beaver Basin trail to foot and

horse only




Proposal to change designation of South Mountain, Doe, Pole and Dry Fork trail to foot and horse only

will result in further crowding on the front side trails


These trails were proposed for a designation change to foot and horse only because they currently

receive such low use by bikers. Changing the designation of these trails is not expected to displace any

user groups.

Comment (Ref#7, 10, 14, 16, 17, 19, 23, 34, 37, 40, 42)


COMMENT ANALYSIS

Page 26

Do not support closing the South Mountain Trail to bikes, they are lightly used trails and can

accommodate all the user groups. Commenter #42 specifically states keeping South Mountain Trail

open to mountain bikes to preserve options for bicycle loops.


These trails were proposed for a designation change to foot and horse only because they currently

receive such low use by bikers. Changing the designation of these trails is not expected to displace any

user groups. The designation change was proposed to provide an area for those wanting a trail

experience away from the heavy bike use in other areas of the La Sals.

Comment (Ref# 3)

Need to change the Pack Creek Trail to foot and horse only.


This designation change is not included in the Proposed Action or Alternatives as this trail is part of

the Trans La Sal trail that is open to all non-motorized uses and changing the designation would not

provide connectivity for bikes using the Trans-La Sal.


If the Carpenter Basin Trail is to be opened to motorcycles, then Lackey Basin road should be closed

lower down


Motorized route closures are outside of the scope of this project.


Do not support not changing the designation of the Carpenter Basin Trail to open to motorcycles.

Designation change could for example: disrupt wildlife, open territory to illegal use and would cause

conflicts with one of the only trails that horseback riders can use that is not in conflict with mechanized

and motorized use.



Comment (Ref#8, #42, 43)

The designation change on the Carpenter Basin Trail seems reasonable with the seasonal limitations




Creating a new two wheeled motorcycle trail (Carpenter Basin Trail) causes some concern. Its

proximity to motorized areas, such as BFE, is bound to have enforcement and damage problems.


COMMENT ANALYSIS

Page 27



Comment (Ref# 1,4, 10, 39)

Propose changing the designation of the Tran-La Sal north of Warner Lake as open to foot and horse

only



Comment (Ref# 39 )

Propose changing the entire trail system south of the La Sal Pass Road to be designated foot and horse

only because it will be easier to manage, maintain and for the preservation of wildlife that live there.


Most of the area would be open to foot and horse only under Alternative 4. Potential impacts from

these designation changes will be analyzed in the Environmental Assessment

Comment (Ref#4, 24, 35, 43)

Support changing the designation on the Mountain View Trail.




Bikes are losing more trail access than they are gaining. It is disheartening to see that the proposal aims

to change the designation of 13.8 miles of system trails “from open to all non-motorized uses” to “open

to foot and horse only”, when the biking industry brings in so much money into the local community

when compared to other non-motorized uses. This does not seem to make sense considering the growth

of the biking community and the fact that hikers and horses can travel off trail…for a net loss of 10.4

miles of trails to bicycles


The amount of trails open to bicycles would vary among the alternatives. Ranging from 27.4 miles of

trails open to bicycles in Alternative 4, to 102 miles open to bicycles in Alternative 3. The Forest

Service understands the importance of biking to the local economy and manages mountain bike use

as a legitimate recreation use on the forest there are many other forest resources that also must be

considered when managing the forest.

Comment (Ref# 14)


COMMENT ANALYSIS

Page 28

Do not change the designation on the Miners Basin trail to foot and horse only.


Potential impacts from this designation change will be analyzed in the Environmental Assessment.

Under Alternative 3 the designation change would not occur.

Comment (Ref#26)

We (in Colorado) have been able to minimize access limitations to trails outside of wilderness areas. I

don’t see why that can’t be achieved here with some education and mutual respect.


A variety of proposals are being analyzed in the Environmental Assessment, including not changing

the designation of any trails to foot and horse only.

Comment (Ref#39)

Proposed changing the Dorrey and Brumley road system to mechanized use and eliminate the little

motorized use it receives.


Motorized route closures are outside of the scope of this project.

Category- Existing Trail System


Existing trail system is disjointed and does not connect well


Most of the trails on the existing system were not constructed with recreation opportunities in mind

but were rather designed to move livestock to different pastures or access mining claims, etc... The

Forest Service trail proposal recognizes this and attempts to make a more connected trail system for

recreational users.

