Reynolds Creek Motorized Routes (38815) Response to Comments

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1 Stanislaus National Forest Groveland and Mi-Wok Ranger Districts Tuolumne County, California The legal notice for the opportunity to comment appeared in the newspaper of record (Union Democrat) on March 8, The 30-day comment period ended on April 8, In response to the Forest s request for comments, eleven interested parties submitted written or verbal comments during the comment period (Table 1). The interdisciplinary team (IDT) sequentially numbered each letter and each comment within each letter, and provided a unique comment identification (ID) number and a response (Table 2). Table 1 List of Commenters ID Name Address City State Zip Organization Received 1 Randy James P.O. Box 384 Tuolumne CA Stanley Cox P.O. Box 699 Tuolumne CA Tuolumne Me-Wuk Tribal Council 3 Natalie Wiemeyer 1163 Hopper Ave. Apt. 37 Santa Rosa CA Robert and P.O. Box 415 Tuolumne CA Cynthia Rhorer 5 Steve Hix John Buckley P.O. Box 396 Twain Harte CA Central Sierra Environmental Resource Center Darryl Cully 4001 S. Sperry Road Denair CA Amy Granat 1500 El Camino #352 Sacramento CA California Off-Road Vehicle Association v Michael Damaso 1119 E. Linwood Ave. Turlock CA Merced Dirt Riders Michael Damaso 1119 E. Linwood Ave. Turlock CA Merced Dirt Riders Michael Damaso 1119 E. Linwood Ave. Turlock CA Merced Dirt Riders v Verbal Comment The IDT reviewed all comments and identified supporting comments and substantive comments. Substantive (S) comments are: within the scope of the proposed action; specific to the proposed action; have a direct relationship with the proposed action; and, include supporting reasons for the Responsible Official to consider (36 CFR 215.2). The remaining comments do not meet the substantive test and the IDT identified them as non-substantive () comments. Table 2 below lists the comments received along with a response to the substantive comments. 1

2 Table 2 Comments and Responses 1-1 My comments are in response to the Reynolds Creek Motorized Trails Project. I disagree with the Forest Service proposal to block and restore motorized route 21812C off of road 2N12 in the Reynolds Creek Area for the following reasons: Route accesses a popular dispersed campsite Both campsite and access route 21812C are in good condition without any previous maintenance by the Forest Service Recommend re-establishing existing barriers (logs) with rock boulder barriers to keep vehicles from driving through campsite to creek and/or meadow areas Route 21812C should be added the National Forest Transportation System as a legal route to continue to provide access to dispersed camping opportunities by the visiting public as it has no negative impact to Forest health or resources. 1-3 Please forward any documentation (e.g., condition surveys, reports, maintenance records) that the Forest Service has completed related to this route that justifies such blocking and restoration of route 21812C. 1-3 I would like to work with the Forest Service by adopting this route and campsite as a Forest volunteer for any future maintenance needs. 2-1 We have no concerns with this project. In fact we think it is a good project to close off these user-created trails in order to protect the resources. 3-1 My comments are in response to the Reynolds Creek Motorized Trails Project. I disagree with the Forest Service proposal to block and restore motorized route 21812C off of road 2N12 in the Reynolds Creek Area for the following reasons: Route accesses a popular dispersed campsite. Both campsite and access route 21812C are in good condition without any previous maintenance by the Forest Service. Recommend re-establishing existing barriers (logs) with rock boulder barriers to keep vehicles from driving through campsite to creek and/or meadow areas. Route 21812C should be added the National Forest Transportation System as a legal route to continue to provide access to dispersed camping opportunities by the visiting public as it has no negative impact to Forest health or resources. 3-2 This change personally affects me as well as the hundreds of people who have had the opportunity to camp at locations accessed by route 21812C. For decades and several generations with my family, I have had the privilege to camp at sites that this road leads to. These camping experiences have given me the utmost respect and appreciation for the forest and its beauty. Without such experiences people like myself are not able to learn how to respect and value their forest. decommissioned or restored. In response to public comments, the Responsible Official selected a Modified Proposed Action where five unauthorized routes segments (21802H, 21803H1, 21803H2, 21812C and 21822B2) will be blocked to prevent unauthorized motorized use but will not be decommissioned. These five route segments may be considered for addition to the NFTS in a future environmental analysis. All documentation for this project is on file at the Groveland Ranger Station. Please call or stop by our office to review the documentation. 2

