Stewards of the Sequoia: Greenhorn OHV Inventory comments

[Ed A. Stevens]

The final version of the Stewards comments on the initial OHV Route
inventory of the Greenhorn district

STEWARDS OF THE SEQUOIA
Division of CTUC 501c3 non profit
PO Box 267
Lake Isabella, CA 93240


November 16, 2004


Sequoia National Forest
Norm Carpenter
900 West Grand Avenue
Porterville CA 93257-2035



Re: Comments on Greenhorn District trail designation

Please incorporate these comments into the record and carefully consider
our suggestions regarding the creation of the designated multiple use
trail system in the Greenhorn district of the Sequoia National Forest.

Stewards of the Sequoia is a group promoting responsible motorized
recreation & environmental stewardship. We are recently formed & our
members volunteered over 400 hours on trail work in the Keyesville area
during March. Our members are diverse. Most have been enjoying the
Greenhorn district for decades & are extremely knowledgeable about the
area. Many of these members have donated thousands of hours working on
local trails over the decades. Many have enjoyed motorized recreation
here for up to five decades, while others are new to the area. Most of
our members are also members of other organizations such as CORVA & Blue
Ribbon Coalition.

NO MAPS
It was regrettable that the Forest Service decided at the last moment to
not provide inventory maps to the public at the 9/22/04 inventory
meeting. Many users drove several hours to attend the inventory meeting
& expected to have maps that they could review at home or on the trails
to verify if all the trails had been included. The last minute change by
the forest service makes it very difficult for the public to be
involved. It is unreasonable to ask users to drive hours to return &
look at maps in forest service offices during business hours.
Alternately it is impossible for users to me! morize h undreds of miles of
trails & make any meaningful comment. It is fortunate that the forest
service responded to lobbying efforts & has allowed the maps to be
released. It is unfortunate that forest service chose to charge $30 to
public as well as public benefit & non profit groups such as Stewards of
the Sequoia. We are not aware of any other planning process in which
documents or maps have been charged for. Regarding other forest plans,
we have received at no cost, forest documents in excess of 500 pages
including maps. The choice to charge for trail inventory maps creates a
precedent for the forest service. It has made it so that the public
cannot be as involved as in other public processes & would indicate a
desire by the forest service to reduce or eliminate public involvement
in the trail designation process.

OVER 50 TRAILS MISSING
After spending considerable time reviewing the inventory maps which
Forest Service charged $30 to Stewards of the Sequoia we have found the
following trails to be missing:
On Greenhorn & Breckenridge Maps:
TRG22 Portuguese Trail Spur A
TRG22A Portuguese Trail Spur A Fork A
TRG23 Manzanita Trail
TRG26 Virginia Trail
Single track that starts at the end of 31E83
Various dead end spurs east of Sunday Peak
Trail behind Greenhorn Summit Gravel Shed that connects to 24S15 at
intersection with 25S16 & then continues to Manzanita Trail
Several single tracks south east of Greenhorn Summit down to 26S20 &
over to Black Mountain Saddle
Trail from Black Mountain Saddle east
Single track from 24S35B to 25S11
Eight single tracks off 25S11
Single track that starts off 23S16 north of Panorama campground & runs
south to 23S15
32E46 Just Outstanding
Two connectors off Just Outstanding
32E42 Borderline 4x4 trail
32E56 Brown Mill 4x4 trail
32E47 Bradshaw 4x4 trail
TRG12
26S04A
26S03
TRG3B Old Delonegha 4x4 Spur B
31E2! 2 Delone gha 4WD Trail, long section of trail
TRG5 Tucker Canyon trail
TRG6 French Ranch 4x4 trail
Trail to lookout off Mill Creek
Trail off 31E78 to Lighteners Flat
Another trail off 31E78
Trail from 32E58 north to Black Gulch
Another trail from 32E58 west of above going north
Trail from Breckenridge Mountain Lookout south down to other trail on map
Trail from Oak Flat Lookout directly down to Rancheria Road
Trails that follow along Rancheria Road from Badger Gap to east

