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BUFFALO PASS TRAILS PROJECT:

RESPONSE TO COMMENTS

MAY 22, 2016

TABLE OF CONTENTS

INTRODUCTION ............................................................................................................................................................................. 1

ACRONYM KEY .............................................................................................................................................................................. 1

CULTURAL RESOURCES .............................................................................................................................................................. 1

ECONOMICS ................................................................................................................................................................................... 2

Economics- General ................................................................................................................................................................... 2

Economics- 2A Funds ................................................................................................................................................................ 4

Economics- Partnerships .......................................................................................................................................................... 8

Economics- Special Events ..................................................................................................................................................... 10

FIRE ............................................................................................................................................................................................... 10

NEPA ............................................................................................................................................................................................. 11

NEPA- Alternatives ................................................................................................................................................................... 11

NEPA- Environmental Effects .................................................................................................................................................. 13

NEPA- Forest Plan Consistency .............................................................................................................................................. 17

NEPA- Proposed Action ........................................................................................................................................................... 18

NEPA- Public Involvement ....................................................................................................................................................... 22

NEPA- Purpose and Need ........................................................................................................................................................ 23

RECREATION ............................................................................................................................................................................... 25

Recreation- Accessible Trails and Facilities .......................................................................................................................... 25

Recreation- Campgrounds, Parking, and Facilities ............................................................................................................... 26

Buffalo Pass Trails Project Response To Comments

Recreation- Closures and Rehabilitation ................................................................................................................................ 28

Recreation- General .................................................................................................................................................................. 28

Recreation- Hunting ................................................................................................................................................................. 29

Recreation- Maintenance and Enforcement ........................................................................................................................... 29

Recreation- Road Conditions and Traffic ............................................................................................................................... 33

Recreation- Signing and Public Education ............................................................................................................................ 34

Recreation- Special Events ...................................................................................................................................................... 35

Recreation- Trail Designation and Use ................................................................................................................................... 36

Recreation- Trail Layout and Design ...................................................................................................................................... 44

Recreation- User Group Conflicts ........................................................................................................................................... 51

ROADLESS AND OTHER SPECIAL AREAS ............................................................................................................................... 54

SOILS AND HYDROLOGY ........................................................................................................................................................... 60

SPECIAL USES ............................................................................................................................................................................. 62

THREATENED, ENDANGERED, AND SENSITIVE SPECIES ..................................................................................................... 62

VISUAL RESOURCES .................................................................................................................................................................. 64

WILDLIFE ...................................................................................................................................................................................... 65

Buffalo Pass Trails Project Response To Comments 1

INTRODUCTION Summarized and addressed below are specific written comments considered, including opposing comments and/or those that identify errors, potential issues, or recommended actions (36 CFR 218.2) from the thirty day comment period ending May 19, 2015. Supportive and neutral comments are not listed or analyzed here, but are considered in the decision and are included in the project record. Comments are grouped into similar categories. Letter # corresponds to the party that submitted the comment letter, which can be found in the Comment Response Key document in the project record. The Forest Service Response summarizes information that is included in the project record and Environmental Analysis. ACRONYM KEY

BA= Biological Assessment. FSH= Forest Service Handbook MRTB= Medicine Bow-Routt National Forest and Thunder Basin National Grassland

CPW= Colorado Parks and Wildlife. FSM= Forest Service Manual NEPA= National Environmental Policy

Act

CRA= Colorado Roadless Area. HPBE= Hahns Peak/Bears Ears Ranger District

OHV= Off-Highway Vehicle

EA= Environmental Assessment. IMBA= International Mountain Biking Association

PCA= Potential Conservation Area

COMMENT RESPONSE SUMMARY

Letter # Comment Forest Service Response

CULTURAL RESOURCES

79

1) Prior to any ground disturbance, all areas of proposed trail construction must be surveyed for cultural and historic resources, in compliance with the National Historic Preservation Act and the Archaeological Resources Protection Act. Any resources discovered must be protected until their

The Buffalo Pass Trails Project is in full compliance with all Federal and State laws and Forest Service policy, including completing surveys and incorporation of design criteria (EA, Appendix D) into the Proposed Action to avoid or reduce negative impacts to cultural resources. No actions will occur before SHPO concurrence is received on any trail.




eligibility for the National Register of Historic Places can be determined.

65

2) Pursuant to Section 106 regulations, fully consider the direct, indirect, and cumulative effects associated with the project. Reasonably foreseeable effects may include those associated with illegal trail construction/use and cross-country travel.

Pursuant to NEPA, potential direct, indirect, and cumulative impacts that may result from the Proposed Action are described in the EA (pp. 20-23). The Proposed Action includes implementation of a Closure Order on all wheeled-vehicle travel off of designated routes, in accordance with 36 CFR 261.55 (c). Forest Service policy already prohibits the construction (36 CFR 261.10 (a)) and maintenance of (FSM 2350.3.7) of non-authorized routes.

ECONOMICS

Economics- General

40 3) Analysis of economic impacts of this proposal

must be addressed under NEPA. Economic benefits that may result from the Proposed Action are described in the EA (p. 26).

17, 24, 43, 47, 61, 86,

89, 92

4) The proposed trail designation, which would exclude motorized use, will negatively impact the local economy. Multiple-use trails have a greater benefit to the economy than exclusive trails. The economic analysis of the Steamboat Springs Trail Alliance proposal, and that which directs where 2A dollars are being spent, is flawed.

Economic benefits that may result from the Proposed Action are described in the EA (p. 26).The Proposed Action adds 5.7 miles of multiple-use trail open to motorized use. No motorized routes are designated in the project area currently, so the proposed action is an improvement over existing condition. All proposed trails are multi-use trails, but not all trails are open to motorized use due to Forest Plan direction and user conflict. See page EA p. 6-9 for a more detailed description of the Proposed Action. The Recreation Resources report discusses existing use of the area, and potential conflicts.




Decisions regarding how the Steamboat Springs Trail Alliance and 2A tax dollars funds are used is beyond the scope of this analysis. The Forest Service is using 2A funds to meet public need and reduce management issues. Long term maintenance costs are of concern to the Forest Service, and Recreation Design criteria #5 (p. 69) was developed if identified partnerships and alternate funding do no materialize.

33, 56

5) The proposed action will negatively impact hunting and angling success, revenues, and the local economy.

Consultation with Colorado Parks & Wildlife (CPW) has occurred regularly on this project and recognizing existing recreation use in the Buffalo Pass area may have already affected big game and hunting success, CPW are generally in support of the project in this area versus other undeveloped areas on the Forest. The Aquatics Specialist Report determined that there would not be a significant impact to fish populations as a result of the Proposed Action (EA, p. 13). Therefore, angling success will not be impacted.

The Proposed Action trails are not anticipated to significantly impact hunting success, nor the resulting revenues and support to local economy. The majority of the trails on the north side of the Buffalo Pass Road are existing, so there will be very little new disturbance. On the south side of the Buffalo Pass Road, the majority of the trails are within ½ mile of the road. The trails in the Long Park CRA are on the edge of the boundary and affect an area of approximately 330 acres, leaving a significant portion (approximately 99.6%) of this roadless area undeveloped and available for wildlife and hunting.




56

6) Describe in detail what market the trails are designed to reach (locals, tourists, user types).

The trails are designed to meet the needs of a variety of trail users. Public input, from mostly local residents, requested a mix of difficulty levels for trails. The EA describes the mix of trail classes (TC) which meet a variety of difficulty levels (p. 8). The Recreation Specialists report discusses this in more detail. The Steamboat Trails Alliance, Bike Town USA and City 2A committee desire to market to outside visitors including recreation events. For more details on the Proposed Action, please refer to the EA, p. 6-9. Providing recreational opportunities for multiple user types is in accordance with Forest Service policy (FSM 2350.2.2).

Economics- 2A Funds

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7) Allocate 2A tax dollars to repair Buffalo Pass Road.

This decision is beyond the scope of the project. 2A Tax funds are designated as described in the 2A following ballot language in the November 5, 2013 Steamboat Springs General Election:

“Vote Yes or No on the following:

Shall the City of Steamboat Springs be obligated to a multiple-fiscal year obligation by allocating, for the next ten fiscal years, the revenues from the existing public accommodations tax (tax revenues), on a fiscal year basis, as follows: (A) The first $600,000.00 of tax revenues to be split on a 50%-50% basis between (I) the development of trails in and around the city in accordance with the trails alliance proposal and (II) improvements to Yampa Street in accordance with the Yampa Street River Park Proposal, until the total allocation to the improvements on Yampa Street reaches $900,000.00, thereafter 100% of the first




$600,000.00 of tax revenues shall be spent on development of trails; (B) the next $60,000.00 of tax revenues to be splint on a 50%-50% basis between (I) marketing of the tourist related improvements constructed with tax revenues and (II) reserves for the Haymaker Golf Course capital improvements; and (C) any tax revenues in excess of $660,000.00 may be spent at the discretion of city council on projects authorized by the 1986 Public Accommodations Tax ballot question.”

The trails alliance proposal referred to in the ballot language is summarized as, “accommodation tax funding is specifically requested to enhance multi-use recreation through new and improved natural surface trails, enhanced trailhead areas, safety improvements, and core trail extension for the benefit of all recreational users.” More information on the trails alliance proposal can be found at: www.steamboatspringstrails.com.

12, 66

8) Allocate 2A tax dollars to cover costs of enforcement and costs of trail closures and restoration. Those entities funding trails development have a responsibility to commit to their maintenance and enforcement.

This decision is beyond the scope of the project. 2A Tax funds are designated as described in the following November 5, 2013 ballot language:


Shall the City of Steamboat Springs be obligated to a multiple-fiscal year obligation by allocating, for the next ten fiscal years, the revenues from the existing public accommodations tax (tax revenues), on a fiscal year basis, as follows: (A) The first $600,000.00 of tax revenues to be split on a 50%-50% basis between (I) the development of trails in and around the city in accordance with the trails




alliance proposal and (II) improvements to Yampa Street in accordance with the Yampa Street River Park Proposal, until the total allocation to the improvements on Yampa Street reaches $900,000.00, thereafter 100% of the first $600,000.00 of tax revenues shall be spent on development of trails; (B) the next $60,000.00 of tax revenues to be splint on a 50%-50% basis between (I) marketing of the tourist related improvements constructed with tax revenues and (II) reserves for the Haymaker Golf Course capital improvements; and (C) any tax revenues in excess of $660,000.00 may be spent at the discretion of city council on projects authorized by the 1986 Public Accommodations Tax ballot question.”

The trails alliance proposal referred to in the ballot language is summarized as, “accommodation tax funding is specifically requested to enhance multi-use recreation through new and improved natural surface trails, enhanced trailhead areas, safety improvements, and core trail extension for the benefit of all recreational users.”

Mountain biking groups and partners have committed time and resources to help construct and maintain the proposed trails. The Forest Service and Routt County Riders have entered into a Challenge Cost Share Agreement in order to ensure time and resources to construct and maintain the proposed trails are available. The Yampa Valley Community Foundation has established the Trail Maintenance Endowment Fund to fund annual maintenance costs over the long-term. The combination of these options are designed to




allow development of the Buffalo Pass Trails with no or minimal costs to the Forest Service.

12

9) Allocate 2A tax dollars to cover the growing costs of game damage control on private lands incurred by CPW and sportsmen.

This decision is beyond the scope of the project. 2A Tax funds are designated as described in the following November 5, 2013 ballot language:


Shall the City of Steamboat Springs be obligated to a multiple-fiscal year obligation by allocating, for the next ten fiscal years, the revenues from the existing public accommodations tax (tax revenues), on a fiscal year basis, as follows: (A) The first $600,000.00 of tax revenues to be split on a 50%-50% basis between (I) the development of trails in and around the city in accordance with the trails alliance proposal and (II) improvements to Yampa Street in accordance with the Yampa Street River Park Proposal, until the total allocation to the improvements on Yampa Street reaches $900,000.00, thereafter 100% of the first $600,000.00 of tax revenues shall be spent on development of trails; (B) the next $60,000.00 of tax revenues to be splint on a 50%-50% basis between (I) marketing of the tourist related improvements constructed with tax revenues and (II) reserves for the Haymaker Golf Course capital improvements; and (C) any tax revenues in excess of $660,000.00 may be spent at the discretion of city council on projects authorized by the 1986 Public Accommodations Tax ballot question.”

The trails alliance proposal referred to in the ballot language is summarized as, “accommodation tax funding is




specifically requested to enhance multi-use recreation through new and improved natural surface trails, enhanced trailhead areas, safety improvements, and core trail extension for the benefit of all recreational users.” More information on the trails alliance proposal can be found at: www.steamboatspringstrails.com.

Potential impacts, including seasonal closures, to wildlife and private land owners were analyzed throughout the development of the Proposed Action. See EA p. 35-40. Consultation with Colorado Parks & Wildlife has occurred regularly on this project and recognizing existing recreation use in the Buffalo Pass area may have already affected big game and hunting success, they are in support of the project in this area.

40 10) Allocate 2A tax dollars to provide trails for

multiple-use including motorized. 5.7 miles of multiple-use route open to motorcycles is included in the Proposed Action, consistent with the Purpose and Need for this project.

Economics- Partnerships

40

11) The primarily non-motorized trail designation will fracture partnerships and compound current USFS budget issues.

Contrary to this thought, this project is allowing new planning and improvements for the motorized community and utilizes grants from CPW. The Forest Service will continue working with all users to continue implementing multiple-use across the Forest unit as a whole.

The Proposed Action is not anticipated to negatively impact the HPBE Ranger District’s budget. Mountain biking groups and partners have committed time and resources to help construct and maintain the proposed trails. The Forest




Service and Routt County Riders have entered into a Challenge Cost Share Agreement in order to ensure time and resources to construct and maintain the proposed trails are available. Additionally, the Yampa Valley Community Foundation has established a Trail Maintenance Endowment Fund to help financially support trail and trailhead maintenance. The combination of these resources are designed to make the Buffalo Pass Trails a no or low cost project for the Forest Service. If these opportunities do not materialize, Recreation Design Criteria #5 (p. 69) was developed to re-assess the project, and possibly removing trails.

Over the long term, the Forest Service will continue working with current partners and strive to develop new partnerships for additional funding and maintenance needs, such as developing an Adopt-A-Trail program with local businesses to ensure the sustainability of the trail system here and across the Forest.

24, 47, 60, 78, 84, 89

12) Trails may not be maintained because the mountain biking community has not funded or carried out the construction or maintenance of trails like the motorized community has with the help of vehicle registration fees and group efforts.

