BARK
PO Box 12065
Portland, OR 97212
www.bark-out.org
503.331.0374
Michelle Lombardo
Mt. Hood National Forest
16400 Champion Way
Sandy, OR 97055
RE: Scoping Comments re Road Decommissioning in Zigzag Ranger
District
October 12, 2009
Dear Michelle,
The following are Bark’s comments in regard to the proposed Zigzag
Road Decommissioning.
Travel Planning Generally
Bark appreciates the efforts of the Forest Service to identify and
decommission unneeded roads in Mt. Hood National Forest and specifically in the
Zigzag Ranger District. In particular,
we are pleased that the survey of roads to consider for decommissioning included
those that lead to forest stands that the agency intends to harvest in the
future. We understand that it is a large
undertaking to collect this information, but believe that it lends more
credibility to decision-making and improves the quality of data that exists on
the road system. Exempting these roads, as was done in the 2009 Clackamas
Aquatics Restoration EA, is a sure way to miss roads at risk of significant
aquatic impacts. In addition, it ensures
that the forest road system remains unsustainably large and is not brought
within the fiscal constraints of the Mt. Hood budget. That said, we remain concerned about how the
piecemeal approach to road decommissioning in Mt. Hood National Forest will fit
with the directive of the travel management rule.
The Travel Management Rule mandates identification of a minimum
road system in each and every national forest. Unnecessary roads should be decommissioned.
“For
each national forest, national grassland, experimental forest, and any other
units of the National Forest System (§212.1), the responsible official must
identify the minimum road system needed for safe and efficient travel and for
administration, utilization, and protection of National Forest System lands…” Roads “that are no longer needed to meet
forest resource management objectives… should be decommissioned or considered
for other uses, such as for trails. Decommissioning roads involves restoring
roads to a more natural state…. Forest officials should give priority to
decommissioning those unneeded roads that pose the greatest risk to public
safety or to environmental degradation.”
36 C.F.R. 212.5(b). Mt.
Hood National Forest has opted to instead focus on decommissioning roads in
five increments. While the result of
this process will be a significant improvement over the status quo, the Travel
Management Rule’s mandate to identify a minimum road system will still require
fulfillment. The Travel Management Rule
clearly states that the identification of roads and their respective purpose
shall be a deliberate process,
(a) General criteria for designation of
National Forest System roads, National Forest System trails, and areas on
National Forest System lands. In designating National Forest System roads,
National Forest System trails, and areas on National Forest System lands for
motor vehicle use, the responsible official shall consider effects on National
Forest System natural and cultural resources, public safety, provision of
recreational opportunities, access needs, conflicts among uses of National
Forest System lands, the need for maintenance and administration of roads,
trails, and areas that would arise if the uses under consideration are
designated; and the availability of resources for that maintenance and
administration.
36 C.F.R. 212.55. The
current process prioritizes road decommissioning based on risk to aquatic
resources, with the exception of the “decommission with delay”
categorization. However this is all that
it accomplishes. After the 5 increments
are complete, will the resulting system be a conglomeration of roads that are
not immediately threatening aquatic ecosystems?
Or will it be a system that meets the needs outlined in the Travel
Management Rule? The EA should address how this incremental process will fit in
to ultimate mandate of the Travel Planning Rule, the identification of a
minimal road system.
Bark suggests two ways that the Forest Service work to make the 5
increment process include other management objectives:
1)
Include descriptions in
the EA of the purpose served by the remaining (post-implementation) road system
and how it relates to the road system elsewhere in the Forest.
2)
Include in the EA an
assessment of “the need for maintenance and administration of roads, trails,
and areas that would arise if the uses under consideration are
designated…” Bark proposes one simple
method for this analysis below.
Use the 1999 Access and Travel Management Plan (ATM) to make the
process more efficient
The 1999 ATM was “intended to analyze the desired future condition
of our travelways on the Forest.” The
ATM is the proper starting place for decisions on roads to be based. The plan is responsive to the Northwest
Forest Plan and the Mt. Hood Land and Resource Management Plan. It deliberately identifies those roads that
have a specific purpose, and suggests closures/obliteration for those that do
not.