On Piute Inventory Map:
TR66 Top Trail
TR23A
TR47
Single track from Brown Peak to 33E45 near TRG3
Single track from TR9 to 33E44
Trail paralleling Saddle Spring road & ending at TRG6 with a connector
midway to 33E68
Connector near start of Woolstalf Meadow trail going to trail to north
TR53B
TR12
TR58 Glen Olive Mine trail

We had understood that this inventory was supposed to include everything
on the ground. This apparently is not so. We have been told that the
guideline given to forest service GPS crews in making the Sequoia trail
inventory, was that any trail that did not have a track on it would be
omitted from the inventory. Is this the standard guideline for all
forests? It seems highly questionable, especially since much of the
inventory was done in the spring when snow will have erased most tracks
& prior to riders going on the trails.

PRIOR INVENTORY WAS INCLUDED?
In a letter dated 11/4/04 to Stewards of the Sequoia from District
Ranger Freeland responding to our question of whether the Baskin
inventory was included in the official inventory. He states “The team
who conducted the OHV inventory for the Greenhorn Ranger District was
given a copy of Recreation Officer Baskin’s work”.
It is therefore astonishing that at least 21 of the missing trails
listed above were included in the GPS Inventory that was done by Baskin.
These trail have numbers as well as names. What is the reason for the omiss ion of documented & numbered trails from the inventory that is
supposed to include everything on the ground?

It is reasonable to expect that some unknown trails might be missed in
the initial inventory. It is not reasonable for the inventory to miss 21
trails that have numbers & are on forest service maps.

In an email dated 10/12/04 to Stewards of the Sequoia from Mark Stevens
Regional Mapping Coordinator Pacific Southwest Region 5. He states:
“Dave Baskins did do a lot of work on the Sequoia, and for reasons
beyond our control Dave could not finish so I expanded the existing
contract I had on the rest of the Forest to finish off Dave's area with
the recommendation from the Forest, and to the best of my knowledge the
work Dave had completed is being used by the Forest“.

Apparently the Mapping team thought that the forest was going to include
the Baskin inventory in the final inventory & the District Ranger
thought that the Mapping Team was going to include them.

There are seven trails mentioned in the Greenhorn 2004 Operations &
Maintenance report, page 26, as the MAJOR 4WD trails on the district. It
is most surprising that three of them were omitted from the inventory:
32E42 Borderline 4x4 trail 6 miles
32E56 Brown Mill 4x4 trail 4 miles
32E47 Bradshaw 4x4 trail 4 miles
All three were included in Baskin’s prior inventory.

None of the non system routes marked on the inventory map have any
numbers. There are over 118 trails that should have TR numbers if
Baskin’s inventory had been used as a guide. It seems likely that the
mapping team was never given Baskin’s inventory which would have saved
considerable time, effort & money. How else can 118 missing trail
numbers & 21 missing trails that were on Baskin’s inventory be explained?

It is reasonable to expect that the forest service would have at least
one of their staff that is knowledgeable with the Greenh! orn trai ls, go
over the maps & check for accuracy, in which case many of these
omissions would have been caught. After all they were on their prior maps.

OHV USE IS GROWING & BEING FORCED ONTO A SMALLER TRAIL SYSTEM
The Forest Service has recognized in numerous publications that more &
more families are turning to motorized & mechanized recreation as their
way to enjoy the outdoors. That this is a valid form of recreation on
forest service lands. The proposed trail system must take into
consideration the need to make up for the massive closures of multiple
use trails in the neighboring areas through wilderness designation as
well as the proclamation of the Sequoia Monument. These closures have
caused a loss of hundreds of miles of single track trails as well as
roads. Motorized & mechanized use is on the rise & the forest service
will not be fulfilling their mission of providing recreation
opportunity, if they do not expand the existing multiple use trail
system to provide for that need. The forest service also needs to open
more trails to reduce the unacceptable impact, as well as increased
trail maintenance cost, that has resulted from forcing the motorized &
mechanized users onto a smaller & smaller trail system.