Mountain biking groups and partners have committed time and resources to help construct and maintain the proposed trails. The Forest Service and Routt County Riders have entered into a Challenge Cost Share Agreement in order to ensure time and resources to construct and maintain the proposed trails are available. The Yampa Valley Community Foundation has established a Trail Maintenance Endowment Fund to fund long-term maintenance costs. Over the long term, the Forest Service will continue working with current partners and strive to develop new partnerships for




additional funding and maintenance needs, such as developing an Adopt-A-Trail program with local businesses.

The concept of bike registrations is being considered by the State of Colorado to address this statewide issue. It is outside the scope of this analysis, but could be another funding source for long tern sustainability.

Economics- Special Events

14, 18, 30, 59, 70, 75-

77

13) Allow mountain biking events on the trail network and support outfitter/guides and outdoor educational programs by providing permitted uses. This will support the local and regional economy and revenue stream that is funding the project (i.e., Steamboat Springs 2A Initiative, 2% tax on lodging).

The 2A lodging tax is 1%, not 2%, on public accommodations of less than 30 days stay.

Consideration and authorization of future recreation events and special use permits in the area will occur on a case-by-case basis following Forest Plan direction for the appropriate Management Areas and Forest Service policy.

56, 80

14) Special events on the proposed trail network will result in overuse and environmental impacts.

Consideration and authorization of future recreation events and special use permits in the area will follow Forest Service policy, and Forest Plan direction for the appropriate in Management Areas. Requests will be analyzed on a case-by-case basis considering both social and resource impacts.

FIRE

82

15) The decision must describe fire danger and precautions that the Forest Service must take.

Fire Danger is a function of both fire hazard (vegetation) and risk (potential for fires to occur). The Proposed Action will not affect fire hazard. Natural fire risk is low in the project area, and increased users may increase risk slightly. Ongoing Forestwide fire prevention activities will continue to be effective to minimize human caused fire related impacts




through education and information. During times of high fire danger, restrictions of use will include this area as a aprt of the larger Forest.

NEPA

NEPA- Alternatives

32, 80, 82

16) A preferred alternative should be analyzed that would have minimal impacts to wildlife, plant communities, and quiet users in the Mad Creek and Long Park roadless areas.

A preferred alternative is not a required component of Environmental Assessments (36 CFR 220.7(b)).

Impacts to the two identified Colorado Roadless Areas (CRA), (p.16-20), plants (p.13-16), recreation (p. 23-27), and wildlife (p. 34-40) are analyzed in the EA/Specialist Reports for all of the alternatives. Design criteria (EA, Appendix D) are incorporated into the Proposed Action to avoid or minimize impacts to these and other resources.

19, 76

17) The No Action Alternative would not resolve the current need for action in the Buffalo Pass area.

The Alternative 1: No Action Alternative would not meet the Purpose and Need for the project. As described in the EA, the Purpose of this project is to provide for trail-based recreation needs by developing and managing a sustainable, designated trail system; to address illegal trail activities; and to prohibit off-route travel by mountain bikes and other wheeled vehicles.

19, 76

18) Alternative 3, Trail/Area Closure, would be inconsistent with the need to provide recreation opportunities for the Steamboat Springs community.

Alternative 3: Trail/Area Closure was developed as a way to reduce negative resource impacts from the user-created trails, however it would not fully meet the project’s Purpose and Need.




56

19) Compare effects of closing all trails in the project area versus designating them for use.

Alternative 3: Trail/Area Closure was developed and analyzed to address this issue. For a complete comparison of all three alternatives considered in this project, please refer to the EA, pages 5-43.

80

20) The three alternatives appear extreme and do not adequately allow for consideration of a sufficient range of possibilities.

The EA and its consideration of Alternatives 1, 2, and 3 are consistent with NEPA and agency implementing policies. No specific number of alternatives is required or prescribed by law or regulation. When there are no unresolved conflicts concerning alternative uses of available resources, the EA need only analyze the Proposed Action and proceed without consideration of additional alternatives (36 CFR 220.7(b) (2)).

56, 58

21) Analyze a broader range of alternatives using best available trail planning science and select a less impacting one.

The EA and its consideration of Alternatives 1, 2, and 3 are consistent with NEPA and agency implementing regulations. No specific number of alternatives is required or prescribed by law or regulation. When there are no unresolved conflicts concerning alternative uses of available resources, the EA need only analyze the Proposed Action and proceed without consideration of additional alternatives (36 CFR 220.7(b) (2)). Trails will be designed following Forest Service design standards (FSH 2309.18), and utilizing IMBA standards for sustainable trails. The EA describes potential impacts that could result from the Proposed Action (p. 10-40) and includes design criteria (EA, Appendix D) to minimize impacts.

28 22) Consider an alternative with fewer trail miles. Approve fewer trails at the higher elevations

An alternative with fewer trail miles would not meet the project’s Purpose and Need as well as the Proposed Action.




where there is more hunting and the mountain biking season is shorter; concentrate trails at the lower elevations.

The trail miles included in the Proposed Action have been designed to avoid or minimize potential impacts. Review of the Proposed Action Map (p. E 75), shows that most trails are at the lower elevations.

The Proposed Action trails are not anticipated to significantly impact hunting. The majority of the trails on the north side of the Buffalo Pass Road at higher elevations are existing user created routes, so there will be very little new disturbance only where resource problems need to be corrected. On the south side of the Buffalo Pass Road, the majority of the trails are within ½ mile of the road. The trails in the Long Park CRA are on the edge of the boundary and affect an area of approximately 330 acres, leaving a significant portion (approximately 99.6%) of this roadless area available for wildlife and hunting.

During the later hunting seasons, bike and hiking use is minimal, and trails may improve access thus improving hunting success.

NEPA- Environmental Effects

32, 58

23) The project will contribute to erosion and impact quiet National Forest users, plant communities, and wildlife (including bird) populations and habitat.

Design criteria (EA, Appendix D) are incorporated into the Proposed Action to avoid or minimize significant impacts to any resource. Potential impacts to quiet uses, soils, plants, and wildlife are summarized in the EA (p 10-40) and analyzed in detail in the Specialist Reports. Soils, hydrology, botany and recreation resources will benefit from the proposed action.




28, 32, 45, 58, 79, 80

24) Mountain biking and motorized uses cause wildlife displacement and conflict with quiet and primitive uses such as hiking, bird and wildlife watching, and hunting.

The EA summarizes potential impacts to wildlife (p. 35-40). and recreationists (p. 23-27). Design criteria (EA, Appendix D) are incorporated into the Proposed Action to avoid or minimize significant impacts. After consultation with CPW, analysis in the Wildlife Specialist Report, and consideration of the existing heavy recreation use in the area, it was determined that the area will continue to provide for bird/wildlife watching and hunting and will not cause significant wildlife displacement. In contrast, additional trails may increase access to other areas for wildlife viewing and hunting. The Wildlife BA determined that the Proposed Action will not have an adverse effect on lynx habitat connectivity nor linkage areas.

17, 40, 43, 61, 86

25) Other recreational users will be negatively impacted since preference is given to mountain biking, despite the fact that bicycling is 14th on the National Visitor Use Monitoring (NVUM) list of reasons people are visiting public lands in Region 2 of the National Forest System.

The most recent Routt National Forest NVUM survey (2012) lists bicycling as 8th in visitor activity. Hiking/Walking is #2, and motorized Trail Activity/OHV use was #23. The proposed trails are designed for multiple-use, per Forest Service policy (FSM 2350.2.2). For more details on the Proposed Action, please refer to the EA, p. 6-10.

56

26) Evaluate effects on backcountry, primitive recreation settings and other management area prescriptions of the Forest Plan.

The EA analyzes for potential impacts to Management Areas and found the Proposed Action to be consistent with Management Area prescriptions set forth by the Forest Plan (EA, p. 9-10).

58 27) The proposed trails will have serious impacts

on wildlife, birds, plants, and the undeveloped nature of the area.

The Buffalo Pass area was selected for trail development due to the existing heavy recreation use of the area. The project was planned to maintain functional and connected




wildlife habitats by condensing recreation use and protecting areas with biological significance through design criteria (EA, Appendix D) as defined in the Wildlife BA and Specialist Report.

Utilizing existing trails where they are not creating resource damage and incorporating the design criteria and mitigation measures (EA, Appendix D) as defined in the Botany Specialist Report will minimize impacts to botany resources.

Based on analysis in the Wildlife and Botany Specialist Reports and the EA, the Proposed Action will not result in significant impacts to wildlife, birds, and plants and other resources (EA, p. 41-42).

56

28) The Forest Service and trail proponents must show there will not be impacts.

Pursuant to NEPA, the EA analyzes for potential impacts from the Proposed Action and alternatives (EA, p. 10-40). Based on this analysis, the Proposed Action will not result in significant impacts, which is documented in the Finding of No Significant Impact (p. 47-50).

80

29) Quiet uses can have similar, if not greater, impacts than motorized use.

Each use has its unique impacts to disturbing wildlife (p.34-40)Design criteria (EA, Appendix D, p. 68-73)) are incorporated into the Proposed Action to avoid or minimize resource impacts. The EA analyzes for potential resource impacts from the Proposed Action, which includes both motorized and non-motorized use on wildlife (p. 38-40). Based on this analysis, the Proposed Action will not result in significant impacts documented in the Finding of No Significant Impact (p. 47-50).




40

30) A landscape level review of the proposal is necessary as there is already a significant trail network in place for the mountain bike community. This analysis and inclusion of motorized use in the proposal is required by the USFS planning rule (Section 219.6) and the agency’s multiple-use mandate.

The Forest Plan and FSM 2350 provides direction to achieve multiple-use across the broader unit, or landscape. The Proposed Action was found to be consistent with Forest Plan direction, including Management Area prescriptions (EA, p. 9-10).

The Forest Service 2012 Planning Rule (36 CFR 219) sets forth process and content requirements to guide the development, amendment, and revision of land management plans. The planning rule applies to Forest Plan level analysis. This project is being implemented tiering to the current Forest Plan for the Routt National Forest. See the EA for further discussion of the proposed trail system and how it aligns with the Forest Plan (EA, p. 9-10).

Motorized use is considered and 5.7 mile trail is included in the proposed action. The Recreation Resources report discussed user conflict and rationale for not allowing all trails for motorized use.

38

31) Effects from the proposal to travel infrastructure, including the Buffalo Pass Road, must be considered.

Potential impacts to travel infrastructure and the Buffalo Pass Road are discussed in the EA (p. 23-24). Several projects unrelated to this proposal are ongoing that address this concern. Making changes to the road is outside of the scope of this project and will be analyzed in a separate NEPA analysis, if needed.

56

32) Conduct a GIS analysis of cumulative impacts to landscape integrity and habitat effectiveness and connectivity. Consider large, medium, and small scale impacts.

Potential direct, indirect, and cumulative impacts to resources, including wildlife and habitat, are summarized in the EA (p. 35-40) and analyzed in detail in the Wildlife BA




and Specialist Report. Utilizing GIS was a helpful tool in these determinations.

33, 56

33) Evaluate the magnitude and scope of impacts, including the zone of disturbance, from different types of trail types and trail uses.

Trail type (class) information was provided to resource specialists for inclusion in their analysis where applicable.

NEPA- Forest Plan Consistency

79

34) The decision notice needs to show how the proposal is consistent with Forest Plan direction for resource protection and how potential impacts will be addressed.

The Draft Decision Notice incorporates this. The EA analyzed potential direct, indirect, and cumulative resource impacts to resources from the Proposed Action (EA, p. 10-40). Design criteria (EA, Appendix D) are incorporated into the Proposed Action to avoid or minimize resource impacts below significant levels. The Proposed Action was also found to be consistent with Forest Plan direction for all resources (EA, p 9-10).

79

35) The proposed trails are inconsistent with Forest Plan management prescriptions. This includes Management Area 1.32, where areas have a natural appearance with little or no sign of human disturbance; and Management Area 3.23 which discourages construction of new recreation facilities. Trail construction and use constitute a disturbance.

This description of Management Areas is incomplete. Management Area 1.32 direction includes Transportation Guideline 3: “Develop non-motorized trails to provide experiences at all levels of difficulty,” (Forest Plan 2-15). Management Area 3.23 has no specific Transportation Guidelines, but recognizes the presence of trails. The theme of this MA is municipal watershed protection with other uses subordinate. The watershed, soils and fisheries findings state the proposed action will not be detrimental to the municipal watershed. The Forest Plan includes Infrastructure-Travelways Standard 3: “Prohibit all summer motorized use in Management Areas 1.11, 1.12, 1.13, 1.32,




2.2, and 8.22,” which does not prohibit motorized use in MA 3.23.

The EA found the Proposed Action to be consistent with Forest Plan direction, including Management Area prescriptions (EA, p. 9-10).

56, 79, 82

36) Any new trails should be developed and focused in MA 4.2, the central portion of the project area along the Buffalo Pass Road corridor.

A large portion of the trails are within MA 4.2. The EA found the Proposed Action to be consistent with Forest Plan direction, including all Management Area prescriptions in the project area. For a list of miles of trail by Management Area, please refer to Table 4 on page 8 in the EA.

79

37) The Forest Plan should be amended to prohibit bicycle use off designated routes.

The Proposed Action includes implementation of a Closure Order to prohibit mountain bike and all other wheeled-vehicle use off of designated roads and trails in the project area, in accordance with 36 CFR 261.55 (c). Resource issues are most prevalent here versus other places on the Forest, so the closure order is restricted to the project area. Amending the Forest Plan is another option to accomplish this management need, but the Forest Service feels the closure order is appropriate at this scale. If off-trail mountain biking continues and results in resource impacts across the entire Forest unit a Forest Plan Amendment could be considered in a separate NEPA analysis

NEPA- Proposed Action

40, 86

38) The mountain bike community should not be allowed to assert that all trails are subject to multiple-use management and then be allowed to exclude uses other than mountain

The proposed trails are accessible for multiple user types, per Forest Service policy (FSM 2350.2.2). Use can be regulated “to the extent necessary to provide for user and public safety; to protect…resources; to minimize conflict and




biking in the development of site-specific proposals.

maximize responsible use; to achieve recreation experience objectives; and to comply with Federal and State laws,” (FSM 2350.3.5).

40

39) As done with motorized trails in the past, existing trails should be closed to discourage illegal trail construction in the future.

Closure of the entire trail network was considered under Alternative 3: Trail/Area Closure, however it would not fully meet the Purpose and Need for the project. Instead, Alternative 2 would meet the Purpose and Need for the project by implementing a Closure Order to prohibit mountain bike and all other wheeled-vehicle use off of designated roads and trails in the project area, in accordance with 36 CFR 261.55 (c). Specific portions of trails in the project area that are creating resource damage will also be closed and rehabilitated after sustainable trail segments are implemented.