One significant inconsistency between the Zigzag Road
Decommissioning and the ATM is the use of the words “decommissioning” and
“decommissioning with delay” prescriptions instead of the ATM “close” or
“obliterate” recommendations. The ATM
definition of these roads, and the basis for those roads that show up grey in
the attached map, is described in the ATM.
Closed Roads or Roads Available for Closure or Obliteration. Closed roads are closed to
traffic, but remain on the road system.
These roads have an identified future use (generally within seven years).
Roads needed for future timber harvest activities or fire protection
efforts would fall into this category.
Roads identified for obliteration have no identified future use (generally within ten years) or are a high risk for
resource damage. Need for closure or
obliteration exceeds funding, so roads at highest risk for resource damage or
other important resource concerns are closed or obliterated first. Roads not funded for closure or obliteration
will naturally close due to lack of maintenance over time. Some of these roads may be converted to
trails if identified in the Forest Trail Management plan.
ATM at 9 (emphasis added). Literally, the ATM recommendation is that
roads that will not be used in 10 years are candidates for “obliteration.” If
funding was available and the ATM had been implemented, Mt. Hood National
Forest would have reduced its road system nearly 49% by this year. Instead, the use of “decommission with
delay” in the Zigzag project is a defacto extension of this timeline, and does
not respect the urgency of reducing the road system which was identified as a
priority in 1998 by Forest Service Chief Mike Dombeck and subsequently ratified
in the Travel Management Rule described above.
In 2008 Bark, the Clackamas Stewardship Partners, and watershed
advocates throughout the Pacific Northwest rallied around Congressman Norm
Dick’s Legacy Roads and Trails Remediation Act, which began providing dedicated
funds for road removal that same year.
Bark recommends that the Forest Service adopt the ATM-recommended
prescriptions in the Zigzag project and all future road decommissioning
projects.
1)
Roads that are needed for
resource goals in the next seven years, but are not necessary to be opened to
traffic will be closed using a gate or berm and trap and boulders.
2)
Roads that are not needed
for resource goals in the next ten years will be obliterated, using active
techniques such as decompaction, slope recontouring, culvert removal and stream
channel recontouring, and replanting.
Understanding that funding for this work became available and has
continued since 2008, Bark recommends that Mt. Hood National Forest reset the
clock and use 2008 as the starting point for the 7-year and 10-year thresholds. While this is the equivalent of a nine-year
delay in the recommendations contained in the ATM, it appears to be a
reasonable course of action. It ensures that
the ongoing ecological impacts and taxpayer burden of the road system will be
addressed in a timely manner and will not be subject to arbitrary and seemingly
indefinite delays.
Need clarification of prescriptions
Bark requests that the Forest Service use the term “close” to mean
the use of active or passive means to close the point of entry to a road. This includes building gates, earthen berms,
“tank traps,” and allowing natural vegetation to hide the entrance. The purpose of closing a road, as described
in the ATM, is to keep roads on the road system that should be closed to
traffic but will be needed for future activities (generally within seven
years). “Obliteration” is the
recommended term for blocking all vehicle use and minimizing the road’s hydrologic impact to the extent feasible,
with no expectation for future use. Bark recommends that proper obliteration
include the following:
1)
Reestablishing former drainage
patterns, stabilizing slopes, removing nonnative species and restoring
vegetation;
2)
Removing the roadbed by restoring
natural contours and slopes;
3)
Removing culverts, reestablishing
drainage-ways, removing unstable fills, pulling back road shoulders, and
scattering slash on any remains of a roadbed.
As Bark raised in its comments on the Forestwide Aquatics
preliminary assessment published in 2008, and has raised at multiple
face-to-face meetings with Mt. Hood staff, it is critical that the Zigzag EA
include specific prescriptions for action on those roads it is recommending for
closure or obliteration. Bark believes
that this is important for the Forest Service to meet its requirement for a
“hard look” as required by NEPA, otherwise the impacts of the action cannot be
adequately considered. The importance of
this information may not be conspicuous when looking at the individual maps
provided in this one increment of the process.