Comment (Ref# 2, 9, 13 )

Need more bike trails that are able to be used as up-hill trails in the 3% to 6% grade range and

contouring. Need to reroute-existing trails to make them more up-hill friendly.


Any new designated trails would be constructed to Forest Service standards. Sections of trail that

currently do not meet these standards and need to be rerouted will also be identified.

Comment (Ref# 3)


COMMENT ANALYSIS

Page 29

Need to retain the opportunity to use trails that don’t feel like well-trodden paths. I hope that experience

can be retained, even while the growing demands of different users are addressed. It appears that the

proposed plan would go along ways in accomplishing that.


The Proposed Action and Alternatives would provide for a full range of trail related opportunities

including primitive type trails.


With an increase in activity in the La Sal’s, there has been an increase in the number of mountain bikers

exploring the existing trail system and improvements and additional trails are needed to meet the

growing number of visitors to enhance their recreation experience.


The Proposed Action and Alternative 3 would provide for improvements and additional trails.

Comment (Ref#17)

Increasing use may create need for more frequent maintenance intervals on existing trail system.


The ability for the Forest Service to maintain trails to standard is a consideration when designating

new trails. Decreasing budgets and increasing use on the trail system will require that volunteers

provide a larger part in maintaining forest trails.

Comment (Ref#17)

The current trail system is inadequate in addressing the need for recreational opportunity


Providing an adequate, useable and sustainable trail system is part of the Purpose and Need for this

project.

Comment (Ref#4)

Unsure if NEPA analysis has occurred on the “Whole Enchilada” trail and if the Burro Pass trail really

provides a desired experience for most mountain bikers.


A NEPA analysis has been completed on all new sections of trail that have been designated in the

past. The entire trail system and all new proposed trails, designations, and restrictions will be

evaluated in the Environmental Assessment for the project. The Burro Pass trail is a difficult trail,

but judging by the amount of use on the trail many mountain bikers are seeking that experience.

Comment (Ref# 4)


COMMENT ANALYSIS

Page 30

Concerned about resource damage occurring along the Moonlight Meadows Trail. If the trail is to

remain open to mechanized use then it needs to be hardened and re-built.


Maintenance on the Moonlight Meadows trail occurs regularly. Several sections of the trail do need

additional work to elevate the tread out of wet areas. This work is scheduled to occur over the next

several years.

Comment (Ref#24)

The Moonlight Meadows Trail needs to be closed until the trail is permanently hardened to withstand

heavy commercial use.


Maintenance on the Moonlight Meadows trail occurs regularly. Several sections of the trail do need

additional work to elevate the tread out of wet areas. This work is scheduled to occur over the next

several years. The level of impact associated with the trail currently does not require that the trail be

closed to commercial use.


The Moonlight Meadows Trail has also suffered increased trail damage and erosion from a large

increase in bicycle use.


Maintenance on the Moonlight Meadows trail occurs regularly. In 2010 a series of turnpikes were

constructed, in 2011 and 2012 additional drainage features were constructed and several small

reroutes occurred. These actions reduced impacts associated with the trail. Several sections of the

trail do need additional work to elevate the tread out of wet areas. This work is scheduled to occur

over the next several years.

Comment (Ref#41)

The Moonlight Meadows Trail is overwhelmed with cow shit and flies, it is not only unridable but I

would not even hike it.


The Forest Service manages lands for multiple uses, including livestock grazing. The original trail in

the area was used to move cattle into the upper meadows of Geyser Pass and it continues to be an

important corridor for managing livestock use in the Geyser Pass area. Changing grazing practices is

outside the scope of this project.

Comment (Ref#9, 17, 23, 29)

The Forest Service should recognize that most of the non-motorized trails on the mountains which have

mountain bike use were not designed for mountain biking, Trails need to be redesigned and rebuilt for

mountain bikes with appropriate grades and switchbacks, for non-destructive recreational access.



COMMENT ANALYSIS

Page 31

The Purpose and Need in the Scoping Letter specifically stated that “Most of the existing authorized

non-motorized trail system in the La Sal Mountains was created for uses such as accessing mining

areas or moving livestock across the range, while these trails now provide opportunities for

recreationists to enjoy the forest most of them were not created with recreational opportunities in

mind.”

The Forest Service has and will continue to look at areas where the existing system trails do not meet

standards for their designed uses and will make appropriate changes. It is anticipated that known

areas that are not currently meeting Forest Service trail standards will also be identified in the

decision document for this project.