51, 56, 72, 80

40) Develop a sustainability, capacity, or growth management plan that will address future demand for trails and associated impacts across the Forest.

This action is beyond the scope of this project. Realizing that recreation use on national forests is projected to increase, and demands for additional trails do not meet the projected funding to maintain trails, the District is embarking on a Trails Master Plan, of which this project is a part. The outcome of this longer term plan is a sustainable trail system, minimizing resource impacts and maximizing appropriated funds, partnership opportunities and other avenues to maintain a high quality and safe trail system.

56, 80

41) Implement an adaptive management approach for trail management including monitoring and trigger points for specific

A specific adaptive management approach as described is not part of the Proposed Action. Design criteria (EA, Appendix D) are incorporated into the Proposed Action to minimize resource and social impacts. Following project implementation, unforeseen resource damage issues will be




remedies (e.g., signage, reinforced closures) with measurable results.

addressed per Forest Service policy, and Forest Plan direction.

56

42) Implement a closure to limit mountain bikes to designated trails throughout the Hahns Peak/Bears Ears District.

The Proposed Action includes implementation of a Closure Order to prohibit mountain bike and all other wheeled-vehicle use off of designated roads and trails in the project area, in accordance with 36 CFR 261.55 (c). Resource issues are most prevalent here versus other places on the Forest, so the closure order is restricted to the project area. Amending the Forest Plan is beyond the scope of this project. If off-trail mountain biking continues and results in resource impacts across the entire Forest unit a Forest Plan Amendment could be considered in a separate NEPA analysis.

40

43) Limit all mechanized travel to designated routes in the project area.

The Proposed Action for this project includes implementation of a Closure Order to prohibit mountain bike and all other mechanized travel off of designated roads and trails, in accordance with 36 CFR 261.55 (c). Please refer to the EA for more details (p. 8) and a map of this Closure Order (Appendix E, p. 75: Map 2). Motorized use is already restricted to designated routes per the Forest’s Motor Vehicle Use Map (MVUM).

56

44) Include in the decision the intent to focus intensive trail use in the Buffalo Pass project area and a commitment to avoid this type of development in more remote areas across the district.

The Forest Plan designates Management Areas, which provide guidelines to implement the Forest Plan. In this case, development of a trail system in partnership with the local community in the project area, is guided by multiple Management Area prescriptions, as described in the Forest Plan and referenced in the EA (p. 1). Any future actions in other areas would be based on a need for change from the existing conditions for those areas, Forest Plan consistency




and consideration of tradeoffs and resource impacts of a proposal.

55, 80 45) The proposed action map provided in the NOPA was not very clear and should include numbering or labels.

The Proposed Action map has been updated in the EA or on the Forest Service website at: http://www.fs.usda.gov/project/?project=46247.

24

46) Use of Forest Service motorcycle trail crews to construct the trails would be a misuse of OHV sticker funds that fund trail crews to maintain OHV trails.

OHV crews or funds will not be used to construct or maintain non-motorized trails. The proposed 5.7 miles of multi-use motorized route could be constructed and maintained by Forest Service motorcycle trail crews if OHV funds were granted to the Forest Service or to a Forest Service partner.

53, 94 47) Construct the trails as soon as possible. Project implementation may occur after completion of the

NEPA process and is planned for the spring or summer of 2016.

56

48) Implement a phased development approach whereby only those trails in the Buffalo Pass Road (Management Area 4.2) would be approved and other trails would be put on hold until user compliance is established, impacts are better known, and sufficient funding for trail maintenance and enforcement is secured.

Priority for implementation will be those areas already creating resource impacts. The majority of new trails will be within the 4.2 MA, however some of the high priority areas of resource issues are in the 1.32 MA.

The EA describes potential resource impacts from the Proposed Action. Design criteria (EA, Appendix D) are incorporated into the Proposed Action to avoid or minimize resource impacts, including monitoring. The Proposed Action was determined to not have a significant impact (EA, p. 43).

Funding for the construction of proposed trails comes primarily from the City of Steamboat Springs 2A Tax. Mountain biking groups and partners have committed time and resources to help construct and maintain the proposed

http://www.fs.usda.gov/project/?project=46247




trails. The Forest Service and Routt County Riders have entered into a Challenge Cost Share Agreement in order to ensure time and resources to construct and maintain the proposed trails are available. The Yampa Valley Community Foundation has established a Trail Maintenance Endowment Fund to address long-term maintenance shortfalls. The combination of these resources makes the Buffalo Pass Trails a no-cost project for the Forest Service.

Over the long term, the Forest Service will continue working with current partners and strive to develop new partnerships for additional funding and maintenance needs. Recreation Design Criteria #5 addresses your comment.

NEPA- Public Involvement

19

49) The Forest Service should establish an advisory board which the Strawberry Park Group could join and meet with interested parties.

There are no plans to establish an advisory board or working group. Consistent with law and regulation, public involvement for the project has occurred since the proposal stage and comments have been fully considered in the decision.

56, 79

50) The public must have an opportunity to comment on a draft environmental assessment.

Public involvement for this project is consistent with regulations as described in 36 CFR 218 Subparts A and B. The Forest Service combined scoping with the legal notice published in the Steamboat Pilot and Today and a 30-day opportunity to comment. A forty-five day objection period on the EA, Finding of No Significant Impact, and draft Decision Notice will also be available to commenters with standing, consistent with 36 CFR 218.26 (a) 36 CFR 218.5 (a). For




more details on public involvement, please refer to the EA (p. 4-5).

51

51) The comment period was too short and public notification was limited. Extend the comment period.

Public involvement for this project is consistent with regulations as described in 36 CFR 218 Subparts A and B. The Forest Service combined scoping with the legal notice published in the Steamboat Pilot and Today and a 30-day opportunity to comment. A forty-five day objection period on the EA, Finding of No Significant Impact, and draft Decision Notice will also be available to commenters with standing, consistent with 36 CFR 218.26 (a) 36 CFR 218.5 (a). For more details on public involvement, please refer to the EA (p. 4-5).

71, 90

52) Keep the desired experiences of the communities in mind when constructing and designating trails. This will garner support from visitors and volunteers, donors, and partner.

Based on several public comments received, the Proposed Action was modified to develop a trail system to meet the need of a variety of users including a range of ability levels, accessibility, multi-use (hiking, horseback, bike, motorcycle). See the Proposed Action section in the EA (p. 6-10) for more information.

NEPA- Purpose and Need

17, 25, 40, 42, 43, 47, 61, 78, 80,

86

53) The real reason for the proposed trails is to provide trails for mountain bikers who are illegally constructing trails in the area. The Forest Service should not reward or encourage groups for destructive or illegal behaviors or those who do not follow the process.

As described in the EA (p. 3), the Purpose & Need for this project is to provide for trail-based recreation needs by developing and managing a sustainable, designated trail system and address illegal trail activities by prohibiting off-route travel by mountain bikes and other wheeled vehicles. The Proposed Action will meet these objectives. Alternative 3: Trail/Area Closure was developed as an option to address the user-created trails, however, it would not fully meet the




project’s Purpose and Need. The Forest Service is currently not meeting Forest Plan direction here.

19

54) Resource protection along with sustainability should be the two main objectives for the Forest Service in the rehabilitation/construction of trails and the future management of these trails.

As described in the Purpose and Need (EA, p. 3), the EA describes potential resource impacts from the Proposed Action. Sustainable trail design and standards, per FSMs 2300, 2350, and FSH 2309.18, and design criteria (EA, Appendix D) are incorporated as part of the Proposed Action to avoid or minimize potential resource impacts. The Proposed Action was determined to not have a significant impact to resources.

56

55) In the proposed action, identify penalties, trail closures, and similar options for obtaining user accountability and enforcement.

The Proposed Action includes implementation of a Closure Order to prohibit mountain bike and all other wheeled-vehicle use off of designated roads and trails in the project area, in accordance with 36 CFR 261.55 (c). Please refer to the EA for more details and a map of this Closure Order (Map 2: page 75).

Following project implementation, issues related to enforcement will be addressed per Forest Service policy. Over the long term, the Forest Service will continue working with partners to promote responsible trail use and, if needed, seek additional funding to ensure maintenance and enforcement needs are met.

45, 56, 66, 80

56) Protection of resources and closure/rehabilitation of existing trails should be the priority, not more trails or facilitating further use.

Alternative 3 was developed to address this concern, but does not fully meet the purpose and need.

As described in the EA (p. 3), the Purpose and Need of this project is to provide for trail-based recreation needs by developing and managing a sustainable, designated trail




system; to address illegal trail activities; and to prohibit off-route travel by mountain bikes and other wheeled vehicles. The Proposed Action meets these objectives and is consistent with Forest Plan and Management Area direction (EA, p. 9-10 and 42).

Sustainable trail design and standards, per FSMs 2300, 2350, and FSH 2309.18, and design criteria (EA, Appendix D) are incorporated as part of the Proposed Action to avoid or minimize potential resource impacts. Therefore, the Proposed Action was found to not have significant resource impacts (FONSI, p. 48).

56, 71

57) Ensure the proposed action will meet the needs of a broad range of recreating public per Forest Service direction and strategies.

As described in the EA (p. 3), the Purpose and Need of this project is to provide for trail-based recreation needs by developing and managing a sustainable, designated trail system; to address illegal trail activities; and to prohibit off-route travel by mountain bikes and other wheeled vehicles. The Proposed Action meets these objectives and is consistent with Forest Plan and Management Area direction (EA, p. 9-10 and 42). Specifically, the proposed trails are accessible for multiple user types and abilities, per Forest Service policy (FSM 2350.2.2). Please see the Proposed Action description and map in the EA (p. 6-10 and Appendix E, Maps 2 and 3) for more details on multiple-use.

RECREATION

Recreation- Accessible Trails and Facilities

95 58) Design the lower trail (that would get pedestrians and cyclists off the Buffalo Pass

The proposed trail network will include a variety of trail classes, depending on location and terrain. Generally, trails




Road) and trail width to accommodate jogging strollers, bike trailers, beginner riders, and hand cyclists.

near the Dry Lake campground and trailhead will be more beginner level (wider and smoother), while more remote trails will tend to be more advanced and rugged. Approximately 4 miles of trail meet your description, and another 5 miles could be accessible to hand bikes.

3, 41

59) Design trails, campsites, parking areas, and facilities to accommodate the needs of people with disabilities.

The proposed trail network will include a variety of trail classes, depending on location and terrain. Generally, trails near the Dry Lake campground and trailhead will be more beginner level (wider and smoother), while more remote trails will tend to be more advanced and rugged. The Forest Service will follow Forest Service Accessibility Guidelines for designing and constructing new accessible facilities and trails.

Recreation- Campgrounds, Parking, and Facilities

6, 19-21, 38, 64, 80

60) Address parking needs by expanding the Dry Lake parking area (including design for vehicles with trailers and turn-around areas) and consider additional parking areas. Also consider the need for dispersed camping sites.

The existing Dry Lake Parking Lot provides adequate parking capacity for summer uses, and will be altered slightly to accommodate the installation of an accessible toilet facility. The need for additional parking beyond the Dry Lake parking area or increasing capacity of the current parking lot is a winter recreation issue and not included in this project analysis. Any decision related to winter parking capacity may be assessed in the future in a separate NEPA analysis.

Dispersed camping is allowed in the project area with some restrictions. No changes are proposed in this action. Most dispersed sites in the analysis area meet Forest Plan standards. The Forest Service will monitor dispersed




camping in the area and manage dispersed camping per requirements in the Forest Plan and Forest Service policy.

45

61) Improving and increasing parking space at the Dry Lake parking area will negatively impact the quality of recreation experiences (e.g., by increasing snowmobile usage in the winter months and increasing downhill mountain biking during the summer). The demand for parking will always exceed capacity of the area. A management plan is needed to address recreation capacity in the area before the parking area is enlarged.

Increasing the capacity of the Dry Lake parking lot is not a part of the Proposed Action. The Proposed Action does include improved parking facilities with the installation of an accessible toilet and updated trailhead signs.

A management plan for the Buffalo Pass Road corridor is outside the scope of this analysis.

20, 21, 71, 83

62) Address public toilet and facility needs at the Dry Lake parking area and other possible designated sites.

The Dry Lake parking facilities will be improved for visitor use with the installation of an accessible toilet and updated trailhead signs. Other proposed trailheads at the upper terminus of the BTR, Grouse and Soda Mountain Trails will be Development Scale 1, (low scale and use) and toilet facilities will not be required, unless use exceeds thresholds identified in Forest Service manuals and handbooks. If monitoring of use determines a need, a more highly developed trailhead may be developed analyzed in a separate NEPA analysis.

45, 51 63) A management plan is needed to address

recreation capacity in the area before making changes to the Dry Lake parking area.

The Dry Lake parking improvements will include installation of an accessible toilet and updated trailhead signs, but the parking lot capacity will not be increased with this decision.

45, 56 64) Limit parking lot size to manage use levels. Existing parking capacity is adequate for summer uses. The Dry Lake parking facilities will be improved for visitor use




with the installation of an accessible toilet and updated trailhead signs, but the parking lot capacity will not be increased at this time.

Recreation- Closures and Rehabilitation

32, 71, 82

65) Existing user created trails must be evaluated for impacts before inclusion in the proposal and should be rehabilitated/closed if they are resulting in erosion or impacts on plants, wildlife, or other resources.

Existing trails have been surveyed and evaluated for resource impacts. Surveys will be completed on all existing and proposed trail segments before project implementation. Trail segments not meeting Forest Service standards or where resource issues exist have been identified to close and rehabilitate. Newly rerouted segments have been identified on the ground and surveyed by resource specialists. Sustainable trail design and standards, per FSMs 2300, 2350, and FSH 2309.18, and resource design criteria (EA, Appendix D) are incorporated as part of the Proposed Action to avoid or minimize impacts.

9, 20, 67, 71, 74

66) Regarding closure of any existing illegal trails, redesign them to be more sustainable and less impacting and incorporate them into the trail network.

Where appropriate, existing trails will be incorporated as part of the proposed trail alignments provided they are, or can be improved to be, sustainable as outlined by Forest Service policy (FSH 2309.18 20.2).

80

67) Include provision in the decision to allow continued closure of unauthorized and user-created trails.

The Proposed Action includes implementation of a Closure Order to prohibit mountain bike and all other mechanized use off of designated roads and trails, in accordance with 36 CFR 261.55 (c). Please refer to the EA (p. 8) for more details and a map of the Closure Order (Appendix E, page 75: Map 2).

