USFS proposes new trails, comments requested

COTA has submitted the letter below to our local Forest Service to comment on their proposal for new trail connections around the future site of the Visitor Center on Cascade Lakes Highway near the junction with Deschutes River road, USFS Road 41.

COTA would like to encourage anyone with an interest in this project to submit their own comments. You can copy parts of the official COTA letter below, use the bullet points to write your own letter, or just send in your own thoughts about it. Note that COTA has designed and planned most of the proposed single-track trails. Comments are due by March 4.

Please visit the USFS website for the project here:

<http://www.fs.fed.us/nepa/nepa_project_exp.php?project=41207>

Click on the link for ?Welcome Station Trail Connections Scoping Letter Signed? for instructions on how to send in your comments. The email address to submit written comments to the USFS is:

<comments-pacificnorthwest-deschutes-bend-ftrock@fs.fed.us>

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Central Oregon Trail Alliance

P.O. Box 555

Bend, OR

97701

http://cotamtb.com/

re: Comments for Welcome Station Trail Connections Project

February 24, 2013

Dear Ranger Larkin,

Please accept these official comments regarding the Scoping of the Welcome Station Trail Connections Project.

Bend has become a world-class destination for mountain biking, thanks to forward-thinking Forest Service leaders, recreation planners and COTA, and our mutual willingness to cooperate. This Trail Connections project presents an opportunity to address a few very important missing ingredients to this already outstanding trail system. With decades of combined trail management experience in this region and a shared long-term vision for preserving and enhancing this resource, COTA and the Forest Service can see clearly what is needed. COTA fully supports the stated Purpose and Need for this project, however with a couple minor adjustments we can address some very critical future trends and protect current conditions right now.

Specifically we would like to address the following points in the proposed action:

1. We want to emphasize the new trail connection (2a) along Road 41 as an alternative to the Deschutes River Trail is extremely important.
2. The mileage of proposed beginner trails is insufficient to meet anticipated future needs.
3. Reduction of existing roads or implementing Road-to-Trail conversion is not planned and should be considered.
4. There should be no new trail junctions, all new trails can be logically connected to existing trails at existing trail junctions.
5. Access to ?most difficult? trails (specifically COD) should be minimized and clearly marked, as these types of trails need to be both preserved and enhanced.

Below is our rationale for the above points.

1. New Trail Segment (2a) ?Catch & Release Trail? is a top priority

COTA applauds the Forest Service for proposing the N-S connector trail (segment 2a ? unofficially named ?Catch & Release trail?) because COTA feels this is a very important trail to provide for the public. This trail will accomplish several very important goals at the same time, namely, 1. It provides a safe alternative to cycling on Road 41, 2. It is an important alternative to the Deschutes River trail, and 3. This trail will allow links for intermediate and beginner level mountain bikers to the rest of the Wanoga & Phil?s Trail Systems from the city of Bend, the community of Sunriver and the Seventh Mountain Resort.

It is important to note that this trail is intentionally planned in the current proposed location in order to mitigate several potential problems. It is planned within 150 feet of Rd. 41 for the majority of the distance to reduce impacts to wildlife, and for planning simplicity and it is on the West side of Rd 41 in order to avoid the Deschutes River Wild & Scenic Corridor. With only anecdotal data to support the opinion that trails negatively impact wildlife migration, COTA wishes to point out that a trail in close proximity to a major Forest highway that sees significant high speed vehicular traffic cannot possibly impact wildlife any further. Certainly the trail itself is a far lower cause for concern than the road itself, while construction of the trail will have a lower impact on wildlife than the proposed West Bend Vegetation management activities.

Also, COTA would like to ask that you please consider whether the issue of wildlife impact is of greater importance than providing an important trail connection. COTA is of the opinion that non-motorized trails typically have low to zero impact upon wildlife. In a 2010 study in Arizona (see link here: http://www.heberrvresort.com/images/stories/pdf/2010-Arizona-off-road-and-hiking-trail-guides-and-maps.pdf ) on page 121 the writers confirm this opinion, and further state:

• ?In many cases, scientific knowledge alone can?t determine whether wildlife impacts are great enough to preclude a trail. The decision also should be based on community values, including the benefits the trail will offer the public.?

