Attached please find our objection letter to the Hermosa Creek Watershed Recreation and Travel Management Project and attachments.

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1 From: To: Cc: Subject: Date: Attachments: Mary Monroe Brown FS-r02f13admin-review; Chadwick, Kara -FS Janowiak, Matthew J -FS; Whitney, John (Bennet); David Bode; Mary Monroe Brown Hermosa Creek Watershed Recreation and Travel Management Project Objection Tuesday, October 24, :19:41 PM HermosaObjectionLetter#2017Watershed.pdf Initial Plan (mechanize (text).pdf Initial Plan Draft (grid).pdf Bennet letter to USFS on south trail hermosa.pdf Dear Kara: Attached please find our objection letter to the Hermosa Creek Watershed Recreation and Travel Management Project and attachments. Thank you for your time. Best, Mary

2 Hermosa Creek Watershed Recreation and Travel Management Project Assessment #43010 San Juan National Forest Columbine Ranger District Matt Janowiak, Forest Service District Ranger Objection Reviewing Officer Name: Kara Chadwick Objection Reviewing Officer Title: Supervisor, San Juan National Forest Mary Monroe Brown Trails 2000 Executive Director PO Box 3868 Durango, CO RE: Objection to specific components of the Hermosa Creek Watershed Recreation and Travel Management Project Environmental Assessment Decision Notice Dear Kara: Trails 2000 hereby formally files this objection to specific findings and decisions within the San Juan National Forest Hermosa Creek Watershed Management Plan Environmental Assessment, noticed on September 9, Lead Objector Mary Monroe Brown Mary Monroe Brown Trails 2000 Executive Director PO Box 3868 Durango, CO Statement of standing: Trails 2000, (also referred through out as Objectors ) timely filed comments during all aspects of the Hermosa Creek Watershed Management Plan (hereafter referred to as the HCWMP) in- Page 1

3 cluding but not limited to the pre-planning Hermosa Creek sub-workgroup community collaborative, 2015 HCWMP scoping, 2016 HCWMP initial draft and 2017 HCWMP final Environmental Analysis (EA) providing Objectors appropriate standing in this planning process. Importantly, the Objectors previous comments on this plan and for the issues addressed below have been consistent throughout the process. Objectors are on record requesting balanced recreation trail connectors for mountain bike access to replace other trail closures imposed by the Hermosa Creek Watershed Wilderness legislation, offering to assist in the funding costs for any new trails studied and/or designated, and to assist in organizing volunteer trail work. These consistent comments have been submitted since initial scoping periods began in April Comments referencing and objecting to seasonal closures being expanded to include mechanized use were more limited to the recent final HCWMP EA decision notice as this expansion to include mechanized was only included in the final EA released in summer of 2017 limiting the reaction and response to one final comment period and this Objection letter. 2. Concise Statement of the issues and/or the parts of the HCWMP to which this objection applies. Objection #1: First and foremost, this objection challenges the San Juan National Forest s (SJNF) determination in the HCWMP that a seasonal closure is appropriate and justifiable to include mechanized use and should be expanded to include/apply to mechanized use in the Special Management Area (SMA) without analysis and fully reversing prior preferred actions where the SJNF provided rationale for why season closures were not necessary for mechanized use. We assert that the decision to include mechanized use in the seasonal closures throughout all alternatives in the final EA was both arbitrary and capricious and baseless due to the complete absence of any scientific analysis or evidence of need or impacts associated with mechanized use on the roads and trails in the SMA. The lack of a reasonable range of alternatives violates NEPA. Objection #2: This objection challenges the San Juan National Forest s (SJNF) decision in the HCWMP project level assessments to dismiss a new community trail connector without sufficient analysis and then base the dismissal on flawed reasoning as a way to avoid addressing this need. Despite acknowledging broad support, the SJNF has chosen to minimize the intent of the clear legislator message submitted via letter (see US Senator Bennet letter to SJNF Supervisor Mark Stiles dated July 17, 2012), during the development of the Hermosa Creek Watershed Protection Act legislation. The letter urged the Supervisor Mark Stiles and the SJNF to study the viability of a trail connector between the Colorado Trail and the Hermosa Creek Trail. The reasoning to dismiss is flawed because there is no analysis to justify claims of costs and difficulty and no opportunity provided for the public stakeholders to revise their proposal to address any concerns brought forth via analysis. Without extensive analysis, objectors are left to assume the decision to dismiss this trail connector proposal in order to achieve the intent and spirit of the Hermosa Creek Legislation is arbitrary and capricious. While we understand the alignment was reviewed, the Objector contends that over eight years of conversation regarding this topic was set aside and not provided the full extent of review expect- Page 2