Recreation- General




37, 91

68) Impacts from camping already exist and will get worse with increased use of the area associated with the proposed trails.

Dispersed camping is allowed in the project area with some restrictions. No changes are proposed in this action. Most sites in the analysis area meet Forest Plan standards. The Forest Service will monitor dispersed camping in the area and manage dispersed camping per requirements in the Forest Plan and Forest Service policy.

Recreation- Hunting

40

69) The lack of motorized trails for access and game retrieval impacts the hunting community.

Increased access from the approximately 5.7 miles of motorized trails will result from the Proposed Action. Providing motorized access on trails specifically for hunting access and game retrieval does not occur anywhere on non-motorized trails on the Forest.

Recreation- Maintenance and Enforcement

32

70) Existing trails, such as the Soda Mountain trail should be improved and maintained to minimize erosion and impacts on plant communities, and new trails must be maintained and signed for specific uses. Should new trails be built, the Forest Service must have the resources to maintain them.

Proposed Action sustainable trail design and standards, per FSMs 2300, 2350, and FSH 2309.18, and design criteria (EA, Appendix D) are incorporated as part of the Proposed Action to avoid or minimize impacts. This includes making improvements to existing trails and decommissioning of trails that are unsustainable, as needed. Signage will occur upon project implementation, and future maintenance will occur per Forest Service policy.

Sustainable trail design should minimize maintenance needs and costs. Funding for the Proposed Action comes primarily from the City of Steamboat Springs 2A Trail Fund. Mountain biking groups, such as Routt County Riders, have committed time to help construct and maintain the proposed trails. The Yampa Valley Community Foundation has established a Trail




Maintenance Endowment Fund to fund long-term maintenance shortfalls and needs. Recreation Design Criteria #5 (p. 69) addresses these concerns.

Over the long term, the Forest Service will continue working with partners and, if needed, seek additional funding to ensure maintenance needs are met.

12, 19, 25, 32, 33, 40, 42, 45, 56, 79, 80, 82,

83

71) The decision should address agency resources and secure funding for future trail maintenance needs, and enforcement efforts to prevent illegal expansion of trails.

Funding for planning and construction of the proposed trails comes primarily from the City of Steamboat Springs 2A Trail Fund. Mountain biking groups, such as Routt County Riders, and partners have committed time to help construct and maintain the proposed trails. Sustainable trail design and standards are incorporated as part of the Proposed Action and should reduce overall maintenance needs and costs.

The Yampa Valley Community Foundation has established a Trail Maintenance Endowment Fund to address long-term maintenance costs. Over the long term, the Forest Service will continue working with partners and, if needed, seek additional funding to ensure maintenance and enforcement needs are met.

The Proposed Action includes implementation of a Closure Order to prohibit mountain bike and all other wheeled-vehicle use off of designated roads and trails, in accordance with 36 CFR 261.55 (c). Recreation Design Criteria #5 (p. 69), addresses the lack of outside funding, and decisions to be made by the Forest Service if this opportunity does not materialize.




19

72) A long term maintenance plan is needed for the proposed trails.

Following project implementation, trails will be considered part of the National Forest Trail System and maintenance will be addressed per Forest Service policy. A specific long-term maintenance plan for this project may be developed with the community partners involved in development. Over the long-term, the Forest Service will continue working with partners to ensure maintenance needs are met.

40

73) Trail maintenance needs and costs include removing fallen and hazardous trees associated with the mountain pine beetle epidemic.

There is a very low presence of lodgepole pine in the project area and in the limited areas of dead lodgepole pine, hazard trees will be felled during trail development, reducing the longer term maintenance need. Following implementation, maintenance will be addressed per Forest Service policy.

83

74) Motorized trails will require much more maintenance than non-motorized trails.

With proper trail design, motorized trails do not require more maintenance than non-motorized trails. Design criteria (EA, Appendix D) and sustainable trail design are incorporated as part of the Proposed Action. For more detailed information on trail design, please see the EA, p. 7-8.

Additionally, Forest Service maintenance costs for motorized trails are off-set by funds received annually from outside sources (CPW trail grants and local clubs).

21, 53, 59, 92, 94

75) Provide and take advantage of partnership and volunteer opportunities for trail building and maintenance.

The Forest Service will work with partners and volunteers who want to assist in trail construction and maintenance. All opportunities will be consistent with Forest Service policies for use of outside partners and volunteers, youth conservation corps and other partners.




44, 62, 90, 94

76) If the proposed trails aren’t constructed, people will build them anyway. It’s better to have the Forest Service involved to ensure they are built properly.

The purpose of this project is to provide for trail-based recreation needs by developing and managing a sustainable, designated trail system; to address illegal trail activities; and to prohibit off-route travel by mountain bikes and other wheeled vehicles. The Proposed Action will meet these objectives.

Unauthorized trail construction and maintenance is prohibited by the Forest Service (FSM 2350.3.7 and 36 CFR 261.10 (a)). The Forest Service must be involved in any projects, actions, or activities on National Forest land, as required by law, regulation, and policy, such as NEPA and the Endangered Species Act.

6, 42, 51, 56, 71, 79

77) Address illegal cross country travel and trail construction.

The Proposed Action includes implementation of a Closure Order to prohibit mountain bike and all other wheeled-vehicle use off of designated roads and trails, in accordance with 36 CFR 261.55 (c). Unauthorized trail construction and maintenance is prohibited by the Forest Service (FSM 2350.3.7 and 36 CFR 261.10 (a)).

59 78) Consider limited use of motorcycles for trail

maintenance purposes. Motorcycles may be allowed for administrative use as appropriate.

71

79) A policy statement should be issued by the Forest Service to address user-generated trail development. The closure order is just a temporary solution.

Unauthorized trail construction and maintenance is prohibited by the Forest Service (FSM 2350.3.7 and 36 CFR 261.10 (a)). Additionally, the Proposed Action includes implementation of a Closure Order to prohibit mountain bike and all other wheeled-vehicle use off of designated roads and trails, in accordance with 36 CFR 261.55 (c). This Closure Order is not a temporary decision. Following project




implementation, compliance and enforcement issues related to off-route travel violations will be addressed per Forest Service policy. Information and education of the problems of non-designed trails is a part of the overall plan.

Recreation- Road Conditions and Traffic

52

80) Due to the inconsiderate and irresponsible driving of motor vehicles on the Buffalo Pass Road, a new trail that borders this road is necessary to provide safe access for mountain bikers.

The Forest Service strives to reduce user group conflicts (FSM 2350.3.5) and provide for safety. The Proposed Action trails were designed with these objectives in mind.

68

81) Most of the proposed trails are downhill bike trails requiring vehicle shuttles which would increase traffic congestion on Buffalo Pass Road.

While there are some challenging trails, which, due to their nature, will be used primarily for downhill biking, none of the proposed trails will be designated for downhill biking only. Adding trails that parallel both the north and south sides of the road will provide alternate travel routes and to reduce congestion on the road.

37, 38, 49, 82, 93

82) Repairs to the Buffalo Pass Road are needed to improve access and public safety and accommodate increased traffic associated with the proposed trails.

Improvements to the Buffalo Pass Road are outside the scope of this project, but may be analyzed in the future in a separate NEPA. Several projects are ongoing including resurfacing and drainage improvements, and are being completed as funding allows. A Federal Highways Safety Audit will be completed in 2016, creating more projects and hopefully opportunities for outside funding.

Adding trails that parallel both the north and south sides of the road will provide alternate travel routes for non-vehicle travel and reduce congestion on the road.




38

83) Include a provision that would allow future paving of Buffalo Pass Road to Dry Lake Campground. Complete environmental planning for this action under the current proposal.

Improvements to the Buffalo Pass Road are beyond the scope of this project, but may be analyzed in the future in a separate NEPA. The resurfacing or paving of the Buffalo Pass Road could be considered a maintenance item, and would not require NEPA.

84

84) Buffalo Pass Road is unsafe for motorcyclists due to heavy car traffic, and one or more motorized trails would mitigate this danger.

Approximately 5.7 miles of motorized route are included in the Proposed Action, which will provide an alternate travel route for motorcycles.

6,63

85) A non-motorized trail intended for uphill access would reduce conflict between vehicles and non-motorized use.

Trails are designed to minimize user group conflicts, in accordance with Forest Service policy (FSM 2350.5). A trail which parallels the Buffalo Pass Road to the south is designed for easier uphill access, however, it will be not be a designated uphill only trail.

21

86) A designated down-route, directional trail from the Dry Lake Parking area is needed to link the trail network to downtown Steamboat Springs and help alleviate existing user conflicts on the Spring Creek trail and Buffalo Pass Road.

Trails are designed to minimize user group conflicts, in accordance with Forest Service policy (FSM 2350.5). An alternate trail to the current Spring Creek Trail, Spring Creek Alternate/Trail Segment #12, is included in the Proposed Action to alleviate user group conflicts. It will be designed with this concept in mind complementing the existing Spring Creek Trail.

Recreation- Signing and Public Education

32, 6, 19, 21, 59, 80

87) Adequate signage and seasonal closures must be considered or implemented to

Signage will occur upon project implementation per the Forest Service Enforcement Plan in collaboration with Colorado Parks & Wildlife. Seasonal closures and buffers for critical habitats have been included in the design criteria




protect wildlife and crucial habitats during sensitive periods.

(EA, Appendix D) as part of the Proposed Action. Potential impacts to wildlife and wildlife habitat are described in the EA and analyzed in depth in the Wildlife BA and Specialist Report. Based on these analyses, the Proposed Action will not have a significant wildlife impact.

19, 33, 40, 52, 59, 63

88) Install signs and kiosks to inform the public of trail designations and levels, parking restrictions, trail and road etiquette, wildlife concerns, and resource protection.

Signage and other information/education opportunities will occur upon project implementation per the design criteria (EA, Appendix D) and Forest Service policy.

42, 89) Incorporate educational programs for all

Forest users such as Stay the Trail for OHV and trail yielding practices.

Signage and other information/education opportunities will occur upon project implementation as identified in the design criteria (EA, Appendix D) and Forest Service policy.

80

90) Contact user groups and websites to have them remove advertisement and information of unauthorized, user-created routes prior to designating any new trails.

This comment is beyond the scope of the project. The Forest Service monitors advertisement and dissemination of illegal activities and follow up with legal action. It will continue communicating with user groups and partners to address information issues.

56, 57

91) Manage and guide promotional materials for trails to help manage use and growth.

As a part of the implementation plan, the Forest Service will partner with the City of Steamboat Springs, Routt County Riders and Steamboat Bike Town USA to develop maps and outlets for information and promotion of the trail system. Trail information will be available to the public per Forest Service standards (i.e. Ranger District offices, trailhead kiosks, Forest Service website).

Recreation- Special Events




14-16, 18, 30, 70, 76

92) Allow trails to be used by organized groups and for commercial and non-profit events such as tours and races.

Consideration and authorization of future recreation events and special use permits in the area will occur on a case-by-case basis per Forest Service policy, and consistency with Forest Plan direction.

Recreation- Trail Designation and Use

19, 83

93) Avoid motorized trails except on, or adjacent to, Buffalo Pass Road. The currently quiet area of Soda Creek is more suitable for hiking trails and quiet uses and would be negatively impacted by motorized trails.

The 5.7 miles of motorized routes in the Proposed Action is within 0.5 miles from the Buffalo Pass Road or roads south of the Buffalo Pass Road. No proposed motorized route will be in a CRA, specifically the Mad Creek CRA, where Soda Creek is located.

19

94) If a new motorized trail is necessary, consider locating it south of Buffalo Pass Road instead of the route proposed.

A part of the motorized route is north of the road, and a portion is south of the Buffalo Pass Road after crossing in the Rocky Flats Area. See Comment response #93 for an additional response.

40, 92

95) The proposal is essentially a downhill mountain bike trail network that will increase user conflicts more than if the trails were designated as open to motorized use.

While there are some challenging trails that may be utilized primarily by downhill bikers, none of the proposed trails will be designated for downhill biking only. The proposed trails are accessible for multiple user types, per Forest Service policy (FSM 2350.2.2). However, use can be regulated “to the extent necessary to provide for user and public safety; to protect…resources; to minimize conflict and maximize responsible use; to achieve recreation experience objectives; and to comply with Federal and State laws,” (FSM 2350.3.5). 5.7 miles of route open to motorized use is included in the Proposed Action. For more details on the Proposed Action, please refer to the EA, p. 6-10.




4, 5, 7, 8, 17, 24-26, 29, 34, 35, 39, 40, 42, 43, 47, 50, 54, 60, 61, 73, 78, 84-87, 89, 92

96) Allow multiple-use including motorized use on the proposed trails, particularly motorcycles/dirt bikes, since trails designed for mountain bikes are also suitable for motorcycles and use, speeds, and impacts are similar. Consider other interested groups beyond just the bicycle community.

The Proposed Action was determined in the EA to be consistent with Forest Plan and Management Area direction (EA p. 9-10 and 42). Per Forest Service policy, the proposed trails are designed for multiple-use (FSM 2350.2.2). 5.7 miles of route open to motorized use is included in the Proposed Action. In order to reduce the potential for user-conflicts, avoid resource damage, and follow Management Area direction, the remaining trails are not open for motorized use, per FSM 2350.3.5. See the “Consistency with Forest Plan” in the EA, p. 9-10.

84

97) The decision should allow the trails to be open to motorized use in the future should the Forest Plan designations [management area prescriptions] be changed to allow such use.

This decision is beyond the scope of the project and possibly a Forest Plan revision topic. Future forest planning may result in modifying management area prescriptions, at which time site-specific and project-level decisions would be made consistent with those prescriptions.

84

98) Reroute trails into management areas that allow motorcycles to provide for more motorized use.

Approximately 60% of the trails could allow motorized use. To reduce the potential conflicts when combining user groups in a small area, the Forest Service decided not to allow motorized us on all of these trails (per FSM 2350.3.5.). For a more detailed explanation, see pages 10 and 26 of the EA, and Recreation Resource report. The Proposed Action was determined in the EA to be consistent with Forest Plan and Management Area direction (EA, p. 9-10 and 42). Per Forest Service policy, the proposed trails are designed for multiple-use. 5.7 miles of routes open to motorized use is included in the Proposed Action will not exclude motorized use, it creates some local short duration opportunities, and also to provide a safe, enjoyable egress to Buffalo Pass, the




Wyoming Trail (NFST 1101) and other motorized trails within a day’s ride.