In order to provide for future as well as current users the forest
service should use the trail designation process to start work on
building new trails to create loops, as called out for in forest service
documents. Such as at the lower end of Remington & Mill Creek

The Forest Service cannot legitimately address increasing demand for OHV
recreation opportunity by refusing to accommodate such demand.
Alternatives must prudently provide for increased OHV recreation
opportunities to meet current and anticipated demand.

There is a mechanism already in place to specifically maintain the past
total mileage of trails & thereby prevent loss of tot! al trail mileage
caused by reclassification of adjacent areas as wilderness or monument.
Per the 1990 Sequoia Mediated Settlement on page 103, “As inventoried or
pre-existing trails are closed, “compensation credit” shall be assigned.
“Compensation credit” represents the net benefit or value gained from
the closure. One action can provide credit for another action. The
credits can be held in check until needed. The banking of credits, in &
of itself, does not drive the Sequoia Forest to seek additional
opportunities. The goal is to keep track of gains & losses.”

According to the above the forest service has been keeping track of
trail & road losses. What are the total trail losses & total of road
losses to motorized use?

Some of us have grave concerns that this trail designation process is
flawed & is driven by a closure bias.

This trail designation process is the time to address the massive
closure imbalance & to cash in as many of the closure credits as
possible. Approximately 90 miles of single track trail was recently
closed without public process in the Tule/Hot Spring district by
proclamation of the monument alone.

This brings up five points:
1) In spite of a documented increase in popularity of OHV recreation,
the Forest Service is planning on reducing opportunity in areas adjacent
to the planning area.
2) The only purpose of this designation process is to close trails. This
will only cause greater resource damage.
3) At no point in the current designation process is there any
requirement to open more trails to allow for current increasing need or
future increasing need. By not doing this forest service is creating
resource damage by forcing too many users onto too small a trail system.
4) The fact that ample opportunities for non-motorized recreation in and
adjacent to the planning area must be disclosed to the public and
incorporated into the analysis! .
5) The Forest Service must disclose and analyze the effects of reducing
recreational opportunity in areas adjacent to the planning area and
attempt to quantify and disclose those impacts within this process.

NEED TO OPEN MORE TRAILS
There appears to be no mechanism within the trail designation process to
open more trails to reduce resource damage by spreading the use out.
The carrying capacity of the trail system should be determined & the
trail system designed to handle future user loads. There are a number of
large housing development projects of known size that are approved or in
the process of being approved in Bakersfield & other nearby areas. Per
the CA state Parks study as of 2001 almost 20% of CA households enjoy
motorized recreation. These numbers should be used to determine a
baseline future user load & then design a trail system that is large
enough to handle this increase in users.

One way to reduce the cost of trail maintenance would be to open more
trails & spread the impact of the users per mile of trail.

There appears to be a preconceived notion on the part of the forest
service that closing trails to multiple use will be good for the
resource. That is not true. Closing trails while maintaining the same or
increased user numbers will cause more resource damage. This must be
addressed while designating trail systems.

NET LOSS OF TRAILS
According to the 1998 Record of Decision Sequoia Land & Resource
Management Plan page 15, there were 475 miles of multiple use trail less
than 24”. Today according to the most recent grant funding reports there
are about 330 miles. A net loss of 145 miles of single track multiple
use trail. According to the same record of decision on page 17, that 21
miles of new multiple use trail would be constructed per decade & that
this amount of new trail added to the existing trail system would be
inadequate to meet future d! emands.< BR>They were correct.

District Ranger Freeland has stated in a letter dated 9/22/04, that the
method of calculating trail mileage was very inaccurate in 1998. That we
have more miles of trails now than we had in 1998. This is not possible.
It is quite possible that they severely underestimated the trail mileage
back in 1998. There is no doubt that staff knew the trails on the ground
& their carrying capacity, whatever the mileage might be. The 1990 ROD
stated that there would not be enough trails for future motorized users.
No matter the actual mileage, staff knew the actual trails were
insufficient for future use. After that, many miles of trails were
closed by recent wilderness & monument designation without any public
input. Most importantly the trails that were closed offered far greater
loop potential, something that the forest service guidelines currently
encourage. The closed trails also offered a much higher quality outdoor
experience. This needs to be addressed by the current trail designation
process, but it is not.