4 ed and clearly expressed within the community development of the Hermosa Wilderness bill. The justification for these two objection issues will be discussed in more detail below. 3. Detailed statement justifying and explaining objection #1 and suggestion of how the proposed plan decision may be improved. Objection #1: Lack of range of alternatives The SJNF erred when failing to provide a range of alternatives as it relates to seasonal closures for mechanized use in the final EA leaving mechanized users (bicyclists) with no option other than closures to choose from. After the draft EA, the SJNF altered all alternatives to include the seasonal closure to mechanized travel. This radically departs from the draft where seasonal closures did not apply to mechanized use and the SJNF made arguments to justify not including mechanized where both resource concerns and wildlife impacts were addressed and considered non impacted. This failure to provide a reasonable range of alternatives that do not lump mechanized use in with motorized seasonal closures violates NEPA. NEPA requires that the SJNF must rigorously explore and objectively evaluate all reasonable alternatives. Lack of science based justification The SJNF also erred in the basis of their complete reversal of its proposed action in the draft to the proposed action in the final EA by adding mechanized use to the seasonal closures within the Special Management Area (SMA) without providing adequate public process or justifiable analysis. Appendix B of the Initial Draft of the Hermosa Creek Watershed Management Plan set out the proposed action on all the critical issues, and on Page B-8 (see attached) included the proposed action for trails. The grid lists the current situation for most trails as open year-round and the proposed action as open year-round. On Page B-9 (see attached) after the grid it states the reasoning: Currently there are no seasonal closures on any trail, but the proposed action designates seasonal closures for motorized use. This is to protect wintering big game and to protect trail surfaces during muddy fall and spring conditions. The reason mechanized use is not similarly restricted is because human-powered transportation is quieter and because it s not likely that bicyclists will be able to push through much un-groomed snow; thus, the risk of disturbance to wintering wildlife is much less than that from motorized use. The basis for the reversal of the above claim and position was stated explicitly to be based on the legislation in the HCWMP EA where the SJNF, lacking any other justification, states on page 71: Page 3

5 The Travel Rule requires the publication of an MVUM which specifies not only the designated motor vehicle classes, but also the designated time of year that roads are open. For the Hermosa Plan, all action alternatives include the provision that seasonal closures would apply to mechanized as well as motorized uses; this includes bicycles. The reasons that bicycles are included in the seasonal closures is that the Hermosa watershed was identified by Congress as a special landscape needing extra protection; the legislation did not differentiate between motorized and mechanized vehicles. Seasonal closure of the roads to all vehicles will help protect the watershed from erosion, will help protect wildlife during critical months, and will help protect the capital investment of the road itself. This not only contradicts, without justification, the very arguments that the FS made in the previous daft documents, but it also falsely suggests that the Travel Management Rule applies to bicycles. It does not. It then falsely claims, as justification, that the legislation did not differentiate between motorized and mechanized vehicles. Reliance upon false premise-the Objectors contend that the seasonal closure relating to mechanized travel are unjustified and falsely based on weak and inaccurate arguments related to the legislation. The SJNF has relied upon the false premise that the intent of the Hermosa Creek Watershed Protection Act was that motorized and mechanized be managed the same and the false premise that the SMA was created to limit recreational access. Regarding the purpose of the SMA, Subsection (b)(2) of the enabling Hermosa Creek Wilderness Legislation clearly stated that the purpose of the SMA included the preservation and protection of its recreational resources. Seasonal closure negatively affects the areas recreation resources by unnecessarily limiting the bicycle-assisted hunting access, recreational mountain biking and snow biking access for the public without proper justification and therefore is counter to the intent of the SMA. Regarding the claimed link between motorized and mechanized. The Forest Service presents an attempted rationalization for the change in several places, including the Expanded Response #4 to the Plan Comments, and Pages 71 and 87 of the Final EA. In all three places virtually identical statements are made as the underlying basis of the rationale to include mechanized (bikes) in the seasonal closure. In Response #4 the Forest Service stated that, Motorized and mechanized uses are mentioned together throughout the legislation; therefore, it is clear that they are meant to be treated equally, and on Pages 71 and 87 of the EA, The reasons that bicycles are included in the seasonal closures is that the Hermosa watershed was identified by Congress as a special landscape needing extra protection; the legislation did not differentiate between motorized and mechanized vehicles. In addition, the same rationale is presented to support the exclusion of snow bikes: Mechanized vehicles are considered together with motorized vehicles throughout the legislation, therefore, proposed management of these two vehicle classes in the winter is the Page 4