Category – Trail Conflicts

Comment (Ref# 7, #17, 23)

It seems that Burro Pass is currently one of the biggest issues of conflict, but the proposal does not

address the issue. Alternatives should be considered that would alleviate the conflict such as a new trail

from Moonlight Meadows to Warner Lake (the Needle Trail), a parallel trail and/or a bypass around

Warner Lake. The Canal Trail seems an obvious solution.


Several ways methods for alleviating perceived conflict on the Burro Pass trail will be analyzed in the

Environmental Assessment including, creating area open to foot and horse only, designating the

Needle Trail, constructing several bypass trails and designating the canal trail.

Comment (Ref# 20)

To reduce user conflicts with downhill mountain bike riding you should consider limiting the use by

mountain bikes to even or odd days. If this is not feasible, limit commercial shuttle service to the trail to

even or odd days.


Enforcing an “even or odd” day schedule has been shown to be effective in other Forest Service

managed areas, but it requires a significant amount of enforcement and staff time to implement. The

current level of staffing on the Moab/Monticello Ranger District would not allow for this to be

effectively implemented. Commercial shuttle use is currently limited to a certain number of user days

for the year but not to the days that they can operate. Methods for regulating commercial use could be

looked at in the permittees operating plans.

Comment (Ref# 10)

It is not appropriate to take user conflicts happening on Burro Pass and apply that to every trail on the

mountain.


The Forest Service recognizes that the conflicts occurring along the Burro Pass trail is not

necessarily representative of all trails on the District. Proposing to change the designation of some

trails to open to foot and horse only (such as the South Mountain Trail) was not due to conflict on the


COMMENT ANALYSIS

Page 32

particular trail but an attempt to create areas on the District where foot and horse users could go and

expect to avoid the type of conflicts occurring on some other shared trails.

Comment (Ref# 9)

I believe that the grazing and heavy non-motorized recreation use in the central portion of the La Sals is

incompatible. The presence of cattle creates a safety issue along the trails. Cattle also create undesirable

conditions by fouling the trails with fecal matter. More visitors would use the mountain trails if they

were not impacted by cattle. I suggest removing grazing from the area to minimize conflict and negative

impacts.


Restricting grazing use is outside the scope of the project.


Cows and horses are doing more damage to trails then bikes but the restrictions are being put on

mountain biking.


The Forest Service understands that all uses and users have impacts. The Purpose and Need for this

project includes providing appropriate and sustainable opportunities for all trail users. Much of the

focus of this project is on managing mountain bike use because that use is the dominant use of the

trails on the La Sals.

Comment (Ref# 20)

The change designations on 13.8 miles of trail will reduce user conflicts.


The impacts from these designation changes will be analyzed in the Environmental Assessment.

Comment (Ref# 19)

More users on trails can lead to an increase in the numbers of encounters and potential for user conflict

can occur.


A variety of designations are being proposed and analyzed that are designed to mitigate trail conflicts.

Comment (Ref# 17)

Increasing use supersedes the current trail system’s carrying capacity for user demand and addressing

user conflict.


A variety of designations are being proposed and analyzed that are designed to mitigate trail conflicts.

Comment (Ref# 24, 27, 28, 31)

The Burro Pass Trail down the Wet Fork of Mill Creek to Warner Lake is now too dangerous (unusable)

for horses because bikers come downhill at excessive speeds, jumps, trail condition, etc.


COMMENT ANALYSIS

Page 33


Several methods of alleviating perceived conflict on the Burro Pass trail will be analyzed in the

Environmental Assessment including, creating areas open to foot and horse only and designating

bypass trails in the area.

Category- Seasonal Closures

Comment (Ref# 3,4, 18, 35, 36, 38, 39)

Support the proposed seasonal closure of Moonlight Meadows and Burro Pass Trails. Perhaps opening

should be based on a site inspection instead of a fixed date, such as “July 1 or later, depending on

conditions”.


The conditional closure approach is being analyzed under Alternative 3

Comment (Ref# 16, 17, 19 )

The proposed seasonal closure on Moonlight Meadows and Burro Pass trails is unfair; if you close trails,

close them to all users, not just mountain bikers. Opening should be based on site inspection and not a

static annual date.

Forest Service Responses

The proposed seasonal closure is not an attempt to target mountain bikers, the proposed closure is

based on use numbers more than on activity type. Closing the trail seasonally to bikes would be a way

of reducing the level of use during the time when the trail was most susceptible to damage. The

conditional closure approach is being analyzed under Alternative 3

Comment (Ref# 20, 24, 28)

A seasonal closure for bicycles until July 1 or later for the Burro Pass and Moonlight Meadows trail

makes sense to protect resources.