3 3-3 Closing off the routes to such beautiful campsites as can be accessed via route 21812C will only compound the problems the forests nationwide will face. It is obvious that funding for our nation's parks are dwindling. Closing off routes and eliminating opportunities for people to experience our beautiful forests will only decrease their longevity. 3-4 Closing route 21812C would take more than campsites away, it would take away the glimmer of hope that there can be complete and total freedom from the chaos of the world. 3-5 Please forward any documentation (e.g., condition surveys, reports, maintenance records) that the Forest Service has completed related to this route that justifies such blocking and restoration of route 21812C. 3-6 I would like to work with the Forest Service by adopting this route and campsite as a Forest volunteer for any future maintenance needs. Thank you for the opportunity to comment on your project. Please contact me with any questions. 4-1 We would like to comment on the Reynolds Creek Motorized Trails Project. We disagree with the Forest Service proposal to block and restore motorized route 21812C off of road 2N12 in the Reynolds Creek Area. We have been able to access a dispersed campsite off of route 21812C for the last 17 years. Each year that we go there we have had a wonderful time enjoying nature at its best (we are tent campers and do not own an ATV.) We feel that if access route 21812C is decommissioned due to the damage left behind by inconsiderate campers that we as well as other conscientious campers are being penalized. 4-2 We feel that access route 21812C should be left open with the following recommendations: Re-establish existing barriers (logs) with rock boulder barriers to keep vehicles from driving through campsite to creek and/or meadow areas. Add route 21812C to the National Forest Transportation System as a legal route to dispersed camping opportunities as we feel it has no negative impact to Forest health or resources. 4-3 We really appreciate being able to have had access to this dispersed campsite for the last 17 years and are hoping that this will continue. We are willing to volunteer and adopt this route and campsite for any future maintenance needs in order to keep it open. 5-1 Too bad the USFS doesn't make some type of camping areas in the Reynolds Creek area. Some of the older routes could stay for loop opportunity. 6-1 CSERC strongly supports the proposed action to close off use and to decommission/block the 14 route segments. We support the use of the draft Decision Memo as the appropriate level of analysis. The management requirements as spelled out in the document appear to be well designed and sufficient to prevent any potential significant resource damage from the proposed actions. See Response to Comment

4 7-1 The routes in the Reynolds Creek area are but another proposed closure of a small area that is open for OHV use in the great expanse of the forest. The closures in the past have been adding up, and sentiment is growing that these are designed to the eventual prohibition of nearly all OHV recreational use in the forest. How can anyone disagree that the forest is ours to share and use. This current situation can hardly be referred to as sharing. If the Forest Service honestly intends to manage the forest in such a way as to provide for all interests, Reynolds needs to remain open and managed. 8-1 We are concerned about the Reynolds Creek proposal because it will limit motorized access to a few campgrounds that have been available to use by members of the public for many years. Eliminating motorized access to these areas will make it difficult for protected members of society, including the disabled, elderly and very young to access previously available dispersed camping areas. This is an unacceptable, albeit unintended, consequence of the proposed action. 8-2 CORVA is confused by the terminology in the Reynolds Creek Project. The description of this project calls for decommissioning roads, but these roads were never commissioned by the Forest Service. A more correct terminology for a proposal of this type would be to restore areas affected by unauthorized vehicular access. The forest must be specific about the type of project proposed; decommissioning would entail a more extensive analysis than is offered in this document, and not be appropriate for a categorical exclusion. 8-3 Please correct the documentation that is associated with this project, and determine if removing motorized access to dispersed camping areas would greatly hamper access by the disabled, elderly and very young. This proposal is incomplete at best, and inappropriately defined, and the document must be remanded for further elucidation. There is no legal requirement to allow people with disabilities to use motor vehicles on roads, on trails, and in areas that are closed to motor vehicle use. Restrictions on motor vehicle use that are applied consistently to everyone are not discriminatory. Generally, granting an exemption from designations for people with disabilities would not be consistent with the resource protection and other management objectives of travel management and would fundamentally alter the nature of the Forest Service's travel management program (29 U.S.C. 794; 7 CFR 15e.103). Under section 504 of the Rehabilitation Act of 1973, no person with a disability can be denied participation in a Federal program that is available to all other people solely because of his or her disability. Consistent with 36 CFR 212.1, FSM , and Title V, Section 507(c), of the Americans With Disabilities Act, wheelchairs and mobility devices, including those that are battery-powered, that are designed solely for use by a mobility-impaired person for locomotion and that are suitable for use in an indoor pedestrian area are allowed on all NFS lands that are open to foot travel. Decommissioned routes would be blocked and stabilized, and are not intended to be used again in the future. In addition to blocking with barriers, removing culverts and constructing water bars, other actions may be taken to further reduce hydrological impacts, such as subsoiling, outsloping, recontouring and mulching. The barriers may be augmented with techniques such as camouflaging with brush or slash and recontouring the segment of route visible from its entrance. Decommissioning routes identified as railroad grades would consist of blocking and camouflaging the entrance of the route and not disturbing the road prism beyond the blocked entry. See Response to Comment