6 same in the Proposed Action. The problem is that these statements are not a correct reflection of the legislative language. In Section 3(b)(i)(I) of the legislative language it simply states: the use of motorized and mechanized vehicles in the Special Management Area shall be permitted only on roads and trails designated by the Secretary for use by those vehicles. This is a common statement used to help identify where motorized use and mechanized use is permitted. This is the only joint reference in the entire legislative Act, so motorized and mechanized are not mentioned together throughout, nor is there any indication they are meant to be treated equally. Contrary to the Forest Service s repeated assertion, there are no legislative restrictions on mechanized use other than that it be limited to roads trails designated by the Secretary. In fact, in the legislation, under Sec 3. (i) Management Plan the intent is made clear that the SJNF, by way of the Secretary, (1) take into account public input, and (2) Provides for recreation opportunities to occur within the SMA, including biking, among other activities. The SJNF has based this proposed action on a minority comment and ignored the broad public sentiment that helped draft and pass the legislation that created the SMA. In the Wildlife plan section 5.0 of page 170 of the final analysis, mechanized and motorized are clearly separated and listed as to their effect on elk: Elk was chosen for detailed analysis because much of the available research on the effect of the recreational activist on wildlife is related to impacted of motorized travel on elk. Roads and motorized trail have the potential to be an influential element in how elk use key habitats on public lands. Reliance upon biased wildlife advocates-it appears that the reversal was unduly influenced by one specific comment letter submitted by Matt Thorpe, Area Manager of the Colorado Parks and Wildlife (CPW). CPW, via Mr. Thorpe s letter, advocates for expanded seasonal closure dates and inclusion of mechanized closures to serve the interests of its constituents hunters. It is well known that CPW seeks broad sweeping closures to non-hunting recreational access, specifically mountain bike access, and statements made in this letter prove this. CPWs negative bias towards bicycles is clear when they falsely suggest bicycles are noisy as justification for closures to benefit hunters when CPW states In addition we recommend limiting mechanized use of Upper Dutch/Pinkerton and Little Elk trails during the period of September 1-November 30 to reduce conflicts with hunters and outfitters. This restriction will provide an area of quiet enjoyment for hunters. Bicycles, unlike motorized vehicles are non-motorized and therefore are quiet. The Forest Service accurately acknowledged this fact in the draft but has conveniently removed and ignored this in its apparent adoption of the unfounded restrictions advocated by this CPW manager. CPW, and the SJNF by association, due to the reversal in the proposed action, also appear to rely upon outdated (20+ year old science review by wildlife advocates) that lump bicycles in with motorized vehicles in the analysis of impacts falsely associating bicycles as having impacts on par with motorized vehicles. Yet these studies are conveniently ignored when it comes to the adjacent management of the ski area where far greater impactful and noisy operations are commonplace. This reliance on outdated science to justify public access restrictions to non-hunters yet serve to maximize hunter experiential Page 5