This action will be analyzed in the Proposed Action and Alternative 4

Category- Trail Closures

Comment (Ref# 24 )


COMMENT ANALYSIS

Page 34

The Fisher Mesa Trail needs to be signed and closed immediately. The Fisher Mesa Trail is rewarding

illegal trail builders in the Forest.


A portion of the Fisher Mesa underwent NEPA analysis and has been open to bikes for several years

now. The extension portion that is now being proposed has not been constructed but as been ridden in

the past by bikers and walked by hikers to connect with trails on BLM lands. The trail has been

signed closed in the past. Potential impacts from designating the Fisher Mesa extension will be

analyzed in the Environmental Assessment.

Comment (Ref# 3, 4, 20, 24, 38 )

Support closing the Deep Creek Trail


Proposal will be analyzed in the Environmental Assessment.

Comment (Ref# 23 )

Do not support closing the Deep Creek Trail


Proposal will be analyzed in the Environmental Assessment under the No Action.

Comment (Ref# 24 )

The Lackey Basin road is used mainly by hunters. The FS is closing the switchbacks in the upper basin

to motorized vehicles. The switch backs needs to be hiking and horses only. This would be in addition

to the rest of the South Mountain changes for Pole and Doe Canyons. The bikes could climb the

switchbacks.


The upper switch backs on the Lackey Basin road were closed in 1991. Designating the South

Mountain trails including Pole and Doe Canyon trails as open to foot and horse only will be analyzed

in the Environmental Assessment.

Comment (Ref#4)

It was suggested that the northern end of the Bachelor Basin Trail be closed due to issues with the

private property and we supported the removal of the trail from the system. The NEPA document should

propose removal of all or part of the trail and downgrading the open portion to foot and horse travel only

to protect wilderness characteristics. The NEPA document needs to address why the change is not

considered in the Proposed Action.



COMMENT ANALYSIS

Page 35

The northern section of the trail (the portion that crosses private property) would be closed and the

rest of the trail would be open to foot and horse only under Alternative 4.


Before closing the Deep Creek Trail an effort should be made to get a right of way across the portion

private land to keep the trail in its’ entirety.


The portion of the trail being proposed for closure does not cross private property it actually ends at

the boundary of private property and Forest Service lands. The trail receives very little use and is not

a deemed critical portion of the trail system. Hikers and equestrians can still access the area but the

trail will not be maintained if it is taken off the system.

Category- Unauthorized Trails

Comment (Ref# 4 )

Pleased to see the Forest is not considering adding many truly absurd trails to the system such as Adobe

Mesa, Fisher Falls, Top Shelf, Round the Mountain and Megladon.


The Forest Service has received many different opinions concerning the Proposed Action. After going

through the public comments the Top Shelf trail and other trails that were requested were used to

create Alternative 3, which will be analyzed in the Environmental Assessment.

Comment (Ref# 4 )

Interested in helping with hardening closures and monitoring for unauthorized uses occurring


The Forest Service conducts numerous volunteer trail projects throughout the summer season and is

always looking for help.

Comment (Ref #4, 36)

Concern that user created routes are under consideration for potential designation. User created routes

were not constructed with the authorization of the FS and without consideration of resource protection.

It is not appropriate to designate user created routes unless they are demonstrated to be benign and

absolutely necessary to achieve desired conditions. Designating user created routes rewards unethical

and in some cases criminal behavior, and should be avoided whenever possible.



COMMENT ANALYSIS

Page 36

The majority of the “user created” routes are not routes that have been constructed but routes that

have been created simply by the passage of users (hikers, equestrians and bikers), or they are routes

where recreational users are following existing trails created by livestock operators, game trails, or

old reclaimed roads. All potential impacts from new trail designations will be analyzed in the

Environmental Assessment.

Comment (Ref #6,22, 35)

Support closing and rehabilitating user created trails.


Support noted

Category- Commercial Use

Comment (Ref# 4)

Geyser Pass has become heavily used mountain bike concentration area. Commercial use is heavy in the

summer. We are concerned that La Sal Pass could be turned into another highly concentrated mountain

bike commercial use area. We urge the Forest Service to take action to limit or restrict commercial use

in the La Sal Pass Area.