According to that plan, today there should be 475 miles of single track
trail, plus 31 miles for the one & a half decades of new trail building
that as never done since 1998. We should have 506 miles of single track
trail today. Also on page 17 it stated that, “trail construction over
the next ten years would be increased in recognition of a demonstrated
need to improve the system of trail connecting facilities & providing
loop opportunities“. This was not done. Where any new trails built at
all? Instead the trail system was further reduced & loops were cut off.
There would appear to be nothing in the mediated settlement of 1990 that
contradicts or changes any of the above statements from the 1988 record
of decision. Therefore the forest service has not followed its own
guidelines of the 1988 record of decision to maintain all existing
trails as w! ell as b uild new trails. The current trail designation plan
is the place to remedy some of these past errors.

CURRENT TRAIL DESIGNATION PLAN FLAWED
While we are not there yet, it seems that the trail designation process
is following many of the wrong paths that caused the Roadless Rule to
fail. In the decision handed out by Justice Brimmer he notes on:
page 14 the forest service maps do not contain the best available data
page 47 forest service made a self imposed deadline made prior to
beginning scoping
page 50 forest service adopted a top down approach
page 62 consider only alternatives, such as eliminating road
construction, that protect roadless areas. This created a premise that
any road construction would degrade the desirable characteristics
The current trail designation process assumes that trails must be closed
to protect the environment. The forest service has repeatedly stated
that OHV use is valid & growing. Yet closing trails will force more
users onto fewer miles of trails. This will create damage unnecessary to
the trails. Therefore the current process should be designating a trail
system which can handle current as well as future OHV needs. This would
require the current process to address opening more trails to handle
user capacity.
The current trail inventory is on self imposed arbitrary
deadline/timetable set by the forest service. The Sequoia inventory was
released on 9/22 in a ready or not fashion. The maps are inaccurate,
there are no maps available on the forest website, no maps available for
the public. The public did not request the trail designation, the forest
service decided it was needed. Why is the forest service forcing this
process on a fast track through the public process? Forcing it like a
square peg in round whole?

Chief Dombecks recent speech on OHV use Rising to the Management
Challenge stated that 36,000 miles of trail are open to OHV use, or
about ! 28 perce nt of the total national trail system.
Yet OHV trail users represent more than 28 percent of the users &
growing. More trails need to be opened to multiple use to address this
imbalance. Of course these multiple use trails would be open to all
users, so they would allow for other users as well.

PLENTY OF TRAILS FOR THOSE WHO WANT TRAILS ALL FOR THEMSELVES
For those foot & horse users who are intolerant of other users, they can
enjoy sole use of the nearby massive amount of trails that used to be
open to multiple use, in what is now wilderness & monument.
One of the most common reasons for trail closure to motorized &
mechanized use is user conflict. While there certainly are users that
are too intolerant to share trails, it should be noted that the majority
of foot & horse users are willing to share multiple use trails. The
tolerant majority are happy with the way things are & are far less
likely to bother making a comment during the public process. However the
minority who are intolerant have everything to gain by complaining &
making comments stating their intolerance. These intolerant comments are
not a true indicator of the majority of the public’s desire to share
more trails. The majority of motorized & mechanized users are happy to
share multiple use trails with everyone. Our motorized members have
noted that only one out of every ten foot or horse users on the trail
are unhappy to see them. In talking with equestrian members of
Backcountry Horseman, many have commented that they have no problem
sharing multiple use trails.

“CONFLICT OF USERS” NOT “USER CONFLICT”
We were also told at a 9/22 meeting with forest service that a coarse
sieve would be used by the district ranger to determine temporary
closures. It would include “user conflict“. That is a very vague factor.
I doubt anyone can even define what a valid user conflict is. Does one
person compla! ining or ten or a hundred constitute user conflict? Does
ten people who have never been to the Sequoia's complaining constitute
user conflict. Can a anti access group that is based somewhere outside
the Sequoia area complain & constitute user conflict? If ten people
complain about a thousand people's recreation is that a valid user
conflict? We hoped that the forest service would have already defined
very specific & realistic guidelines for temporary closures. User
conflict should not be one of those guidelines, also the temporary
closures should be truly temporary in nature.