5 9-1 v Michael specifically talked about route 21812C. He mentioned the campsite that is associated with it. When I said that we had problems of people driving from the campsite into Reynolds Creek and into the meadow, Michael suggested placing boulders to prevent this route pioneering. Michael suggested adding 21812C to the road system. 9-2 v Michael also mentioned 21803H and that it looks to be an old logging road and not a user-created route. He said that adding 21803H would make a good loop (connecting 3N22A and 3N21) since most OHV users prefer loops vs. turning around at a dead end. I mentioned that there was a problem of route pioneering from 21803H down to Lost Creek and he suggested barricading the trail to prevent this. 9-3 v I explained that it is not currently legal for the public to be on these routes and the Reynolds Routes project just aims at restoring these roads to a natural condition. Michael stated that he has seen more illegal route pioneering occur after the Travel Management ROD because the Forest is shutting everything down. He explained that people will create their own routes if they re not given anywhere legal to ride. He also mentioned that during the public scoping phase of Travel Management, the Stanislaus said that loopcreation and route expansion would be looked at a project by project basis to see if OHV opportunities existed C Dispersed campsite, has been used for over 40 years by a current forest service employee. The current log barriers are rotted which allowed access to Reynolds creek. We are asking to leave the campsite open, but to block off the motorized access to the creek, not the motorized access to the campsite to allow parking, there is no parking along 2N12. a. OHV Soil Loss Monitoring (Green/Yellow/Red) rating of green condition during Stanislaus NF Motorized Travel Management Project (2009) b. Dispersed campsite inventory good condition rating during the 2007 Clavey River Ecosystem Project dispersed campsite inventories. c. Recommend re-establishing existing barriers (logs) with rock boulder barriers to keep vehicles from driving through campsite to creek H a. Popular dispersed campsite especially late in season during Deer Season when creek is dry. b. OHV Soil Loss Monitoring (Green/Yellow/Red) rating of green condition during Stanislaus NF Motorized Travel Management Project (2009) c. Dispersed campsite inventory good condition rating during the 2007 Clavey River Ecosystem Project dispersed campsite inventories. d. Recommend installing new boulder barriers on each side of creek crossing and block/restore route 21802H from 3N22 to the creek. e. Maintain and designate north end of route 21802H from NFTS road 3N21 into existing campsites. 5

6 10-3 Existing routes not designated in TMP: All these routes have very little slope, just a few feet to approximately 250 feet of change in elevation. A H This should have been two routes, the north route looks like an old log skid with water bars, it is the main one I am requesting to be added to the forest transportation trail system as it completes a loop opportunity connecting 3N22A to 3N21. a. Popular Four Wheel Drive Route and access to dispersed campsite opportunities. b. Never maintained by Forest Service, but remains in OHV Soil Loss Monitoring (Green/Yellow/Red) rating of green. c. Provides loop opportunity for OHVs, alternative to paved/graveled section of 3N B H The south section is an old log skid with water bars, that leads south down to a big rock outcropping that is used for rock crawling and as a dispersed camp site. It is not currently being used but could provide trail access from 3N21 to 3N22A C B2 This route runs along a ridge top and ends very close to 3N01T. It would be very easy to connect 21822B2 with 3N01T and then cross 3N01 to 02N I am an advocate for an environmentally responsible public, to have access to their forest lands. Resource conservation and continued public use and enjoyment were specifically stipulated in the legislation that withdrew lands from the public domain and entrusted those lands to the Forest Service for management. Public interaction with their forest is something to be managed for rather than against. The public is a major deterrent to abuse of our forest resources; it is their eyes and ears in the forest that safeguard our forest resources for future generations I believe public access and complete resource preservation are mutually exclusive; therefor, appropriate forest management is determining the level of public access that is in agreement with achieving a desirable forest condition that is sustainable in the longterm. The desired sustainable state of roads and campsites, under multiple use management that are addressed in this Draft Decision Memo (DM), will often not be in pristine natural condition, but a semi-natural state that attempts to meet a multitude of public expectations. The desirableness of a site condition is determined not only by the site itself, but the role it plays in the larger context of the integrated humanforest ecosystem. Although a road or trail is not a natural setting, the road opens the forest to public use and to achieving other Forest mandates. I believe that the forest service has the obligation to provide enough trails and dispersed campsites that will satisfy the general publics need for both 6

7 11-3 I believe that the general public is still using these campsites and routes. I also believe that they will reopen them or create new ones to replace them. These resources have a very high recreational value. Pioneering of new routes and or campsites would cause more resource damage than opening these existing sites and routes would cause In summary I want the public to have access to their own lands (meadows and beyond) and I want roads with adverse impacts in meadows to be repaired. I do not see management for public access and management for resource conservation as an either or option; the assignment of the Forest Service since its inception has been to accomplish both objectives. The Forest has the skills and financial capability to satisfy both objectives, but the alternatives provided will not allow the Forest to do so. At all of the TMP meetings I attended the public was told that, the TMP could be added to under projects like this one! 11-5 **This letter includes the same comments about specific routes as stated in letter 10** Several unauthorized routes exist within the Reynolds Project; many of these are user-created and are causing negative hydrologic and other resource impacts. Action is needed to block unauthorized access and to protect and restore degraded meadow and wildlife habitat in order to meet Forest Plan direction. The proposed action balances resources concerns while providing for dispersed camping opportunities, both motorized and non-motorized, public access, and looped motorized riding opportunities. See Response to Comment See 10-1 through