Prohibiting commercial shuttle services in the La Sal Pass area will be analyzed in the Proposed

Action and Alternative #4.

Comment (Ref# 3, 4, 8, 11, 22, 24, 35, 38, 39)

Support restricting commercial shuttle services in the (entire) La Sal Pass area


Restricting commercial shuttle service will be analyzed in the Proposed Action and Alternative 4


Support restricting commercial shuttle services in the Geyser Pass area…examples includes restricting

bike use on holidays and weekends or bike-free days.


Managing commercial services in Geyser Pass will be dealt with in the Operating Plans and through

the administration of Outfitter and Guide permits.

Comment (Ref#24, 28, 29, 36)

The forest is too small to be dominated by large commercial groups. The forest is for many users and

the use should not damage the forest resources.



COMMENT ANALYSIS

Page 37

The purpose of the project is to provide for a wide range of trail opportunities across the La Sal

Mountains. Currently some trails on the La Sals see relatively heavy commercial use and other areas

see almost no commercial use.


The economic benefit of any particular interest group should not be the driving force behind planning

how our public lands are used.


Providing economic opportunities to local economies is an important part of forest management, but

this must be balanced with the other multiple uses that the Forest Service is mandated to manage.

Comment (Ref#3 )

Please analyze carrying capacity of the trails and limit bike shuttles to levels that trails can withstand.


Managing commercial services in Geyser Pass will be dealt with in the Operating Plans and through

the administration of Outfitter and Guide permits.


Forest Service should consider the monetary importance of the mountain bikers to every economic

corner in Moab including lodging, retail establishments, restaurants, real estate, construction and all

associated business and organizations including government agencies.


Providing economic opportunities to local economies is an important part of forest management, but

this must be balanced with the other multiple uses that the Forest Service is mandated to manage.

Comment (Ref#7)

There are no other rides in the mountain to shuttle to other than the Whole Enchilada. In considering

trails for the next five years it is important to consider the user groups and which way they are trending.

Downhill oriented riding is growing. If you limit shuttle companies private groups will still flock to the

Whole Enchilada and the infrastructure to deal with private vehicles is not in place.


Authorized shuttle companies are currently permitted to shuttle to other areas in the La Sals. Limiting

shuttle companies operating on the Whole Enchilada is not part of this project.

Comment (Ref#18)

The Forest Service should not limit shuttle business either because of increased traffic, more damage,

waste of fuel, covering plants in dust.


Prohibiting commercial shuttle services in the La Sal Pass area will be analyzed in the Proposed

Action and Alternative #4. Currently authorized shuttle companies will continue to be managed

through their Operating Plans and permits.


COMMENT ANALYSIS

Page 38

Comment (Ref#7, 10, 16, 19, 23, 30, 34, 37, 40)

Do not support closing La Sal Pass to commercial shuttles. The new proposed trails in the area, which

largely include ways to travel back to Moab on downhill style trails, will not be accessible to most users

without commercial shuttle service. Prohibiting shuttles will exclude users and will create a problem

with crowding from private vehicles being driven to the trailhead.


Commercial shuttle companies are a legitimate use of Forest Service lands and can provide an

important opportunity for many users. Geyser Pass is heavily used by commercial shuttles; the Forest

Service has received comments and complaints about the level of commercial use in the area. The

proposed prohibition on commercial shuttles in one portion of the District is an attempt to balance

uses between users who would like to use commercial services to access recreational opportunities

and don’t mind using the heavily used trails that are accessed by shuttles and those users that would

rather experience the forest in a less commercialized manner with less trail encounters.

Most trails in the La Sal Pass area are designed to be loop type trails. Cyclists can also drop off to the

west of the pass on roads or trails into the Pack Creek Area, however this leaves bikers approximately

18 miles (most of which is along Highway 191) to get back to Moab. Due to the long distances back to

Moab it is assumed that the downhill oriented trails would be used by people running their own

shuttles and leaving a vehicle in the Pack Creek Area, unlike the Whole Enchilada trail which lends

itself to shuttle companies dropping riders off at Geyser Pass and having them ride most of the way

back to Moab on a trail.

Category-Mill Creek Climbing


Any infrastructure should be designed to be invisible and not signed at their entrances (38). An

alternative to a parking lot would be to route the trail from the turnouts north of the bridge.


A parking area was constructed in 2012 as part of the La Sal Loop road project. Any trails built into

the area for climbing access would not be signed at their entrance to promote increased use.