John Stewart of United Four Wheel Drive Association has made a valid
point regarding the above:
“The entire Forest Service effort to inventory and designate routes is
driven by Executive Order 11644. That EO requires agencies to inventory
and designate routes and provides general criteria to accomplish the
process. One of the often cited criteria for determining suitability of
routes is the issue of "...user conflict..."
Please note, when you read EO 11644, there is a criteria for route
designation that states "...conflict of uses..." that is a valid
criteria for determining the status of a route.
With respect to comment attributed to the District Ranger, the lack of
definition coupled to the re-ordering of the words (and changing the
words) changes the meaning of the phrase "...conflict of uses..." to a
more subjective meaning of "...conflict of USERS...".
In this case (as used in the EO), the term "...uses..." is distinct with
its meaning "...the act or practice of employing something...". And, the
term "...user..." is distinct with its meaning "...one that uses...".
The term "...user..." does not appear in the Executive Order in the
context of establishing route suitability. As such, the district ranger
is in error citing "...user conflict..." as a reason to close a route.
There is no validity to that rational in the ! governin g Executive Order
11644.

The application of the phrase "...user conflict..." is also contrary to
the multiple use mandate of the Forest Service. The Forest Service has
acknowledged that motorized recreation is a valid "USE" of public lands
managed by the Forest Service.

OHV USERS FUNDS TRAILS
No other user group funds the recreation program directly. Yet OHV green
sticker funds are paying for multiple use trails that everyone can
enjoy. The forest service has repeatedly stated that it lacks funding.
Based on this clear ability of ohver’s to fund more & more recreation
each year, the forest service should open more trails to motorized use.
Since no other users except motorized users will directly fund trails,
the forest service should not be closing any trails to motorized use. No
other user groups have demonstrated as great a desire or ability to pay
for the trails.

OHV USERS HAVE TRIED TO REDUCE CONFLICT
According to the 1988 record of decision page 15,”OHV users have said
they do not want conflict and welcome compromise in the spirit of
working together”. Looking back it is apparent that ohv users have
continually compromised, while continually loosing recreation
opportunity. That the spirit of working together has not been
reciprocated by those who have furthered their agenda of public land
closure to multiple use. This must not be allowed to continue & flies in
the face of past agreements, decisions & arbitration.

FAMILY RECREATION
A large number of the users here are families that come to our area from
quite far away, such as San Diego, Los Angeles & other areas. In large
part because of public land closures in other areas these families must
travel this far to be able to enjoy their public lands. The forest
service needs to be sure that they provide for this very beneficial form
of family recreation. This allows parents to teach their children about the la nd, responsibility for themselves as well as to form bonds that
will last a lifetime.

TEMPORARY FOREST ORDERS ARE NOW THREE YEARS INSTEAD OF ONE YEAR
The Sequoia forest listing of proposed actions 2005 states that the
temporary forest orders closing multiple use trails or changing their
use to foot & horse only, will have a maximum life span of 3 years. In
the past temporary forest orders had a much shorter time frame of 120
days or perhaps one year. Three years seems excessive. It gives new
meaning to the word temporary. What is the chance of a trail being
reopened after three years? How will the remaining open trails be
damaged by the increased user load during the three years?


We would hope that the temporary forest orders will not be made until
after all trails have been adequately GPS'd & evaluated. If the missing
trails are not given the same attention then how can the district ranger
make a meaningful temporary order. It is not enough that he knows that
there are missing trails. He must also know what their value is to the
system.


Thank you for your time. We look forward to helping the forest service
designate the Greenhorn multiple use trail system, which can handle
current & future users loads & be enjoyed by everyone.





Sincerely,




Chris Horgan
Executive Director
Stewards of the Sequoia
sequoiastewards@earthlink.net

Promoting Responsible Recreation & Environmental Stewardship