7 benefits suggests an inherent bias towards non-hunting recreational access in favor of hunters. Public lands are for all public benefit. Despite the merger of Wildlife and Parks into one entity, CPWs comments consistently seek to serve a small and diminishing segment of hunters at the expense of other trail users, specifically mountain bikers who helped pass the very legislation that led to the increased protections to lands in the watershed. In fact, CPW references the economic benefits of hunting and fishing to the local economy, yet conveniently ignores the negative impacts of its recommendations to a far greater and growing economic benefit to the local and state economy that trail based recreation such as mountain biking provides. The La Plata County Comprehensive Plan identifies the importance of recreation to the County in the following statement: Recreation and tourism is one of the biggest driving industries within La Plata County. This positive impact led the county to set pro-recreation and pro access policies in its comprehensive plan. Policy 9.1.A1 seeks to incentivize and provide for increased access to public lands. Policy 9.1.A3 seeks to encourage recreation and tourism related development in order to maintain and enhance the benefits of these to the local economy. The apparent reliance, by the SJNF, on the narrowly focused view of a singular commenter to reverse proposed actions in all alternatives conflicts with the desires and needs of the local community to enhance access to public lands for trail-based recreation. In the town of Durango, almost half of the landscape is closed to all non-motorized users from November 15 to April 15 on Animas Mountain, on the Grandview Trails, Perins, Twin Buttes and Smelter based on wintering habitat; therefore, adding Hermosa Creek, Jones, Dutch, Pinkerton and a series of trails in the Hermosa Watershed Area to the six-month closure does irreparable harm to public recreational access without justification. The seasonal closures designated by the EA assumes that big game remain in the high country during the winter months when snow is deep, which is not the case. The reason for the local trail closures is that the winter range and production areas are primarily at lower elevations during this period. In fact the CPW letter acknowledges this in their comments where they state, In addition these dates are consistent with existing seasonal closures on nearby recreational lands which would help to avoid confusing trail based recreationalists. This fails to recognize the purpose of seasonal closures to certain areas, which is to address habitat sensitivities in specific localized landscapes where conditions warrant a special limited closure. Closures must not be broad sweeping as this creates considerable harm to public access and amounts to a runaround to the public process for determining appropriate designations for recreational access. Recreationalists are used to management prescriptions that change based on jurisdiction and geography and time of year. Suggesting that a one-size-fits-all seasonal closure access approach is necessary across the region is inappropriate and a poor management solution. The SJNF must not base its seasonal closures on these grossly biased recommendations. We don t see any scientific indication in the HCWMP EA that indicates bicycles pose a resource impact problem. The intent of the legislation was to keep the landscape as it is; the Hermosa area has never had a seasonal closure and there has been little impact to the landscape to change the decision. It is adjacent to a popular ski area, with snowmobiling and backcountry ski tours utilizing snow cats. Evicting mountain bikes, arguably the highest user group, off the iconic Hermosa Creek Trail for several months out of the year was not expressed as a public desire Page 6

8 and is certainly not in line with the community s desire to create a community-wide plan complete with compromise for the Hermosa area. Mountain bikers experienced a great loss of trail access, losing trails: 559Salt Creek, 519Big Bend, 547Neglected, 549Cape of Good Hope, 559Salt Creek and 550Clear Creek. The Objectors, under Trails 2000, agreed to support the Wilderness bill despite these losses to a key user and stewardship group with the understanding that additional trail connects would be studied. Relief Requested/Proposed Plan Improvements: The Objectors seek relief and resolution in an amended EA that would remove the term mechanized from the seasonal closures in the management of the SMA in Alternative 2 (Proposed Action) of the HCWMP. The change to all alternatives from the draft to the final is drastic and contradicts itself and lack the necessary analysis of impacts that are needed to justify the added closures to mechanized vehicles. Prior to enactment of the Wilderness legislation mountain bikers had year-around access to the entire 107,900 acres of the Planning Area. Bikers were able to ride, push or carry their bicycles to access all historical trails, logging and mining roads, as well as open ground where it was appropriate. The complete ban of bicycles from the Wilderness and relegation to only the 58 miles of roads and 118 miles of trails designated for mechanized use under the proposed Travel Management Plan reduces that access to less than 170 acres (based on 20 ft. road and 2 ft. trail widths). This amounts to a loss of approximately 98.4 percent of the terrain in the Planning Area to use by mountain bikers, which the Forest Service intends to further limit by seasonal closure in this HCWMP EA. Trails 2000 does not believe this is in keeping with the goal and intention of the community in drafting the SMA, nor the enacted legislation. 4. Statement that demonstrates the link between prior substantive formal comments submitted by the objector and the content of the objections, unless the objection concerns an issue that arose after the opportunity for formal comment. The inclusion of mechanized use was not in the draft EA preferred alternative. Therefore the first this issue was discovered was in the final EA where every alternative included mechanized use in the seasonal closures. The Objectors thoroughly reviewed and commented on the opposition to this closure to mechanized based on the lack of justification. The inclusion of the link to the claimed legislative intent was added most recently. Objectors comments related to this were submitted July of Detailed statement justifying and explaining objection #2 and suggestion of how the proposed plan decision may be improved. Objection #2: The SJNF erred by not providing more thoughtful analysis on the Page 7