The Clackamas River watershed provides an illustration of this
point. If the Forest Service
“decommissions” 1,000 miles of road in the Clackamas watershed, yet the
decommissioning does not include decompaction and revegetation of the roadbed,
it will have a dramatically different impact on the watersheds ability to
infiltrate runoff than if it did include these activities. Bark expects that the upcoming EA will
address this discrepancy by outlining specific actions and analyzing their
impacts.
Method for analyzing future maintenance burden
The 2003 Roads Analysis states that Mt. Hood National Forest’s
road system could be reduced by nearly 50%. This is based on the 1999 Access and Travel
Management map.
Although
at first blush 50% sounds like an aggressive amount of road removal, taxpayers
need the Forest Service to adjust this number based on site-specific
information. In reality this number may
be 65%, or it may be 35%, it is depending on what is required to “maintain all
roads so they function properly” as described in the scoping letter. Bark suggests the following as one method for
determining this number:
1) Determine the percentage of
roads maintenance funding that can be dedicated to the project area. This is best accomplished by road maintenance
category, and is simply the mileage of each category road in the project area
divided by the total in the forest. For
example, if there are 100 miles of category 2 roads in the project area, and
there are 2,000 forest-wide, then on average it can be expected that 5% of the
forest roads budget for category 2 roads will be spent on roads in the project
area.
2) Take the average of the last 5
years of road maintenance funding and multiply it by the percentage determined
above to predict future road maintenance funding for the project area. For example, if the average road maintenance
budget for the entire forest over the last 5 years is $1,000,000, then multiply
it by your percentage above, 5%, and it can be reasonably predicted that
$50,000 will be available for ongoing maintenance of the roads in the project
area after implementation of road decommissioning activities.
3) The resulting road system in
the project area should be of a length and categories that it will be under or
near this ongoing maintenance level.
Our concerns also lie in what might still be missing by not
utilizing the procedures described in the Travel Management Rule. The Rule
requires that, “[i]n
determining the minimum road system, the responsible official must incorporate
a science-based roads analysis at the appropriate scale and, to the degree
practicable, involve a broad spectrum of interested and affected citizens,
other state and federal agencies, and tribal governments.” 36 C.F.R. 212.5(2)(b)(1). For instance,
without broader outreach to the recreation community, the Forest Service may
make decisions that would adversely impact this community. By reaching out to a broad community of
stakeholders, the Forest Service will be able to garner support and public
confidence in this important restoration effort.
Site specific recommendations
Wildcat Mountain area:
The Wildcat Mountain area has a long history of illegal activities
including shooting, dumping, and ATV use.
The impact of these activities is in clear conflict with the legitimate
and high-level of recreational use that the area experiences and the supply of
clean drinking water to the City of Sandy.
The City of Sandy holds water rights on the Alder Creek watershed
for providing drinking water to its residents.
The protection of the quality and quantity of this supply should be an
absolute priority for the Forest Service.
In order to ensure the highest level of protections for the Alder
Creek watershed Bark requests that the Zigzag project include immediate road
decommissioning for roads 3626-114, 3626-107, 2609-150, and 2609-140,
regardless of their timber potential.
It is worth noting that 2609-140 was recently utilized for the Wildcat
Thinning CE, and the remaining plantations adjacent to the road can be accessed
from Rd 2609 proper. In the meantime,
the end of 2609-140 is a known dumping shooting site, as shown in the picture
below.
PHOTO: End of 2609-140, taken prior to logging of Wildcat Thinning
CE.
In 2003 the “Teachers in the Woods” completed a survey of illegal
ATV routes and found 6.7 miles in the Wildcat Mountain area. Bark does not have the raw data from the
survey, and we aren’t able to overlap the map provided in the publication with
the road system. Bark has attached
the Teachers in the Woods publication to our comments and would ask that any
roads under consideration in the Zigzag project that are being used to access
illegal ATV routes be decommissioned immediately. For mainline roads such as 3626 and 2609,
Bark recommends mitigating damage from off-highway vehicles through legal
closures, boulder placement, and increased law enforcement.