Trail Segment 2a ?Catch & Release Trail? should be constructed as described in the Proposed action.

Trail use in the Wanoga Area is only going to increase due to the strong demand for progressive style trails that this area does provide. This use is primarily shuttling up to Wanoga, and riding downhill. Without a trail to connect directly to the lower end of Wanoga trails (specifically Storm King and Tyler?s Traverse which is due for completion this Spring) mountain bikers have but a few options to continue to town or other trailheads to the East. One of these options is the Deschutes River Trail. By providing a new trail to effectively ?catch? all this new downhill bike use we feel potential conflicts can be avoided on the Deschutes River Trail and the increased mountain bike use of Wanoga trails will be channeled back to the Welcome Station or other primary mountain bike trail heads.

COTA wishes to commend USFS Recreation staff for planning construction of this trail after certain West Bend Vegetation Management activities have been implemented in Summer 2013, however the need for this trail is urgent. Once Vegetation management activities have been completed COTA volunteers would like to begin trail construction as quickly as possible. This trail is also a key volunteer match to the proposed RTP grant application for the paved trail (Segments 1a & 1b) for which COTA has already committed support. It is with the above considerations that we stress the importance of this trail.

2. Insufficient Proposed Beginner trails

Since the COTA Board of Directors first learned of the plans to create a new Welcome Station at the junction of FS Road 41 and Cascade Lakes Highway, we have argued strenuously for additional beginner-level trails in the vicinity. This opinion is based on the need to provide ?easiest? trail opportunities for the general public that will use the new Welcome Station as a day-use trail head or enter the trail systems from Resort areas nearby. A popular ?most difficult? trail called COD is very close to the planned Welcome Station and COTA has concerns for the public safety and the long-term viability of this trail if all trail users have easy access to it. For trail management purposes, COD should be considered ?expert only?. COTA Members prize this ?most difficult? trail opportunity and we feel we need to reserve COD as a true black diamond trail.

Since the Forest Service wishes to provide trail access from the Visitor Center to the rest of the trail system it is extremely important that this access be made available for the greatest number of potential trail users, so a beginner-level trail is absolutely necessary to connect to existing beginner-level trails. Also, since everyone prefers a mountain bike loop ride, the need to create complete, beginner-friendly loops from the Welcome station should be a top priority.

With this in mind COTA had assisted the Forest Service over the past year in planning and designing appropriate beginner trail opportunities in this area. Several objectives were considered when planning these beginner trails (Segments 3a, 3b, 3c & 3d), however some late changes have been proposed which may look OK on a proposed map, but will not function well on the ground. As a beginner mountain biker progresses in skill and fitness they will typically seek both longer and more difficult opportunities, but not necessarily at the same time. Options need to exist for beginners to have both longer beginner loops and incrementally more challenging trails. For the most part the West Bend trail system does meet these objectives therefore the proposed day-use trail activity originating at the Welcome Station needs more ?ground-truthing? to accomplish this objective.

A particular issue is with the proposed beginner trail Segment 3d as it meets existing trail ELV (?Elvin Magic?). ELV is rated ?intermediate? and the only other trail option at that particular junction is COD, rated ?most difficult?. COTA proposes retaining the section 5c to connect to proposed section 3b heading further West, and providing continuity on COD (section 4) heading South. This also eliminates the need for two additional junctions. (See #4 below for further rationale on this point)

Mountain bikers seek a trail opportunity primarily based upon its difficulty rating, while scenic or other values are secondary. It is not only important to provide ample opportunities for those seeking beginner type of experiences, but also to ensure they don?t get ?stuck? in an area where the only options are to turn and go back or proceed on a trail that is beyond their ability. Most cyclists are unlikely to ?go back?, preferring instead to keep going. It is for this reason beginner options are ideally designed in a ?stacked loop?, enabling riders to complete an entire loop within one difficulty level. Put another way, beginners have no business trying to ride an advanced trail such as COD. Effective planning and design must address this issue, and it is COTA?s opinion the scope of the current proposal is insufficient to meet this need.