9 clear legislator/legislative intent to study the broadly supported trail proposal to connect the Colorado Trail with the Hermosa Creek Trail and based the decision to dismiss on false assumptions and broad speculations that lacked scientific and economic support and offered no data and little on-the-ground analysis that would support the cost and feasibility claims made in the EA. In dismissing and failing to study this proposal, the SJNF is inconsistently applying the components that comprise the intent of the legislation to the HCWMP and violating the intent with false claims that lack support. These arbitrary and capricious actions of the SJNF to avoid studying the full trail analysis or suggesting an alternative connection despite legislator intent, would suggest that the SJNF seeks to prevent the trail from ever being built which would be a disservice to the community and the collaborative process that led to the passage of the Hermosa Creek Watershed Protection Act of The new Wilderness eliminates all existing Hermosa Creek Trail/Colorado Trail mountain bike connections from West Cross Creek to Highway 550, except for the Buck Creek Trail which the Forest Service and Trails 2000 have determined is unusable, and the HCWMP offers no alternatives for this vital connection despite the clear intent by the legislative sponsors of the Act for such alternatives to be studied to create the necessary trail connectors and the importance of these access points for the community. The HCWMP amounts to a pseudo-analysis of a possible Colorado Trail to the Hermosa Creek Trail connector and was not inclusive of the entire trail distorting the assumed conclusions. In considering the first part of the No Buck Trail and the adjoining private property to form its justification for dismissal; the Objectors believe the long standing desire of the Objector to create a connect from the Colorado Trail to the Hermosa Creek trail was ignored. The plan included an irrelevant and unrelated cost estimate, which was not based on an actual price quote. No other proposed projects in the HCWMP included the cost as reason for supporting or denying the proposal, and at no time were the Objectors (Trails 2000) asked to consider another alignment. We do acknowledge the proposal is a long-term proposal but there are several funding options available from private funding to State Trails grants. Our highest need was for the NEPA to be done during the planning process. Without a study, the outcome is predetermined. During the legislative process, the Objectors worked with the collaborative group to come up with a compromise for the Hermosa Creek Watershed Protection Bill that identified a need and indicated broad support for a connector trail from the Hermosa Creek trails to the Colorado Trail to replace trails lost in the legislative proposal. US Senator Michael Bennet s office supported this agreement and made recommendations via a letter to the Forest Service dated July 17, 2012, and addressed to Supervisor Mark Stiles. In this letter, Sen. Bennet referenced; there is also broad support to consider the possibility of creating a new route that would provide a link between the Hermosa Creek Trail and the Colorado Trail. Page 8

10 Sen. Bennet s letter went on to state that; Properly sited and vetted, a trail of this nature would be a tremendous asset to the community. With the goal and intent of seeing this connector come to fruition, the Senator finished his letter to the San Juan National Forest with; I urge you to fully explore and study the possibility of creating such a trail at your earliest opportunity. This HCWMP would constitute the earliest opportunity that Senator Bennet intended. The failure to study this proposal during the earliest opportunity that the HCWMP provided fails to meet the legislative intent of the Hermosa Creek Watershed Protection Act. The Objectors contend that the intent of the EA is not only to build a management plan for the Hermosa Creek Watershed to bring into compliance the forest plan with the letter of the law passed in the legislation of the Hermosa Creek Watershed Protection Act of 2014 but also to meet the spirit of the Congressional intent that existed when it passed Congress in Senator Bennet sent his letter to ensure that all parties involved in the development of his legislation were able to realize their goals and achieve the outcomes of the agreement that made the passage of the bill possible even if every aspect of the agreement were not contained in the legislative language itself. For the SJNF to dismiss the proposal without studying its potential, is a not only inconsistent with the intent of the law, but serves as a disincentive to future collaboration and discourages community involvement on issues that involve Forest Service land management that the SJNF so often encourages. The SJNF should have studied the trail connector proposal to determine definitively any issues, concerns, mitigations and economic costs of the proposal in order to justify any decision on the proposal in the HCWMP and provide the public an opportunity to respond. Relief Requested/Proposed Plan Improvements: The Objectors seek relief and resolution in an amended EA that creates a clear process and timeline that would properly study the trail connector proposal to determine its potential and to seek to assess a proper alignment for the proposed trail to meet the intent of the legislation and to allow the proposed connector to remain as an alternative until funding allows construction. We ask that the SJNF specifically complete the NEPA for the proposed route or most sections in the HCWMP or subsequent planning process. The Objectors seek relief in a proper study performed by the SJNF to understand any and all concerns and provide an opportunity to address concerns in concert with the SJNF and other stakeholders in the future. This study would allow for the Objectors and other community members to seek any necessary funding and organize volunteers to help realize the Page 9