84

99) The proposed action should start with multiple-use for all groups and reduce motorized trail miles only where there is solid justification. The proposed action is biased against motorized use.

See the EA, pages 10 and 26, for detailed explanation on multiple-use. This area is a high use recreation area, with a predominant numbers being non-motorized. 5.7 miles of route open to motorized use is included in the Proposed Action. In order to accommodate multiple user groups, reduce the potential for user-conflicts, avoid resource damage, and follow Management Area direction, the remaining trails are not open for motorized use, per FSM 2350.3.5. The Proposed Action was determined in the EA to be consistent with Forest Plan and Management Area direction (EA, p. 9-10 and 42). Per Forest Service policy, the proposed trails are designed for multiple uses (FSM 2350.2.2). It is difficult enforce trail closure once trails are established for use, especially if a trail is only being closed to one user group.

84, 92

100) Maximize the number of new trail miles for motorized use. The proposed 4-mile trail for motorized use will concentrate use, thereby increasing impacts and user conflicts. Further, the same trail must be used for climbing and descending.

The EA and FONSI determined that the Proposed Action would not have any significant resource impacts.

Motorized trail is included on the north and south sides of Buffalo Pass Road to create loop trail segments for short duration trips. The 5.7 mile trail will also provide access to the Wyoming Trail and other motorized routes on the east side of Buffalo Pass. The Buffalo Pass Road will remain open to motorcycles.

84 101) Start with opening trails to all users, including motorcycles. If resource problems

It is difficult enforce trail closure once trails are established for use, especially if a trail is only being closed to one user




or conflicts develop, then close trails as needed.

group. Instead, the Proposed Action is designed to allow for multiple-use and to reduce the potential for user group conflict. Following project implementation, the Forest Service will monitor resources and user group conflicts and manage them in accordance with Forest Service policy.

84, 89

102) Create a motorized trail network with loops to connect to other areas such as the Rabbit Ears Pass area and Grizzly-Helena trail.

This decision is outside the scope of the project, however, managing trail development at a broad scale to coordinate with other trail systems is part of the Forest Plan (1-19). Future trail construction to network with Rabbit Ears Pass and the Grizzly-Helena trail would be analyzed in a separate NEPA analysis.

80, 84, 92

103) Alternate/rotate trail user days between user types to reduce conflicts.

The Proposed Action is designed to reduce user group conflicts. Following project implementation, the Forest Service will monitor resources and user group conflicts and manage them in accordance with Forest Service policy. The alternating day management tool could be an option to consider in the future if user conflicts exist on trails open to differing user groups (e.g. hikers, bikers, motorcycles)

35, 47, 50

104) Most of the existing trails surrounding the Steamboat Springs area including those used by mountain bikers were used by motorized users and built and paid for with motorized OHV grants.

Existing trails in the project area are primarily user-created. Some information on use of the old Soda Mountain jeep trail has been presented. The area has primarily been non-motorized since the Davis Peak addition to the Mount Zirkel Wilderness in 1980, and are also in non-motorized MA prescriptions of the Forest Plan.

17, 24, 25, 84, 89, 92

105) An extensive non-motorized trail network already exists in the Steamboat Springs area, such as the Emerald Mountain area

5.7 miles of motorized routes will be added to the system and MVUM providing direct access close to Steamboat Springs. This will allow two ways to access other motorized




and Steamboat Ski Area. The motorcycle community must travel outside the area to access a dedicated motorized singletrack system.

trails along the divide and east of Buffalo Pass, including the Buffalo Pass road. Motorized users can generally travel longer distances than non-motorized users in the same period of time. This new trail does create a new opportunity, while also providing for other uses.

17, 35, 40, 43, 50, 61, 84, 86, 92

106) Designating the trails as multi-use would leverage more partnering and funding opportunities (e.g., CPW OHV grants) for future maintenance of the proposed trail network and associated costs.

The Proposed Action was determined in the EA to be consistent with Forest Plan and Management Area direction (EA, p. 9-10 and 42). Per Forest Service policy, the proposed trails are designed for multiple-use (FSM 2350.2.2). 5.7 miles of route open to motorized use is included in the Proposed Action. In order to accommodate multiple user groups, reduce the potential for user-conflicts, avoid resource damage, and follow Management Area direction, the remaining trails are not open for motorized use, per FSM 2350.3.5.

Mountain biking groups, such as Routt County Riders, and other partners have committed time to help construct and maintain the proposed trails. The Yampa Valley Community Foundation has established a Trail Maintenance Endowment Fund to fund maintenance. Over the long term, the Forest Service will continue working with partners and, if needed, seek additional funding to ensure that construction and maintenance needs are met. Recreation Design Criteria #5 (p. 69) describes management options if partnership funding does not materialize.

87 107) The proposed trails should favor multiple-

use over single use because: The comment of motorized users covering a larger area in less time supports the Forest Service decision to limit motorized trail use in this area close to a population center.




a. Motorized use by its very nature requires more space—a trail bike can cover a lot more ground in an hour or day than a mountain biker or hiker.

b. The largest percentage of our population now is made up of aging baby boomers who are either physically incapable or don’t want to hike or bike.

c. An extensive trail system designated for mountain bike use already exists in the Steamboat Springs area (Emerald Mountain).

In order to accommodate multiple user groups, reduce the potential for user-conflicts, avoid resource damage, and follow Management Area direction, the remaining trails are not open for motorized use, per FSM 2350.3.5. The Proposed Action was determined in the EA to be consistent with Forest Plan and Management Area direction (EA p. 9-10 and 42). Per Forest Service policy, the proposed trails are designed for multiple-use (FSM 2350.2.2). 5.7 miles of route open to motorized use is included in the Proposed Action.

The proposed trail system is designed to complement the other nearby trails on Emerald Mountain. These trails are heavily used and support recreation events. Public comment received included the desire for a more rugged and primitive experience. This design is consistent with the need to provide for multiple use trails safe for hikers and equestrians.

55, 80

108) Avoid motorized trails in the project area to preserve the pristine nature of the Buffalo Pass area.

The Proposed Action was determined in the EA to be consistent with Forest Plan and Management Area direction (EA p. 9-10 and 42).. Per Forest Service policy, the proposed trails are designed for multiple-use (FSM 2350.2.2). Sustainable trail design and standards, per FSMs 2300, 2350, and FSH 2309.18, and design criteria (EA, Appendix D) are incorporated as part of the Proposed Action to avoid or minimize impacts.

83

109) Mountain bike use causes more erosion than hikers.

With proper trail design and user compliance, bicycle use on trails do not require more maintenance than non-motorized trails. Sustainable trail design and standards, per FSMs 2300, 2350, and FSH 2309.18, and design criteria (EA, Appendix D) are incorporated as part of the Proposed Action




to avoid or minimize impacts. Potential erosion impacts are analyzed in detail in the Soils and Watershed Specialist Reports and summarized in the EA (p. 27-30 and 31-34).

19

110) Regulations to protect the natural environment and to maintain the separation of the different users are appropriate and necessary. The public is conditioned to regulations designating different uses and closures.

The EA analyzes for any potential resource impacts that may result from the Proposed Action. Sustainable trail design and standards, per Forest Service Manuals 2300, 2350, and FSH 2309.18, and design criteria (EA, Appendix D) are incorporated as part of the Proposed Action to avoid or minimize resource impacts.

The Forest Service strives to reduce user group conflicts (Forest Service Manual 2350.3.5) and provide for safety. The Proposed Action trails were designed with these objectives in mind. Following project implementation, the Forest Service will monitor resources and user group conflicts and manage them in accordance with Forest Service policy.

36

111) More downhill routes are needed in the Steamboat Springs area. Not all users can afford to pay to ride at the ski resort.

The issue of affordability is outside of the scope of this project.

Designated downhill routes in the project would not meet the Purpose and Need for the project. While there are some challenging trails, which, due to their nature, will be used primarily for downhill biking, none of the proposed trails will be designated for downhill biking only.

36, 90

112) Trail terrain and routing will help determine the appropriate user class (foot, horseback, bicycle, etc.) and achieve multiple-use without designating trails.

The proposed trail network will include a variety of trail classes, depending on location and terrain, which will help to separate users. Generally, trails near the Dry Lake campground and trailhead will be more beginner level (wider and smoother), while more remote trails will tend to be more




advanced and rugged. Following project implementation, the Forest Service will monitor resources and user group conflicts and manage them in accordance with Forest Service policy.

84

113) Any motorized route designations should be for motorized use only (i.e., no mountain bikes or other uses).

In accordance with the Forest Service’s Travel Management Rule, all motorized trails are also currently open to non-motorized use. The proposed trails are accessible for multiple user types, per Forest Service policy (FSM 2350.2.2). However, use can be regulated “to the extent necessary to provide for user and public safety; to protect…resources; to minimize conflict and maximize responsible use; to achieve recreation experience objectives; and to comply with Federal and State laws,” (FSM 2350.3.5). The Forest Service will monitor use and user group conflicts on the trail network and if it determined to be necessary, restrictions could be incorporated.

82 114) The downhill trails proposed will turn into a

drive up and then ride down situation. As regulated by the Forest Plan, trails will be monitored for use and conflicts and adjustments will be made as necessary (B-10.7.b).

51

115) Implement regulations to prohibit single speed gravity bikes on the new trails.

Trails are designed per FSH 2309.18-Trails Management Handbook, which regulates speed through trail class and trail design specifications.

The proposed trails are accessible for multiple user types, per Forest Service policy (FSM 2350.2.2). However, use can be regulated “to the extent necessary to provide for user and public safety; to protect…resources; to minimize conflict and maximize responsible use; to achieve recreation experience




objectives; and to comply with Federal and State laws,” (FSM 2350.3.5). The Forest Service will monitor use and user group conflicts on the trail network and if it is determined that single speed gravity bikes are causing safety issues and/or user group conflicts, restrictions could be incorporated. The Proposed Action does not discriminate against any one type of bike.

56 116) Implement speed limits for faster trail users. Trails are designed per FSH 2309.18-Trails Management

Handbook, which regulates speed through trail class and trail design specifications.

40

117) Prohibit winter, over the snow use by mechanized travel in the project area and across the landscape to minimize resource impacts.

Over the snow mechanized use in the project area is determined by the Forest Plan and the Winter Recreation EA and is outside of the scope of the project. Please refer to the Forest Plan and Winter Recreation EA for more information.

Recreation- Trail Layout and Design

6, 10, 19, 21, 42, 51, 56-59, 67, 71, 80, 90

118) Incorporate sustainable and ecological trail design.

As described in the EA, the purpose of this project is to provide for trail-based recreation needs by developing and managing a sustainable, designated trail system; to address illegal trail activities; and to prohibit off-route travel by mountain bikes and other wheeled vehicles. The Proposed Action meets these objectives and is consistent with Forest Plan and Management Area direction (EA, p. 9-10 and 42).

Sustainable trail design and standards, per Forest Service Manuals 2300, 2350, and FSH 2309.18, and design criteria (EA, Appendix D) are incorporated as part of the Proposed Action to avoid or minimize potential resource impacts. This




includes making improvements to existing trails and decommissioning of unsustainable trails.

33

119) Define maintenance strategies and funding sources prior to construction to ensure trails do not cause excessive erosion or habitat degradation.

Sustainable trail design and standards, per Forest Service Manuals 2300, 2350, and FSH 2309.18, and design criteria (EA, Appendix D) are incorporated as part of the Proposed Action to avoid or minimize potential resource impacts. This includes making improvements to existing trails and decommissioning of unsustainable trails. Based on analysis in the EA, the Proposed Action will not have a significant resource impact.

Mountain biking groups and partners have committed time and resources to help construct and maintain the proposed trails. The Forest Service and Routt County Riders have entered into a Challenge Cost Share Agreement in order to ensure time and resources to construct and maintain the proposed trails are available. Additionally, the Trail Maintenance Endowment Fund has been established to help financially support trail and trailhead maintenance. For more information on the trails alliance proposal, please visit www.steamboatspringstrails.org.

Over the long term, the Forest Service will continue working with current partners and strive to develop new partnerships for additional funding and maintenance needs. Recreation Design Criteria #5 (p. 69) discusses options if external partnership funds do not materialize.

21, 33, 91 120) Site trails to avoid critical habitats such as

riparian and other sensitive areas. Sustainable trail design and standards, per Forest Service Manuals 2300, 2350, and FSH 2309.18, and design criteria (EA, Appendix D) are incorporated as part of the Proposed

http://www.steamboatspringstrails.org/




Action to avoid or minimize potential resource impacts. This includes making improvements to existing trails and decommissioning of unsustainable trails. Based on analysis in the EA and Specialist Reports, the Proposed Action will not have a significant resource impact to wetlands, riparian areas, or aquatic habitat. These sensitive areas will be avoided ( see Appendix D – Design Criteria)

52

121) Include a trail with outlets at all three trailheads.

Trail connectivity is desired across the Forest as a unit per Forest Service Manual 2353.51.1 and is achieved by the Proposed Action. Wherever possible, trails will be built to be part of a loop system. The Forest Service will continue to work towards increasing trail connectivity across the Forest. Any future projects would require a separate NEPA analysis.

83

122) Near the Soda Mountain trail, consider a valley trail following the jeep trail from Dry Lake Campground to Soda Creek then up the south side of the river, then converging with the ditch trail at the east end of the valley.

Trail recommendations were considered for inclusion in the Proposed Action as long as the recommendation met Forest Service trail sustainability standards and did not cause resource damage. Please see the EA for a description and map of the Proposed Action.

83

123) Regarding the proposed hiking trail north of the Buffalo Pass Road, locate it sufficiently over Bear Ridge to the north to avoid noise from Buffalo Pass Road and motorized trails in the area.

The Proposed Action trails are designed in accordance with the FSH 2309.18-Trails Management Handbook to meet multiple standards: to provide for scenic quality, meet trail sustainability standards, and provide for multiple-use.

72, 84, 90, 94

124) Ensure that more advanced, primitive trails are built.

The Proposed Action includes a variety of trail classes, depending on location and terrain, which will help to separate user groups. Generally, trails near campsites and




developed areas will be more beginner level (wider and smoother), while more remote trails will tend to be more advanced and rugged.

31

125) Build as many trails as possible while we have dedicated funds and volunteers.

Resource specialists and experienced mountain biking consultants have analyzed the proposed area and designed the number of trails that the resource area can sustainably hold while also meeting the Purpose and Need of this project, and the needs of the community and visitors.

56, 60

126) Minimize the number of trail designations and miles.

Resource specialists and experienced mountain biking consultants have analyzed the proposed area and designed the number of trials that the resource area can sustainably hold while also meeting the Purpose and Need of this project, and the needs of the community and visitors.