COTA has proposed beginner trails connecting from the Welcome Station all the way to Ben?s trail to the North and to ELV to the East. Proposed Segment 3b following road 4604 within 150 feet is an adequate solution but it will necessitate a new junction, and it remains to be seen whether a complete ?beginner loop? can be achieved under this proposal.

Not only does COTA feel that the new Welcome Station will increase the number of beginner riders, but we also feel that the new tunnel under Cascade Lakes Highway immediately East of FS Road 41 is going to draw more trail users to this location. Event promoters especially will regard this as one less obstacle for planning a route since the tunnel allows crossing the highway without county mandated crossing guards during permitted events. The Forest Service has invested in this new tunnel, now is an opportunity to plan appropriate trails to accommodate this new facility. More use necessitates more trails, especially during events so that the general public is not displaced.

3. Consider Road to Trail conversion

COTA feels that there is opportunity to convert some existing closed and / or open roads to trails to satisfy the need for more beginner trail inventory. Also, some sections of existing ?most difficult? rated trail are actually ?easiest? compliant. Several sections of proposed trail 3c meet this criterion, and this will necessitate re-routing corresponding sections of COD to segregate these two trails. Again, COTA will work closely with FS Recreation staff to determine the best, most logical options on the ground, but we simply want to point out that there is a potential for road to trail conversion, and to include this in any Proposed Actions and future funding requests.

Reducing road inventory can have multiple benefits to wildlife, it aids in the prevention of the spread of invasive species and it reduces illegal (out of season) motorized use. Removing roads has benefits, but so too does creating trails. Healthful economic, social and volunteer stewardship benefits are very well documented.

4. Reducing the need for new trail Junctions

The trail systems West of Bend already have a plethora of trail junctions and the numbering system for these is working well although there are junctions numbering up to 60?s.? Damaged or inadequate junction post signage is becoming a maintenance issue, which COTA is challenged to address. On the Scoping letter map Inset page, the proposed new trails seem to indicate the need for two additional trail junctions (trails 3b & 4, and 3c & 3d). We have found that too many junctions, too close to each other can lead to confusion. Again we see the solution is with further ground-truthing and with changes to proposed trails designed, as described above in #2.

Whenever possible, future trails should tie in to existing trail junctions to reduce construction effort and expense. Changing the small placard signs on existing junction posts is a project COTA is already engaged in. This has the added benefit of ?more efficiency? and fewer signs in the forest. COTA prefers the aesthetic of less signage whenever possible.

5. Retain and improve the ?Most Difficult? trail options

A majority of COTA?s constituency and membership have requested more options for advanced riding opportunities. Since this proposal only creates new beginner trail opportunities it does nothing to address this need. It is important to COTA, our 500 members and thousands of constituents that ?advanced? riding options be preserved or enhanced. COD is one such opportunity. This is why we expressed alarm when the Welcome Station (and expected day-use from there) was proposed in April 2010. Retention of ?most difficult? riding is one of COTA?s top priorities.

This is a concern because, as we?ve seen over and over again, difficult obstacles are very often removed or skirted by trail users that cannot meet the challenge. This is extremely frustrating to those who have worked on these trails and are able to ride them. It?s best if clear alternative trails are provided and difficulty ratings are clearly marked so that these challenging trails are preserved. COTA is committed to preserving these ?most difficult? trail opportunities.

Fortunately, within this project proposal there are several ways to enhance advanced riding opportunities: 1. Reduce the possibility for beginner riders to enter advanced trails, 2. Enhance the COD trail itself for advanced riding and 3. Create re-routes to COD to provide a more consistently difficult trail. Of these options, number 1 is achievable with proper planning. COTA has identified several key areas on the existing COD trail both to the North East and West of the Welcome Station where we can increase the difficulty rating so that we can achieve a consistent ?most difficult? rating along the trail, meeting an indentified need. In implementing this project COTA cautions the Forest Service to consider the unintended consequences of linking beginner to advanced trails without beginner loop options.

Thank you for your consideration of these comments.

Woody Starr, Chairman for

Central Oregon Trail Alliance

P.O. Box 555

Bend, OR

97709

http://cotamtb.com/

Source: http://cotamtb.com/2013/usfs-proposes-new-trails-comments-requested/

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