11 trail in the future if it were feasible. Without any study, this community process can t be pursued. A recent OIA study measured the US economic impact of outdoor recreation as 887 billion dollars; in Colorado, outdoor recreation generates more than 28 billion dollars and over 229,000 jobs. If we are to continue to grow this key driver for the state of Colorado, overcoming these political battles is crucial. Trails 2000 has proven it is an effective partner and has been praised by the Forest Service, including being recognized as Recreation Partner of the Year. 6. Statement that demonstrates the link between prior substantive formal comments submitted by the Objector and the content of the objections, unless the objection concerns an issue that arose after the opportunity for formal comment. Beginning with the submission of our comments on April 27, 2015 during the Hermosa Creek SMA Scoping period, we mention the need for and support of the trail connector, including referencing the Senator Bennet letter, and we offer help with funding and volunteer service to ease the burden on the Forest Service. Objectors continued these recommendations in the most recent comments on the final EA submitted in July 2017 where we again addressed the need for and support of the same trail connector. Our comments have been consistent, timely and justified for over two years of this HCWMP process yet the SJNF has chosen to dismiss the requests outright without adequate analysis or justification despite the legislation indicating that the purpose of the SMA is to include and preserve recreational mountain biking. 7. Statement of historical involvement In response to the HCWMP EAs section on background where the history of the workgroup is addressed, the Objectors wish to shed light on their level of involvement in that same timeframe and process. The Objectors, at the time operating as Trails 2000, have been deeply involved both informally and formally as part of a community collaborative known as the Hermosa Creek Workgroup since the citizen s Hermosa Creek Wilderness proposal first became public in 2008 and the collaborative was established. The Objectors remained involved through all iterations of the legislative development and its passage in Congress in 2014 and throughout the HCWMP that this objection addresses. As such, the Objectors have worked for nearly a decade to help craft and shape the management of the Hermosa Creek Watershed to be aligned with the desires and needs of numerous public and community stakeholders in a manner that also seeks to achieve the resource management goals of the USFS as part of those collaborative workgroups. The HCWMP decision is a critical link in completing and achieving the desired outcome of that collaborative effort. Diverse interests have supported the agreements made in the Hermosa Creek Watershed collaborative effort and, importantly, have supported continued and enhanced mountain bike trail access. This continued and enhanced mountain bike trail access is the lacking aspect in this final EA and comprises the basis of our two-part objection addressed below. In addition, for over 25 years, Trails 2000 and their volunteers have partnered with Page 10

12 the Forest Service on a broad partnership and shared vision of trail stewardship adopting a variety of FS trails from the largest section of the Colorado Trail, Missionary Ridge, Engineer Mountain Trail, and trails at Purgatory, to help reduce costs to the District and assist with various share the trails and educational campaigns. Successful collaboration relies on the long-term trust of all parties. In order to ensure that the value of authentic local collaboration is upheld, there must be trust that the support and follow through of all collaborative process agreements will continue through all aspects of the land management planning spectrum to meet the spirit and intent of those agreements (including those made in legislative law). This value of collaboration is predicated on all parties having a reasonable level of success with the components of the collaboration that are meaningful to their interests. At that time, Trails 2000 contacted and collaborated with the Forest Service, the Wilderness Society, San Juan Citizens Alliance, and various community members to gather potential management solutions to address the impacts of the citizen proposed Wilderness to mountain bike access and the closure to sections of the highly popular and iconic Colorado Trail and Hermosa Creek Trail to mountain bikes via a mechanized closure. This collaborative effort was referred to as the Hermosa Creek sub-workgroup. Please consider our objection and the remedies proposed; they are very important issues for our community. We welcome opportunities to discuss these objections with the SJNF and along side other interested persons and organizations in the community. Sincerely, Mary Monroe Brown Mary Monroe Brown Trails 2000 List of attachments or citations: (Pages B-8 and B-9 of Appendix B of Initial Draft of Hermosa Creek Watershed Management Plan, Trail Mileage PDF, Senator Bennet s Letter) Page 11

