September 14, Comments of the Colorado Trail Foundation On the USFS Scoping Notice of August 13, 2010 RE: the relocation of the CDNST/CT Page 1

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1 THE COLORADO TRAIL FOUNDATION Comments on the U.S. Forest Service Scoping Notice of August 13, 2010 Regarding the Relocation of THE COLORADO TRAIL AND CONTINENTAL DIVIDE NATIONAL SCENIC TRAIL From La Garita Wilderness to Windy Peak September 14, 2010 INTRODUCTION The Colorado Trail Foundation (CTF), in partnership with the U.S. Forest Service, manages and maintains The Colorado Trail (CT) from Denver to Durango to insure a high quality Colorado Trail experience. The CT is a very popular and unique long-distance, high mountain trail widely considered a Colorado treasure. It is very popular with hikers, equestrians and mountain bikers for both day trips and long distance travel. The CT is maintained by a dedicated group of volunteers; in 2009 alone, 579 of them provided 19,354 hours of volunteer work to keep the trail one of the best in the country. The vision for the CT is that it will be a non-motorized trail from end to end. The Colorado Trail coincides with the Continental Divide National Scenic Trail (CDNST) for some 200 miles including the entire distance of the relocation proposed in the US Forest Service s Scoping Notice of August 13, We work closely with the Continental Divide Trail Alliance and provide the majority of the trail maintenance on the co-located trail including the segments of the proposed relocation. For several years, the CTF, in conjunction and cooperation with the Continental Divide Trail Alliance, has been considering a relocation such as the one proposed in the Scoping Notice. Therefore, we are grateful for the USFS s consideration of and proposal for the relocation. It will allow the construction of new, sustainable tread and will greatly improve trail conditions by removing the CT/CDNST from motorized trails and from trail segments where the trail tread has been damaged beyond repair. CONCERNS AND CONSIDERATIONS Trail Construction Priorities: While our long-term view is that the entire distance of the proposed relocation is desirable, we suggest that the segments from Lujan Pass south to La Garita Wilderness be considered the first priority. We also suggest that those southern segments be the subject of an initial Environmental Assessment, with a subsequent EA for the northern segments from Lujan Pass to Windy Peak. We think that an EA addressing the southern segments may be able to be completed more rapidly and allow us to begin construction earlier (see our discussion in the Lujan Pass to the Tank 7 Cutoff segments below). The EA for the northern segments could then be started while we are constructing the southern segments. Comments on Trail Use Proposals: Trail use for all sections designated in the Scoping Notice, except for the Razor Park Road to Tank 7 Cutoff segment, state Horse and Foot Travel Only. Except for a portion of the Skyline Trail to Forest Road 787 segment discussed in our specific comments below, we request that the segments designated in the proposal for Horse and Foot Travel Only be changed to include mountain bike use. The mountain bike community, including day users and long distance travelers, is a significant and longstanding part of the CT/CDNST community. We have heard from the mountain biking community that because of the condition of the trail in some segments of the proposed relocation and because of the extensive Comments of the Colorado Trail Foundation On the USFS Scoping Notice of August 13, 2010 RE: the relocation of the CDNST/CT Page 1

2 motorized use on some segments, they want to move off the existing trail to a newly constructed, more desirable and sustainable trail. If the decision is made to restrict the trail use to horse and foot travel only, mountain bikers would be forced to continue to use the existing trail (if it is not closed entirely), a trail that is admittedly in bad shape for such use. Mountain bikers would also have to continue to contend with motorized users thereby continuing an undesirable level of trail conflict. Comments on Specific Trail Segments: La Garita to Cochetopa Skyline Trail to Old Cochetopa Pass (NN14): The proposed relocation "use designation" is Horse and Foot Travel Only. In the case of part of this segment lying northeast of Forest Road 787, we ask for a use designation that includes mountain bikes. We have long provided mountain bike riders with Wilderness bypass routes. The intersection of the relocation with Forest Road 787 is viewed as the point where the La Garita Wilderness bicycle by-pass would diverge. Because Forest Rd 787 could still be used as the mountain bike exit route to avoid the Wilderness Area, we support a designation of Horse and Foot Travel Only on the relocation southwest of Forest Road 787. We appreciate and support the proposal for development of the trailhead at Cochetopa Pass. Old Cochetopa Pass to Luders Spur Trail, Luders Spur Trail, and Luders Spur Trail 2: As discussed above, we request that all of these segments, including the spur trails, be designated as open for mountain bike use. We applaud the proposal to relocate the CT/CDNST closer to, but not through, Luders Campground. This will provide better access to Luders Spring, but without the CT/CDNST encroaching on the Campground or having the Campground encroach on the trail experience. Access to water is especially important for horses that use the trail. We also applaud the development of spur trails coming from the north and the south that will give easy access to the campground and spring for hikers, equestrians and mountain bikers. We also support and appreciate the proposed development of the trailhead at Luders Campground. Ludders Spur to Lujan Pass: Again we request that this segment be open for mountain bike travel. We appreciate and support the proposal to develop the trailhead at North Pass (US Route 114). Lujan Pass to Razor Park Trailhead: This segment is proposed to remain on the existing CT/CDNST and to be designated for Horse and Foot Travel Only. We again request that this segment be open for mountain bike travel. We have been told that the Forest Service staff has concluded that the trail tread in this segment and the segment from Razor Park Road to Tank 7 Cutoff is in good enough condition to allow continued use without relocation. However, this existing route involves several up and down sections that are excessively steep and should be explored for better grade alignment and sustainability. This is generally a good trail location as far as view shed is concerned and our general recommendation is to keep it. However, a separate EA for the northern segments of the proposal would allow us time to determine if there might be an alignment for some sections of the segment that would improve the trail experience. Comments of the Colorado Trail Foundation On the USFS Scoping Notice of August 13, 2010 RE: the relocation of the CDNST/CT Page 2