56

127) Eliminate parallel and duplicative trails. Parallel and duplicative trails are not always sustainable or desired, however, the Proposed Action includes some parallel trails, such as the Spring Creek Alternate Trail, in order to reduce conflicts.

10, 56, 59, 64, 88, 90

128) Incorporate a wide variety of trails from beginner to advanced level.

The Proposed Action includes a variety of trail classes, depending on location and terrain, which will help to separate user groups. Generally, trails near the Dry Lake campground and trailhead will be more beginner level (wider and smoother), while more remote trails will tend to be more advanced and rugged.

6, 83, 90 129) Address impacts from existing user-created

trails including a trail that parallels the Dry Lake irrigation ditch in the Soda Creek area;

Sustainable trail design and standards will be implemented as part of the Proposed Action. This includes making




trails at Dumont Lake and leading up to Rabbit Ears; and trails along the ridges next to the existing Grouse Trail.

improvements to existing trails and decommissioning of trails that are unsustainable.

Your comment regarding trails at Dumont Lake is outside of the project’s scope.

67

130) Trails near public access areas (campgrounds, day use, etc.) should be more user friendly and more remote trails should be more rugged/advanced.

The Proposed Action includes a variety of trail classes, depending on location and terrain, which will help to separate user groups. Generally, trails near the Dry Lake campground and trailhead will be more beginner level (wider and smoother), while more remote trails will tend to be more advanced and rugged. This has been incorporated into the proposed action.

27

131) Between Buffalo Pass Road and the North Fork of Fish Creek, we should utilize old roads associated with the power lines as part of the trail network. Minimal construction would be needed to connect these routes and create some loops. This will reduce the total miles of trail construction and provide good beginner and intermediate biking terrain.

These existing routes were incorporated into the Proposed Action where they were sustainable and would not create resource damage.

82 132) Construct new connecting trails that make

old routes into loop trails. Some existing routes were incorporated into the Proposed Action where they were sustainable and would not create resource damage.

84 133) Incorporate the old powerline roads to

provide motorized access to the top of Buffalo Pass near the 1101 parking lot.

Incorporating existing routes is discussed in the EA and Recreation Specialist Report. The map of the Proposed Action (p. E 75) shows the motorized trail coming very close




Timberline Trail Riders will assist with the construction of a bridge or low water crossing.

to the parking lot described. An addition to connect to the 1101 trailhead could be a future project, after field verification to determine feasibility.

11, 36, 52, 63, 80, 88,

90

134) Existing trails in the project area are remote, rugged, technical, and challenging. Preserve that experience by not modifying the trails so that they are overly manicured.

The proposed trail network will include a variety of trail classes, depending on location and terrain. Trails near developed campgrounds and parking areas will be primarily beginner level (smoother and wider), while more remote trails will generally be more advanced and rugged.

56, 80, 90

135) Design and maintain trails to be primitive to maximize the quality of the trail experience while decreasing the total miles of trail needed to meet desired experiences. This would reduce user speeds, user conflicts, and impacts on the environment.

The proposed trail network will include a variety of trail classes, depending on location and terrain, which will help to separate user groups and accommodate varying skill levels and desired conditions. Trails near campgrounds and developed areas will be primarily beginner level (wider and smoother), while more remote trails will generally be more advanced and rugged.

Sustainable trail design and standards, per Forest Service Manuals 2300, 2350, and FSH 2309.18, and design criteria (EA, Appendix D) are incorporated as part of the Proposed Action. These criteria and standards help to minimize user group conflicts, regulate speed with trail class, and avoid resource impacts.

80

136) Artificial features such as jumps, ramps, and downhill design are inappropriate in the project area and should be confined to private lands or limited segments of the ski area.

Trails will meet Forest Service standards, Incorporating jumps, ramps, etc. would not meet these standards, unless agreed to by the Forest Service. None are in the Proposed Action.




6, 7, 88

137) Uphill/downhill travel conflicts are a concern on the Spring Creek Trail. A second directional trail would help address this problem.

An alternate trail to the current Spring Creek Trail, Spring Creek Alternate/Trail Segment #12, is included in the Proposed Action to alleviate user group conflicts. However, it will not be a designated downhill or uphill trail. The Forest Service will monitor use and user group conflicts on the trail network and if it is determined that single speed gravity bikes are causing safety issues and/or user group conflicts, restrictions could be incorporated.

7 138) The Grouse Mountain and BTR trails

should be incorporated into the designated trail network.

Portions and re-routed portions of the Grouse Mountain Trail and BTR trails will be included where they are sustainable, or can be improved to be sustainable.

80

139) The proposed trail paralleling the Spring Creek Trail is duplicative, unnecessary, and will further fragment habitat.

The alternate trail to the current Spring Creek Trail, Spring Creek Alternate/Trail Segment #12, is included in the Proposed Action to alleviate user group conflicts.

Wildlife habitat loss was analyzed in detail in the Wildlife BA and Specialist Report and summarized in the EA. The Proposed Action was found to not have significant wildlife or wildlife habitat impacts.

21

140) Increase the number of trail miles for mountain bikes, including around the southwest flanks of Buffalo Mountain and the ridge above NFSR 301.1.

The existence of unauthorized trails, community desire for trails (Steamboat Trails Alliance, 2A proposal passing public vote) helped develop the Purpose and Need. Input from the Steamboat Trails Alliance, general public, and IMBA consultants have been reviewed by the Forest Service and resource specialists have analyzed the proposed area and designed the number of trials that the resource area can sustainably maintain.




Recreation- User Group Conflicts

56

141) Overcrowding of the Buffalo Pass Trails will lead to displacement of trail users to other areas on the district.

The Forest Service’s goal in building a variety of trails is to manage use for multiple uses. Use will be monitored and adjustments will be made accordingly in the future, if needed.

33

142) Minimize negative effects on hunting and angling opportunities. The Mad Creek and Long Park CRAs are especially important areas for big game hunting.

Consultation with Colorado Parks & Wildlife has occurred regularly on this project and they are in support of the project, overall. The Aquatics Specialist Report determined that there would not be a significant impact to fish populations as a result of the Proposed Action (EA, p. 13). Therefore, angling success will not be impacted.

The Proposed Action trails are not anticipated to significantly impact hunting. The majority of the trails on the north side of the Buffalo Pass Road are existing, so there will be very little new disturbance from increased number of trail corridors. On the south side of the Buffalo Pass Road, the majority of the trails are within ½ mile of the road. The trails in the Long Park CRA are on the edge of the boundary and may impact an area of approximately 330 acres, leaving a significant portion (approximately 99.6%) of this roadless area unaffected by this proposal.

83

143) Motorized trails aren’t very compatible with non-motorized trails. Motorized use is noisy and requires a greater need for enforcement.

The proposed trails are accessible for multiple user types in order to provide for diverse recreational opportunities, per Forest Service policy (FSM 2350.2.2). However, use can be regulated “to the extent necessary to provide for user and public safety; to protect…resources; to minimize conflict and maximize responsible use; to achieve recreation experience




objectives; and to comply with Federal and State laws,” (FSM 2350.3.5).

The Proposed Action design includes measures to minimize user group conflicts: 1) routes that are open to motorized use will be signed that they are also open to other users; 2) other routes will not be open to motorized use. Motorized and non-motorized use on single track trails has been successfully implemented in other locations.

33

144) Use partners such as Routt County Riders to help educate the public and minimize conflicts with wildlife and other users.

Upon project implementation, the Forest Service will work with partners such as Routt County Riders, CPW, and Yampatika, as needed to provide educational opportunities to minimize conflicts with wildlife and other users and promote ecological responsibility.

28, 45, 91

145) The proposed trails will impact big game herds and hunter experience/success. Also, there are potential conflicts between mountain bikers and hunters, especially in the fall, and these existing uses must be considered.

After consultation with CPW, analysis in the Wildlife Specialist Report and EA, and consideration of the existing heavy recreation use in the area, it was determined that the Proposed Action will allow the area to provide wildlife habitat and hunting access. Design criteria (EA, Appendix D) are incorporated into the Proposed Action to ensure that there are not significant impacts. The areas of highest concern to impact big game herds, Elk Production Areas and winter range, will be closed to use during a seasonal closure. Bike ride use in late fall during the big game rifle seasons is low.

6, 45, 83

146) Hiking-mountain biking conflicts exist on the Spring Creek Trail due to heavy use.

An alternate trail to the current Spring Creek Trail, Spring Creek Alternate/Trail Segment #12, is included in the Proposed Action to alleviate user group conflicts. The Forest Service will monitor use and user group conflicts on the trail




network and if it is determined that single speed gravity bikes are causing safety issues and/or user group conflicts, restrictions could be incorporated.

55

147) Mountain biking may have adverse impacts on hikers and equestrians. Construct trails for multi, but non-motorized, use.

The proposed trails are accessible for multiple user types in order to provide for diverse recreational opportunities, per Forest Service policy (FSM 2350.2.2). Trails can be dedicated to a specific use for user safety, to protect resources, or to achieve recreation experience objectives (FSM 2350.3.5) if conflicts develop.

Consistent with Forest Plan direction, the Proposed Action is designed to minimize user-group conflicts. The Forest Service will monitor trail use and may adapt management practices as needed to resolve conflicts.

17, 40, 43, 61, 80, 84,

86

148) Due to the exclusive nature of the proposed trails (i.e., for mountain bikes), user conflicts and enforcement problems will increase.

Consistent with Forest Plan direction, design and mitigation criteria are incorporated as part of the Proposed Action to minimize user group conflicts. The Forest Service will monitor trail use and may adapt management practices as needed to resolve conflicts. Currently, no management of these trails exists. This project will increase management, and through information and education, minimize conflicts.

80

149) Consider directional use trails to alleviate user conflicts.

Designated downhill routes in the project are not proposed in the final Proposed Action. While there are some challenging trails, which, due to their nature, will be used primarily for downhill biking, none of the proposed trails will be designated for downhill biking only. Signs will be posted at the bottoms of these trails informing users of heavy downhill




traffic. The Forest Service will monitor trail use and may adapt management practices as needed to resolve conflicts.

ROADLESS AND OTHER SPECIAL AREAS

12

150) Trails should not be constructed in the Fish Creek Roadless Area which serves as important security habitat for elk during the times when this trail would be most used.

The Colorado Roadless Rule does not prohibit trail construction in Colorado Roadless Areas (CRAs). We assume this comment is in reference to the Long Park Roadless Area, which encompasses portions of Fish Creek and its tributaries. The EA analyzes potential impacts from the Proposed Action to CRAs (EA, p. 16-20) and wildlife (EA, p. 35-40). Design criteria, such as implementing seasonal closures to elk production areas and winter range, are incorporated into the Proposed Action to avoid or minimize impacts to elk during critical times. (EA, Appendix D). CPW and Forest Service biologists agreed that effects to elk in this area are less than if proposals were in other areas of the CRAs. Based on analysis in the pre-scoping and pre-decision Regional Roadless Review and the EA, the Proposed Action will be consistent with the Colorado Roadless Rule and will not have a significant impact to the Long Park Roadless Area nor its resources. C

6, 32, 33, 56, 79, 82

151) Trails in the Mad Creek and Long Park Roadless areas would result in reduced habitat, habitat loss, habitat fragmentation, and impacts to wildlife including displacement of animals. Human disturbance and use in these high value areas are currently limited.

As described in the Wildlife Specialist Report, habitat fragmentation is considered across landscapes larger than Buffalo Pass Trails Project area. Habitat loss is used as an analysis tool instead of habitat fragmentation.

The Proposed Action will utilize approximately 9.7 miles of existing user-created trail in the 10.8 miles of total trail planned in the Mad Creek CRA. No user-created trails currently exist in the Long Park CRA. Approximately 5.04




miles (1.22 acres 0.003% of the 42,100 acre CRA) will be directly affected by the proposed trails in the Long Park CRA. Therefore, these impacts can be considered insignificant.

The EA analyzes other potential impacts from the Proposed Action to wildlife (EA, p. 35-40) and CRAs EA, p 16-20). Design criteria, such as seasonal closures, are incorporated into the Proposed Action to avoid or minimize impacts on CRAs and wildlife (EA, Appendix D). Based on analysis in the pre-scoping and pre-decision Regional Roadless Review and EA, the Proposed Action was found to be consistent with the Colorado Roadless Rule and will not have a significant impact to CRAs nor their resources.

33

152) Do not construct trails in or near roadless areas.

The Forest Service completed pre-scoping and pre-decision Regional Roadless Reviews and found the Proposed Action to be consistent with the Colorado Roadless Rule and roadless area management (EA, p. 18) of the Forest Plan. The rule does not prohibit motorized or non-motorized trail construction in CRAs.

91

153) Ensure trails in Roadless Areas are constructed properly.

Sustainable trail design and standards, per Forest Service Manuals 2300, 2350, and FSH 2309.18, and design criteria (EA, Appendix D) are incorporated for the whole project area as part of the Proposed Action to avoid or minimize potential resource impacts. Based on analysis in the EA, the Proposed Action will not have a significant impact on the CRAs.




91

154) Prohibit motorized use on trails in Roadless Areas.

Motorized use in roadless areas is not proposed as part of this project. The Proposed Action for this project includes implementation of a Closure Order to prohibit mountain bike and all other wheeled-vehicle use off of designated roads and trails, in accordance with 36 CFR 261.55 (c). Following project implementation, any issues related to enforcement will be addressed per Forest Service policy.

83

155) One user-created trail exists in the Soda Mountain portion of the Roadless Area. Proper design of this trail would be an improvement and would not result in new impacts on the Roadless Area.

Where possible, existing trails are incorporated as part of the Proposed Action, provided they meet or can be improved to meet Forest Service sustainability standards as outlined in FSMs 2300, 2350, and FSH 2309.18. Approximately 9.7 miles of the existing user-created trail in the Mad Creek CRA will be incorporated into the Proposed Action.

79, 82

156) The proposed trails would adversely affect both roadless areas, including roadless area characteristics 1, 3, 4, 6, and 7 and seriously downgrade 5.

The Forest Service completed pre-scoping and pre-decision Regional Roadless Reviews and found the Proposed Action to be consistent with the Colorado Roadless Rule and roadless area management. Sustainable trail design and standards, per Forest Service Manuals 2300, 2350, and FSH 2309.18, and design criteria (EA, Appendix D) are incorporated as part of the Proposed Action to avoid or minimize potential roadless area impacts impacts to soil, plant and animal diversity and scenic integrity. The purpose of the project is to provide trail-based recreation by managing a sustainable trail system in the Buffalo Pass area. This would provide better opportunities for primitive and semi-primitive non-motorized use, as described by roadless characteristic #5.