13 INITIAL DRAFT Hermosa Creek Watershed Management Plan Appendix B - Recreation and Travel Management Trail Name West Cross XXX Corral Draw 521 Colorado Trail 520, 501, 507, 622 Purg. Trails Complex Wilderness Big Bend 519 Salt Creek 559 Neglected 547 South Fork 549 Clear Creek 550 Current Situation Over-ground motorized Non-system. Closed. Open when snow cover Open yearround. Motorized single track. Open yearround. Some segments motorized single track. Non-System, but under permit Non-motorized/ non-mechanized Non-motorized/ non-mechanized Non-motorized/ non-mechanized Non-motorized/ non-mechanized Non-motorized/ non-mechanized Open 5/1-11/30. Motorized single track. Add motorized connector to road at top to avoid CT. Closed. Add parallel CT at Tin Can Basin Road. Proposed Action Over-snow Mechanized motorized Closed Open where west of watershed boundary, when snow cover. Add to system.. Over-ground on trail only. Over-snow open area. on trail only. Over-ground on trail only. Over-snow open areas. Closed Closed Open over-ground on trail only. Closed over-snow. Non-motorized, Non-mechanized Add to system. Closed Closed Closed Take off system Closed Closed Closed Closed Closed Closed Take off system Closed Closed Closed Take off system and remove bridge Closed Closed Closed Currently there are no seasonal closures on any trail, but the proposed action designates seasonal closures for motorized use. This is to protect wintering big game and to protect trail surfaces during muddy fall and spring conditions. The reason mechanized use is not similarly restricted is because human-powered transportation is quieter and because it not likely that bicyclists will be able to push through much un-groomed snow; thus, the risk of disturbance to wintering wildlife is much less than that from motorized use. The proposed authorization of motorized use on the upper Dutch/Pinkerton Trail would provide a replacement for the Clear Creek Trail motorized use which was lost when the wilderness was designated. The majority of the proposed new motorized segment would fall on an old roadbed, which is easily maintained and would create little surface disturbance. Additionally, authorizing this segment for motorized use would create large motorized loop options. The proposal to designate the Big Lick Trail as non-mechanized would be to provide one trail on the east side of the drainage that would be limited to foot and horse traffic. The Elbert Creek B-9

14 INITIAL DRAFT Hermosa Creek Watershed Management Plan Appendix B - Recreation and Travel Management Proposed Action for Trails All motorized and mechanized over-snow and over-ground vehicle use within the watershed is restricted to designated roads, trails, and areas, as required by the Hermosa Creek Watershed Protection legislation. Each road and trail is designated by authorized type of use and season of use. For proposed designated trail uses, see Table B-4 and Figure B-1. Non-motorized and non-mechanized modes of travel (e.g. foot and horse) are allowed on all trails, except as noted within the ski area permit boundary. Authorized over-ground OHV must be 50 wide or less. Table B-4. Public Trail Use Proposed Action Trail Name Hermosa Creek 514 Jones Creek 518 Current Situation Open yearround. Motorized part single-track, part OHV. Open yearround; Motorized single track. Over-ground motorized Open 5/1-12/31 lower stretch. Open 5/1-11/30 upper stretch. Motorized: part single-track, part OHV. Add <50 bridge. Open 5/1-12/31; Motorized single track. Proposed Action Over-snow Mechanized motorized Open at upper. end when Over-ground on snow cover. trail only. Over-snow open area at upper end. Closed on trail only. Non-motorized, Non-mechanized Dutch Creek 516 Pinkerton 522 Upper Dutch/ Pinkerton XXX Elbert Creek 512 Big Lick XXX Little Elk 515 Open yearround. Motorized single track. Open yearround. Motorized Open 5/1-12/31. Motorized single track. Open 5/1-12/31. Motorized single track. single track. Non-motorized Open 5/1-12/31. Motorized single track. Closed Closed Closed Non-motorized Closed Open when snow cover on trail only on trail only on trail only. Over-ground on trail only. Over-snow open area. Non-motorized Closed Closed Closed Non-motorized Closed Closed on trail only B-8

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