To improve the recreational experience, Bark supports the
recommendations of the Trailkeepers of Oregon to establish a new McIntyre Ridge
trailhead and new Wildcat Mountain trail.
Unlike TKO, Bark has a long history of monitoring road closure
effectiveness and is aware that closing a road using devices such as gates or
berms is often ineffective against illegal use by ATVs. Therefore we recommend active obliteration
of the following roads to compliment the recreation goals identified by TKO: Road 3626 beyond
the Road 108 junction, Road 105 be closed at the junction with Wildcat Mountain
Drive (Forest Road 12), thereby closing all of the spur roads that branch from
Road 105.
A discussion of how Bark believes that the 1999 Access and Travel
Management Plan (ATM) can be used to address the road system can be found on
page 3 of these comments. Below is copy
of the ATM map displaying those roads in the Wildcat Mountain area that have
been recommended for closure or obliteration since 1999. Consistent with Bark’s suggestion that a
reasonable alternative to indefinite delays is to reset the clock at 2008, when
funding for road closure and obliteration became available, we suggest that the
upcoming EA propose “closing” roads that are needed for resource goals in the
next 6 years, and propose “obliteration” for those roads not needed for any
resource goals in the next 9 years. This
would apply to all of the roads currently included in the scoping letter,
except for those described above for protecting drinking water, improving
recreation, and stopping illegal vehicle access.
Zigzag Mountain area:
Bark does not yet have as intimate knowledge of the Zigzag
Mountain area included in this project.
We know that hikers use the 380 road beyond the blowout and would
suggest that the Forest Service consider a formal road-to-trail conversion for
the 380 and 382 roads.
A discussion of how Bark believes that the 1999 Access and Travel
Management Plan (ATM) can be used to address the road system can be found on
page 3 of these comments. Below is copy
of the ATM map displaying those roads in the Zigzag Mountain area that have
been recommended for closure or obliteration since 1999. Consistent with Bark’s suggestion that a
reasonable alternative to indefinite delays is to reset the clock at 2008, when
funding for road closure and obliteration became available, we suggest that the
upcoming EA propose “closing” roads that are needed for resource goals in the
next 6 years, and propose “obliteration” for those roads not needed for any
resource goals in the next 9 years. This
could result in the immediate obliteration of 1828-125 and/or 1828-021.
Additional recommendations
While Bark continues to urge the Forest Service to comply with the
Travel Management Rule, we have also been engaging in this alternative
direction by the Forest Service. We are particularly impressed by this year’s
data gathering effort, and hope that it results in the most informed
decision-making possible. In the
forthcoming EA please include the data gathered on the road system in a format
that is readable.
An explanation of likely sources of funding for this project
Bark does not support the promotion of commercial timber sales as
a means to fund restoration efforts such as this one. In the past Bark has been involved in the
Clackamas Stewardship Partners, which has recommended the use of logging
receipts for road decommissioning. Coupling
the commercial timber sale program with restoration projects such as this one may
provide short-term funding solutions, but is not sustainable over time and Bark
would like to see an active effort on the part of Mt. Hood National Forest
staff to become less, not more, reliant on this type of funding.
Analysis of the impacts of this project on the recreation
community
The scoping letter does not address the process by which
recreation groups (mountain biking, hiking, horse riding, etc.) will be
consulted. Because the Zigzag district
is cherished for its excellent opportunities for quiet recreation, we look
forward to an analysis of how this project will improve recreation
opportunities, and also how it will adversely impact some opportunities.
We look forward to working with the Forest Service and participating
in this process to ensure the effective implementation of road decommissioning
efforts. Please contact me if you would like further clarification on our
comments or to further discuss the issues we have raised.
Sincerely,
Lori Ann Burd
Restore Mt. Hood Campaign Manager
Bark