79

157) Having mountain bike trails in the two roadless areas, which are capable and available for wilderness designation according to the Forest Plan, would likely render them ineligible for wilderness designation because bicycles are not allowed in wilderness.

The Forest Service completed pre-scoping and pre-decision Regional Roadless Reviews and found the Proposed Action to be consistent with the Colorado Roadless Rule and roadless area management.

While both CRA was identified as available and capable for wilderness designation, neither CRA was recommended for wilderness designation in the Record of Decision for the FEIS of the Forest Plan.

79, 80

158) The proposed trails and their maintenance and use must not harm the features for which the Dry Lake and Soda Creek Potential Conservation Areas were designated.

Potential botany resource impacts in the PCAs are summarized in the EA and analyzed in detail in the Botany Specialist Report. Sustainable trail design and standards, per Forest Service Manuals 2300, 2350, and FSH 2309.18, and design criteria (EA, Appendix D) are incorporated as part of the Proposed Action to avoid or minimize impacts. The Proposed Action was determined to not have significant impacts.

PCAs are not regulated by Forest Service law, regulation, or policy. PCAs are certain areas in which surveys were conducted by the Colorado Natural Heritage Program to identify potentially high biological diversity. These resources were considered, and avoided if found.

33

159) Do not construct trails in or near conservation areas.

Sustainable trail design and standards, per Forest Service Manuals 2300, 2350, and FSH 2309.18, and design criteria (EA, Appendix D) are incorporated as part of the Proposed Action to avoid or minimize impact. Based on analysis in the EA and specialist reports, the Proposed Action will not have significant impacts to PCAs.




56, 80

160) Trails will permanently impact previously undeveloped areas of land in roadless areas. These areas should be preserved, and new trails should be concentrated in previously disturbed areas.

The Forest Service completed pre-scoping and pre-decision Regional Roadless Reviews and found the Proposed Action to be consistent with the Colorado Roadless Rule and roadless area management. The rule does not prohibit motorized or non-motorized trail construction in CRAs. 9.7 miles of existing user-created trails will be incorporated into the approximately 15.8 miles of trail proposed in the roadless areas. Sustainable trail design and standards, per Forest Service Manuals 2300, 2350, and FSH 2309.18, and design criteria (EA, Appendix D) are incorporated as part of the Proposed Action to avoid or minimize impacts from trail construction and use.

56

161) Implement seasonal closures of roadless areas to protect wildlife.

The Forest Service completed pre-scoping and pre-decision Regional Roadless Reviews and found the Proposed Action to be consistent with the Colorado Roadless Rule and roadless area management. Design criteria, including seasonal closures, are incorporated as part of the Proposed Action to avoid or minimize impacts to wildlife (EA, Appendix D).

56

162) Evaluate whether enforcement will be adequate on trails in roadless areas.

Following project implementation, any enforcement will be addressed per Forest Service policy. The Colorado Roadless Rule does not require any additional, or specific level of law enforcement.

27

163) The proposed trails between North Fork Fish Creek and Spring and Soda Creeks (roughly the Long Park Roadless Area with the exception of the north slope of Buffalo

The Forest Service completed pre-scoping and pre-decision Regional Roadless Reviews and found the Proposed Action to be consistent with the Colorado Roadless Rule and roadless area management. The rule does not prohibit




Mountain) seem unnecessary and would encroach on this undisturbed, wild canyon. Trail construction resources are probably better utilized north of Buffalo Pass Road.

motorized or non-motorized trail construction in Colorado roadless areas. Sustainable trail design and standards, per Forest Service Manuals 2300, 2350, and FSH 2309.18, and design criteria (EA, Appendix D) are incorporated as part of the Proposed Action to avoid or minimize impacts from the approximately 5 miles of trail (1.2 acres) in the Long Park CRA. Any potential resource impacts are analyzed in the EA. The EA determined that the Proposed Action will not have any significant resource impacts.

6, 45, 79

164) The Soda Mountain Trail in the Mad Creek Roadless Area provides the only hiking access to the Mount Zirkel Wilderness from Steamboat Springs or Dry Lake. The roadless area provides a good buffer to mitigate habitat fragmentation and impacts on the wilderness. Designating or improving trails for mountain bikes will lead to impacts to and management problems associated with wilderness.

As described in the Wildlife Specialist Report, habitat fragmentation is considered across landscapes larger than Buffalo Pass Trails Project area. Therefore, habitat loss is used as an analysis tool instead of habitat fragmentation.

The existing user-created Soda Mountain Trail is currently used by the mountain bikers, hikers, hunters and equestrians. The Proposed Action will utilize approximately 9.7 miles of this trail in the 10.8 miles of total trail planned in the Mad Creek CRA. The Proposed Action will implement sustainable recreation trail management per FSH 2309.18 20.2 objectives. Therefore, the amount of habitat loss from the Proposed Action can be considered insignificant.

Seasonal closures and buffers will be placed in areas of biological significance and have been included in the design criteria (EA, Appendix D) as part of the Proposed Action. Additionally, the Proposed Action includes implementation of a Closure Order to prohibit mountain bike and all other wheeled-vehicle use off of designated roads and trails, in accordance with 36 CFR 261.55 (c). Following




implementation, compliance and enforcement issues will be addressed per Forest Service policy.

SOILS AND HYDROLOGY

19, 21, 44, 79, 82, 91

165) Design trails according to IMBA and Forest Service standards to minimize impacts on soils and hydrology. Consider trail closures during wet periods to minimize impacts on soils and hydrology.

Sustainable trail design and standards, per Forest Service Manuals 2300, 2350, and FSH 2309.18, and design criteria (EA, Appendix D) are incorporated as part of the Proposed Action. These criteria and standards help to avoid or minimize resource impacts.

83

166) Motorized use and mountain bike use causes more erosion than hikers.

With proper trail design and user compliance, bicycle use on trails do not require more maintenance than non-motorized trails. Sustainable trail design and standards, per Forest Service Manuals 2300, 2350, and FSH 2309.18, and design criteria (EA, Appendix D) are incorporated as part of the Proposed Action to avoid or minimize impacts. Potential erosion impacts are analyzed in detail in the Soils and Watershed Specialist Reports and summarized in the EA.

79, 82

167) Trails, particularly trails in steep terrain or trails in wet or snow packed areas, will impact soils and water quality and will be difficult to maintain. Project design must follow the Forest Service Watershed Conservation Practices Handbook, FSH 2509.25.

Sustainable trail design, Forest Service standards, and design criteria, including Watershed Conservation Practices, (EA, Appendix D) are incorporated into the Proposed Action to avoid or minimize potential watershed and soils impacts.

79 168) The EA must contain a listing of mitigation

measures for reducing impacts to soils and Forest Service standards and guidelines, other environmental protection laws and regulations, sustainable trail design per Forest Service Manuals 2300, 2350, and




water bodies, and an evaluation of their likely effectiveness.

FSH 2309.18, along with design criteria and mitigation measures (EA, Appendix D) identified by the interdisciplinary team are incorporated as part of the Proposed Action to avoid or minimize resource impacts.

Pursuant to NEPA, the EA analyzes potential impacts that may result from the Proposed Action (p. 10-40). Based on this analysis, the Proposed Action will not result in significant impacts, which is documented in the Finding of No Significant Impact and Record of Decision.

45

169) The Wall, a steep section on the Spring Creek Trail, should be realigned due to erosion and safety issues. Properly designed stream crossings would be necessary for this realignment.

The Wall on the Spring Creek Trail is Steamboat Springs City property and therefore, outside of the scope of this analysis.

59

170) Incorporate trail design and designate/sign specific routes that will allow use during wet conditions and reduce overall impacts.

Forest Service standards and guidelines, other environmental protection laws and regulations, sustainable trail design per Forest Service Manuals 2300, 2350, and FSH 2309.18, along with design criteria and mitigation measures (EA, Appendix D) identified by the interdisciplinary team are incorporated as part of the Proposed Action to avoid or minimize resource impacts. Allowing trail use during wet conditions that would contribute to resource damage is against Forest Service policy (36 CFR 251.12 (c)). Trails will be closed to all users when wet.

Signage of routes will occur upon project implementation per Forest Service policy.




82

171) Biking and hiking the proposed trails on the north side of Soda Peak will be impossible due to springs and early summer snowpack.

The Proposed Action is chosen because it allowed for sustainability, resource protection, met user needs, and met Forest Service needs and standards. Forest Service standards and guidelines, other environmental protection laws and regulations, sustainable trail design per Forest Service Manuals 2300, 2350, and FSH 2309.18, along with design criteria and mitigation measures (EA, Appendix D) identified by the interdisciplinary team are incorporated as part of the Proposed Action to avoid or minimize resource impacts.

82

172) The decision must explain how the Forest Service plans to regulate fat tire bikes. Their impacts on the trail design and maintenance must be described.

There are currently no Forest Service policies specific to fat tire bikes. Any policies implemented in the future regarding the use of fat bikes on National Forest lands will be incorporated into the Buffalo Pass Trails management.

SPECIAL USES

21

173) The project may negatively impact the Steamboat Powdercat’s cabin in the project area associated with increased use and camping, parking, and potential vandalism.

Additional signs stating “No Camping” will be placed in proximity to the Powdercats Cabin. Violation of these signs is punishable by fines. If this is unsuccessful, a Closure Order in which dispersed camping will be prohibited within proximity to the Powdercat’s cabin.

THREATENED, ENDANGERED, AND SENSITIVE SPECIES

80, 91

174) Design trails to avoid or minimize impacts to sensitive plants and plant species of local concern.

Sustainable trail design and standards, per Forest Service Manuals 2300, 2350, and FSH 2309.18, and design criteria (EA, Appendix D) are incorporated as part of the Proposed Action to avoid or minimize potential resource impacts. This includes making improvements to existing trails and




decommissioning of unsustainable trails. The EA determined that the Proposed Action will not have a significant resource impact.

33, 79, 82, 91

175) Address weed spread. Design trails and implement revegetation, weed treatments, and monitoring to control invasive plants over the long-term.

Sustainable trail design and standards, per Forest Service Manuals 2300, 2350, and FSH 2309.18, and design criteria (EA, Appendix D – Botany #4, P. 68) are incorporated as part of the Proposed Action to avoid or minimize potential resource impacts. This includes making improvements to existing trails and decommissioning of unsustainable trails, weed control monitoring, and weed treatment, per Forest Service policy.

Based on analysis in the EA and the Botany Specialist Report, the Proposed Action will not have a significant resource impact.

79

176) Weed surveys should be used to detect rare plants and these species including a sizable buffer should be protected.

No Threatened, Endangered, Candidate, or Proposed Federally-listed species are known to occur in the project area. On-the-ground surveys and past data review for Region 2 Sensitive plants and Species of Local Concern were completed and potential impacts are analyzed in depth in the Botany Specialist Report and summarized in the EA (p. 13-16). Design criteria and mitigation measures (EA, Appendix D) will be implemented as part of the Proposed Action to avoid or minimize impacts to these species, resulting in no significant impacts.

56 177) Evaluate the effects of publicity-driven

growth and use on newly designated trails such as the Soda Mountain Trail.

The Proposed Action is designed to provide for recreational opportunities in an environmentally acceptable manner that responds to the needs of National Forest customers and




local communities (Forest Plan 1-1 and Regional Goals #2 and #4). Potential impacts that may occur as a result of the Proposed Action are analyzed in the EA. Monitoring of trail use and trends is an ongoing management responsibility.

33

178) Do not construct trails in or near historical boreal toad sites or drainages with conservation populations of cutthroat trout.

An existing user trail that goes through a historic boreal toad site will be closed and rehabilitated. Design criteria (EA, Appendix D) are incorporated into the Proposed Action to avoid or minimize any impacts to boreal toads or cutthroat trout. Potential impacts that may occur to these species as a result of the Proposed Action are analyzed in the Aquatics Specialist Report and summarized in the EA. The Proposed Action was determined to not have a significant impact on these species.

33

179) Surveys and monitoring should be conducted for all proposed trails for threatened, endangered, sensitive species or raptor nests. Survey design should consider buffer zone requirements.

Surveys, monitoring, and design criteria for protection of threatened, endangered, sensitive species and raptor nests are incorporated into the design criteria (EA, Appendix D, p. 71-73) as part of the Proposed Action. Please refer to the Wildlife section of the EA for more details on design criteria, such as buffer zones and timing restrictions for applicable species (p. 35-40).

Potential impacts to threatened, endangered, sensitive species or raptor nests that may occur as a result of the Proposed Action are analyzed in the EA (p. 35-40). Based on analysis in the EA and the Wildlife BA, Proposed Action will not have a significant impact on these species (EA, p. 41-43).

VISUAL RESOURCES




91

180) Visual resources and scenic quality will be enhanced by the proposed trails.

Potential impacts to visual resources and scenic quality were analyzed in the EA (p. 30-31) and the Visual Resources Specialist Report. It was determined that the Proposed Action would not have significant impacts to visual resources (EA, p. 43).

WILDLIFE

32, 45, 79, 82

181) Mountain bikes and OHVs move at great speed and often with little noise and can disturb and stress wildlife in the area, including deer, elk, marmot, voles and other creatures. Trails can fragment habitat and displace wildlife as has happened elsewhere in the area (e.g., Emerald Mountain).

Design criteria are incorporated as part of the Proposed Action to avoid or minimize impacts on wildlife and habitat (EA, Appendix D). Potential impacts to wildlife and habitat that may result from the Proposed Action are described in the EA. Based on analysis in the EA and the Wildlife BA and Specialist Report, the Proposed Action will not have a significant impact on these species.

33

182) Increased human presence may alter wildlife behavior including movement patterns, habitat selection, feeding, and avoidance of areas with trails.

Design criteria (EA, Appendix D) are incorporated as part of the Proposed Action to avoid or minimize impacts on wildlife and habitat. Potential impacts to wildlife and habitat that may result from the Proposed Action are described in the EA (p. 34-40). Based on analysis in the EA and the Wildlife BA and Specialist Report, the Proposed Action will not have a significant impact on these species (EA, p. 43).

33

183) Monitor the effects of trail construction and use on wildlife.

Monitoring of wildlife populations in coordination with CPW is on-going across the project area. Design criteria (EA, Appendix D) are incorporated as part of the Proposed Action.




66, 80

184) Human presence negatively affects all forms of wildlife.

Design criteria (EA, Appendix D) are incorporated as part of the Proposed Action to avoid or minimize impacts on wildlife. Potential impacts to wildlife that may result from the Proposed Action are described in the EA. Based on analysis in the EA and the Wildlife BA and Specialist Report, the Proposed Action will not have a significant impact on wildlife.