Need to place signs to slow traffic in the Mill Creek Area.


This is action is outside of the scope of this project but can be looked at if congestion or dangerous

situations continue along the road.



COMMENT ANALYSIS

Page 39

Request that the existing trails between climbs be designated and maintained


Designating climbing access trails will be analyzed in the Environmental Assessment

Comment (Ref# 33)

Request that access will still be open to these areas during ground work (Mill Creek)


Access would remain open during implementation of the project.


Support the proposed changes in the Mill Creek area, the installation of a new parking area which

hopefully will have a toilet to protect the canyon.


Support noted

Comment (Ref# 32)

Support that the existing trail (to upper Mill Creek), user created, be left open and just upgraded as part

of the makeover. It is important for numerous users and for high angle evacuation.


This action is being analyzed in the Environmental Assessment

Category- NEPA /Planning Process


Concerned that a continuing piecemeal approach is not adequately considering the cumulative effects of

recreation in the La Sals. We would like to see the Forest take a hard look at the whole trail system

considering cumulative effects, and guide and shuttle use combined with resource and cultural and

historic concerns.


Several trails have been added to the system in the past and numerous trail proposals have been

received in an attempt to look at the entire trail system in the La Sals and to consider potential

cumulative impacts the Forest Service is looking at the entire Moab portion of the District for this

project. Potential impacts to cultural and historic resources will be included in the analysis.

Restrictions on commercial shuttle service at La Sal Pass is being considered in the Proposed Action

and Alternative # 4.


COMMENT ANALYSIS

Page 40

Comment (Ref# 4)

Concerned that the mountain may be dominated by a single use


The purpose of the project is to provide a wide range of trail experiences across the La Sals.

Comment (Ref#4)

The NEPA document should include data on ;

- Known location of unauthorized trails

- Estimated annual number of enforcement actions

- Annual number and types of vandalism

- Current budget and staffing for travel enforcement


The NEPA document will include relevant information for managing the trail system in the La Sals.

Comment (Ref#4)

We are providing a complete NEPA alternative called the Sustainable Multiple Use Alternative (SMU

Alternative), which we believe should be fully analyzed.


Comments from all interested publics were used to create the alternatives

Comment (Ref#4, 38)

Recommend that the Forest double check the Proposed Action and alternatives to ensure consistency

with the Forest Plan, Visual Quality Objectives, Management Area Prescriptions, and other management

direction.


A complete Forest Plan consistency check will be part of the Environmental Document.

Comment (Ref#4)

We urge the Forest Service to engage in a comprehensive Forest wide Travel Management Planning

process to adequately capture all forest uses, the recreational desires of all communities, resource

management and cultural resources and wilderness character protection.


This project is specific to the non-motorized trail system. Travel management for motorized uses will

occur at a later date. Other resources named will be planned for in the Forest Plan revision process.

Comment (Ref# 7)

I believe the Forest Service has continually encouraged input from user groups but then doesn’t consider

the well-researched requests in the final decision making.



COMMENT ANALYSIS

Page 41

All substantive public comments have been used to create a full range of alternatives.

Comment (Ref# 15)

Fully supports the development of system wide trail plans


Support noted

Comment (Ref# 17)

Consider reviewing these alignments to allow the corridor to more closely follow the contour of the

landscape (instead of the fall line).


Existing trails that are not meeting Forest Service standards and that need to be rerouted will be

identified as part of the Environmental Document and Decision.

Comment (Ref# 17)

Please include designations for Trail Classifications, (1-5), and other specific guidelines and standards

for construction and maintenance of these trails in the Draft EA.


Guidelines and standards for construction will be included in the Decision

Comment (Ref# 17)

Please be sure that your “No Action” Alternative in the EA reflects user created trails that currently exist

on the ground.


The “No Action” will show those trails that are part of the existing designated system.

Comments were compiled by Brian Murdock from letters, emails and phone calls received from the

public during the comment and review periods. Comments and issues raised in the comments were

considered, used to adjust design features and design alternatives as appropriate, and responses prepared

utilizing information provided by Interdisciplinary Team members and specialists.

Section 3. Issues

Table 2. lists key issues that came out of the scoping comments that were used to create additional

alternatives.

Table 2. Issues

Documents

COMMENT AND ISSUES ANALYSISa123.g.akamai.net/7/123/11558/abc123/forestservic...COMMENT AND ISSUES ANALYSIS December, 2012 USDA, Forest Service Intermountain Region (Region 4) Manti-La