3 Razor Park Road (#793) to Tank 7 Cutoff: As with the above segment, the proposal is to keep the CT/CDNST on its existing alignment. Our comment above applies here as well, but we also note that the proposal is to keep this segment as a single track motorized segment. There is no mention of ATV use, but a recent on-the-ground examination found ATV use starting at the Razor Park trailhead and continuing north for an unknown distance. This section was never designed for ATV use and that use is destroying the trail. If the Forest Service intends to continue to allow motorized use on this segment, we strongly urge the Forest Service to take advantage of this opportunity to relocate the CT/CDNST away from the motorized route. The long term objective for both the CT and the CDNST is for a non-motorized trail and trail experience, and we believe that opportunities to achieve that objective should be taken when they arise. We ask, if the Forest Service agrees with relocation, that the segment be open for mountain bike travel. A separate EA for the northern segments would provide additional time to examine potential relocations and the concerns raised here. Tank 7 Cutoff to Windy Peak: We support new construction for this segment but again request that it be open for mountain bike travel. The existing trail in this section contains some very steep and rocky tread and the proposed relocation is a good way to eliminate these problem areas. Other considerations: Trail design: It is our desire that the relocation trail be designed with grade reversals so that it drains properly from day one. Grade reversals in the design will minimize erosion and maintenance, and maximize environmental protection and sustainability. There may be some places where minor changes to the proposed relocations would take better advantage of the views, an important component of the CT/CDNST trail experience. We request that the CTF be included in the actual flagging of the proposed relocations and that minor relocation changes be favorably considered. Forest Plan and Trail Management: We also request that consideration be given to the relocated CT/CDNST alignment when the Rio Grande and Gunnison National Forests implement the management prescriptions set out in their Forest Plans. For example, if the Plan calls for logging in the vicinity, we would ask that the CT/CDNST location be included in the analysis of the logging proposal with consideration given to minimizing any negative impact on the view shed, minimizing any road crossings, and to the avoidance of trail closures. CONCLUSION We appreciate the opportunity to offer our comments on the Scoping Notice regarding the proposed CT/CDNST relocations. The proposal is an important step in the ongoing effort to create and maintain a premier, high mountain, long distance trail in Colorado. We look forward to continuing to work with the U.S. Forest Service in defining and implementing the best relocations of this important trail. Thank you for your consideration, Bill Manning Managing Director The Colorado Trail Foundation Comments of the Colorado Trail Foundation On the USFS Scoping Notice of August 13, 2010 RE: the relocation of the CDNST/CT Page 3

4 Continental Divide National Scenic Trail Saguache Re-Route Rio Grande and Gunnison National Forests Gunnison National Forest 114 CCOLORADO OLORADO Lujan Pass A 285 F! 81 0 Area of Interest Rio Grande National Forest North Pass 70 Tank Seven Cutoff 4 78 Denver 25 Windy Peak 160 Location Map CR NN14 sti Exi Cochetopa Pass! F 768 FLuder's! Campground ST CDN ng 7465 Skyline Trail LaGarita to Cochetopa Cochetopa to Luders Spur Luders Spur Trail Luders Spur Trail 2 La Garita Wilderness Luders to Lujan Pass Lujan to RazorPark Razor Park to Tank 7 Cutoff Tank 7 Cutoff to Windy Peak F! Proposed Trailhead Existing CDNST Data Sources: Rio Grande and Gunnison National Forests Continental Divide Highway 114 Other Road Wilderness Area National Forest BLM Administered Lands State Lands Map Scale 0 1:199, Miles

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