33

185) The increase in human activity associated with the new trails will increase the potential for human-wildlife conflicts, wildlife habituation, and dispersal of animals to private lands. This may result in human injury or property damage and costs to private landowners.

Signage and other forms of information/education opportunities will be implemented as needed to inform the public of the potential for human-wildlife conflicts and how to minimize this potential (e.g. keeping pets under voice control or leashed). Wildlife habituation awareness information will also be posted at trailheads and wildlife-resistant trash receptacles will be at the trailhead, as mandated on the Forest.

The Forest Service has been working with CPW on reducing game damage on private lands by implementing winter range closures outside of this analysis. The Proposed Action is adding an additional winter closure to Management Area 7.1, which includes Spring Creek trail (NFST 1160) from December 1 to April 15. If monitoring determines that elk are still moving onto private lands, further closure may be implemented.

33 186) Utilize bear-proof trash receptacles at

trailheads and other designated locations. Trash receptacles will meet the MBRTB’s requirement for bear-proof trash cans in newly constructed facilities.

33 187) Enforce and educate the public regarding

keeping pets on leash or in direct control at all times to reduce risk of injury to trail users

Per Forest Service policy (36 CFR 261.8 (d)), pets must be within control. Colorado Revised Statue 33-6-128 (2) prohibits the harassment of wildlife by pets. Signage will




and harassment, injury, or mortality of wildlife.

inform trail users of these policies and enforcement by the Forest Service and Colorado Parks & Wildlife will occur per standards, unless a need for increased enforcement is determined.

82

188) The value of the Soda Peak ridge area is significant to wildlife and should be protected.

Forest Service and CPW surveys during the 2015 field season did not determine any biological wildlife significance in the Soda Mountain area or the ridge parallel to Soda Creek. Design criteria (EA, Appendix D) are incorporated as part of the Proposed Action to avoid or minimize impacts on wildlife across the entire project. Wildlife use during the time of year in your comments do not overlap with trail use. Therefore, there will not be a significant wildlife impact as a result of the Proposed Action (EA, p. 43).

82

189) Trails on the Soda Peak ridge will impact a unique alpine/tundra biological niche and seasonal habitat important to a variety of wildlife and other species.

Forest Service and CPW surveys during the 2015 field season did not determine any biological wildlife significance in the Soda Mountain area or the ridge parallel to Soda Creek. Design criteria (EA, Appendix D) are incorporated as part of the Proposed Action to avoid or minimize impacts on wildlife across the entire project. The prohibition of mechanized travel off of designated routes will prevent further degradation of this niche by avoiding additional user created trails. There will not be a significant wildlife impact as a result of the Proposed Action (EA, p. 43).

Portions of the existing user-created trail that will be incorporated into the Proposed Action and newly constructed trail in this area will be located to minimize amphibian, plant, and watershed impacts per design criteria (EA, Appendix D).




Therefore, there will not be a significant impact to these resources as a result of the Proposed Action (EA, p. 43).

82

190) Mountain bikers and mountain bike trails have greater impacts on wildlife than hikers and hiking trails.

At this time, there is little information in the scientific literature that supports or refutes this comment.

Design criteria (EA, Appendix D) are incorporated as part of the Proposed Action to avoid or minimize impacts on wildlife. Potential impacts to wildlife that may result from the Proposed Action are described in the EA. Based on analysis in the EA and the Wildlife BA and Specialist Report, the Proposed Action will not have a significant impact on wildlife (EA, p. 43).

32

191) Predators are brought into close contact with trail users as a result of displaced prey species.

At this time, there is little information in the scientific literature that supports or refutes this comment.

Design criteria (EA, Appendix D) are incorporated as part of the Proposed Action to avoid or minimize impacts on wildlife. Information will be provided alerting humans on potential for wildlife encounters and suggestions on how to react appropriately to reduce negative wildlife-human encounters. Any potential wildlife impacts that may result from the Proposed Action are described in the EA (p. 35-40) and analyzed in detail in the Wildlife BA and Specialist Report. Based on analysis in these documents, the Proposed Action will not have a significant impact on wildlife (EA, p. 43).

32

192) Improving the Dry Lake parking area will affect year-round recreation use and may have the unintended consequence of increased snowmobile usage in the winter

The Dry Lake parking facilities will be improved for visitor use with the installation of an accessible toilet and updated trailhead signs. Increasing the capacity of the parking lot




months. This would further impact and stress wildlife populations in the Buffalo Pass area.

may be assessed in the future in a separate NEPA analysis, but is not included in this project analysis.

Any potential recreational impacts that may result from the Proposed Action are analyzed in the EA (p. 35-40).Based on analysis in the EA, the Proposed Action will not have a significant impact on recreation or wildlife (EA, p. 43).

Over the snow mechanized use in the project area is determined by the Forest Plan and the HPBE Ranger District’s Winter Recreation EA and is outside of the scope of the project. Please refer to the Forest Plan and Winter Recreation EA for more information.

32

193) Trail use may impact wildlife during seasons when wildlife and big game are easily stressed such as elk calving season.

Design criteria (EA, Appendix D), such as protecting elk calving and winter range areas, are incorporated into the Proposed Action to avoid or minimize impacts. Potential impacts to wildlife that may result from the Proposed Action are described in the EA. Based on analysis in the EA and the Finding of No Significant Impact, the Proposed Action will not have a significant impact on wildlife (EA, p. 43 and FONSI, p. 48).

33

194) Implement enforceable/mandatory seasonal closures on proposed trails within ¼ mile of active raptor nests and in big game production areas and winter range. Closures should apply to all user types and should be in place during construction and maintenance activities.

Design criteria specific to raptors and elk are incorporated as part of the Proposed Action to avoid or minimize impacts on wildlife. For details on these design criteria, especially those that pertain to raptor nests and big game, please refer to the Appendix D of the EA.

Potential impacts to wildlife that may result from the Proposed Action are described in the EA (p. 35-40). Based on analysis in the EA and the Wildlife BA and Specialist




Report, the Proposed Action will not have a significant impact on wildlife (EA, p. 43).

58

195) The proposed trails should avoid fragmentation and impacts on wildlife and birds.

. Potential impacts to these species that may result from the Proposed Action are described in the EA (EA, p. 35-40). Based on analysis in the EA and the Wildlife BA and Specialist Report, the Proposed Action will not have a significant impact on wildlife or birds (EA, p. 43 and FONSI, p. 48). Design criteria (EA, Appendix D) are incorporated as part of the Proposed Action to avoid or minimize impacts on wildlife and birds

33

196) The proposed trails will likely result in permanent habitat fragmentation, and cumulative effects may impede wildlife movement across the landscape and decrease their occupancy in the “edges.”

Potential impacts to wildlife and wildlife-human interactions are analyzed in the EA (p. 35-40). Based on analysis in the EA and the Wildlife BA and Specialist Report, the Proposed Action will not have a significant impact on these species (EA, p. 43 and FONSI, p. 48).

Design criteria (EA, Appendix D) are incorporated as part of the Proposed Action to avoid or minimize direct, indirect, or cumulative impacts on wildlife. Seasonal closures and buffers will be placed in areas of biological significance and have been included in the design criteria as part of the proposed action. For example, high quality lynx habitat attributes will be avoided to reduce bisecting habitat blocks.

33

197) Looped trails may create islands of habitat that would be avoided by wildlife.

The project area was identified as an area that already receives high recreational use and is bisected by the Buffalo Pass Road, powerlines, and the powerline service roads. Looping trails off the Buffalo Pass Road and the powerline




roads (NFSR 301 and 305) will reduce impacts to wildlife more than long distance, widely-spaced trail systems.

Design criteria (EA, Appendix D) are incorporated as part of the Proposed Action to avoid or minimize impacts on wildlife and their habitat.

Potential impacts to these species and their habitat that may result from the Proposed Action are described in the EA. Based on analysis in the EA and the Wildlife BA and Specialist Report, the Proposed Action will not have a significant impact on wildlife or wildlife habitat.

33

198) Minimize trail zones of influence and effects to wildlife. This may include using natural topography and drainages to buffer impacts to wildlife from the proposed trails.

Design criteria (EA, Appendix D) are incorporated as part of the Proposed Action to avoid or minimize impacts on wildlife. Any potential wildlife impacts that may result from the Proposed Action are described in the EA. Based on analysis in the EA and the Wildlife BA and Specialist Report, the Proposed Action will not have a significant impact on wildlife.

37

199) Trails that go far from the road system into areas with little human impact would be the most disruptive to wildlife, reducing the amount of habitat where animals feel secure and not stressed and displacing animals. Proposed trails of concern include:

d. One trail on the ridge between the two forks of Soda Creek to Soda Mountain.

The project area was identified as an area that already receives high recreational use and is bisected by the Buffalo Pass Road, powerlines, and the powerline service roads. Looping trails off the Buffalo Pass Road and the powerline roads (NFSR 301 and 305) will reduce impacts to wildlife more than long distance, widely-spaced trail systems.

Design criteria are incorporated as part of the Proposed Action to avoid or minimize impacts on wildlife and their habitat.

Potential impacts to these species and their habitat that may result from the Proposed Action are described in the EA.




e. Two trails leaving NFSR 301.1 and headed north into Spring Creek and up to Buffalo Pass Road.

f. One trail that accesses Buffalo Mountain.

Based on analysis in the EA and the Wildlife BA and Specialist Report, the Proposed Action will not have a significant impact on wildlife or wildlife habitat.

21, 91

200) Increases in dispersed camping and associated human waste and trash will impact wildlife and other resources.

Design criteria are incorporated as part of the Proposed Action to avoid or minimize impacts on wildlife and their habitat. Any potential indirect impacts to wildlife, that may result from the Proposed Action are analyzed in the EA. Based on analysis in the EA and the Wildlife BA and Specialist Report, the Proposed Action will not have a significant impact on wildlife or wildlife habitat.

Following project implementation, compliance and enforcement issues related to human waste and trash in the project area will be addressed in accordance with Forest Service policy. Regulations are already in place regarding dispersed camping rules, without regards to this decision.

79

201) Species that may be adversely affected by the proposed action include, but are not limited to: lynx, marten, goshawk, golden-crowned kinglet, boreal owl, snowshoe hare, Colorado River cutthroat trout, deer, elk, and southern red-backed vole. Goshawk, golden-crowned kinglet, and cutthroat trout are Forest Service management indicator species.

Design criteria (Appendix D) are incorporated as part of the Proposed Action to avoid or minimize resource impacts, including wildlife, birds, and fish. Potential impacts to wildlife that may result from the Proposed Action are analyzed in the EA. Based on analysis in the EA and the Wildlife BA and Specialist Report, the Proposed Action will not have a significant impact on wildlife or wildlife habitat.




79

202) Proposed trails, especially the one through the Mad Creek Roadless Area, would provide potential new routes for winter snowmobile use. This would adversely affect lynx, marten, and their prey such as snowshoe hare and southern red-backed vole. Snow compaction would make it easier for animals competing with lynx for prey to navigate in the area, and would impact species that live under the snow such as marten.

Snowmobile travel is permitted in these areas, per Management Area 1.32 direction and the Winter Recreation Management EA. Any winter use will continue to be managed per the previous decision.

Design criteria are incorporated as part of the Proposed Action to avoid or minimize direct, indirect, or cumulative impacts on wildlife, including snow compaction impacts. Potential wildlife impacts are analyzed in the EA. Based on analysis in the EA and the Wildlife BA and Specialist Report, the Proposed Action will not have a significant impact on these species.

79

203) Trails must avoid areas near raptor nests consistent with wildlife standards in the Forest Plan. Bike trails should be considered similar to motor vehicle routes for purposes of determining habitat effectiveness.

Design criteria (EA, Appendix D, p. 71-73) are incorporated as part of the Proposed Action to avoid or minimize impacts on wildlife.

Potential impacts to wildlife that may result from the Proposed Action are described in the EA. Based on analysis in the EA and the Wildlife BA and Specialist Report, the Proposed Action will not have a significant impact on wildlife.

56

204) Use the best available science to evaluate effects of roads and trails on habitat effectiveness and connectivity.

Potential impacts to wildlife that may result from the Proposed Action are described in the EA. Based on analysis in the EA and the Wildlife BA and Specialist Report, the Proposed Action will not have a significant impact on wildlife.

56

205) Use the best available trail planning methods to reduce habitat fragmentation associated with motorized and mechanized trails.

Sustainable trail design and standards, per Forest Service Manuals 2300, 2350, and FSH 2309.18, and design criteria are incorporated as part of the Proposed Action to avoid or minimize potential resource impacts. This includes making




improvements to existing trails and decommissioning of unsustainable trails. Based on analysis in the EA and the Wildlife BA and Specialist Report, the Proposed Action will not have a significant resource impact.

56 206) Ensure that seasonal trail closures meet

CPW standards. All wildlife-related seasonal closures were developed in coordination with CPW.

33

207) Reduced hunting success associated with the trails may limit wildlife managers’ ability to effectively manage wildlife populations.

Consultation with Colorado Parks & Wildlife has occurred regularly on this project and they are in support of the project, overall. The Proposed Action is adding an additional winter closure to existing winter closures to protect Elk Production Areas and winter range Management Area 7.1, which includes Spring Creek trail (NFST 1160) from December 1 to April 15. If monitoring determines that elk are still moving onto private lands, further closure may be implemented.

Additionally, the majority of the trails on the north side of the Buffalo Pass Road are existing, so there will be very little new disturbance. On the south side of the Buffalo Pass Road, the majority of the trails are within ½ mile of the road. The trails in the Long Park CRA are on the edge of the boundary and affect an area of approximately 330 acres, leaving a significant portion (approximately 99.6%) of this roadless area unaffected by this proposal for wildlife and hunting.

80 208) Minimize impacts on nocturnal wildlife by

closing trails at night. At this time, there is little information in the scientific literature to support or refute this comment. However, the Wildlife Specialist Report determined that there would not be




a significant impact to nocturnal wildlife from the Proposed Action.

80

209) Prohibit winter use by fat bikes, skis, snowshoes, and over the snow vehicles in critical wildlife habitat areas.

The Proposed Action is adding a winter closure to protect Elk Production Areas and winter range Management Area 7.1, which includes Spring Creek trail (NFST 1160) from December 1 to April 15.

Over the snow mechanized use in the project area is determined by the Forest Plan and the HPBE Ranger District’s Winter Recreation EA and is outside of the scope of the project. Please refer to the Forest Plan and Winter Recreation EA for more information.

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