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To: Cam Hooley From: Trails 2000 Date: September 30, 2016 Re: Hermosa Comments

Dear Cam:

Trails 2000 is commenting on the Forest Service Management Plan for the Hermosa Creek Watershed Management Plan and Travel Management Proposal for Hermosa:

Of particular interest are the following areas:

Mountain bikes have been enjoyed by the public on a network of trails in the Hermosa Creek Watershed area for 30 years under an “open to cross-country travel” policy. Riding cow trails, game trails, and other previously existing use trails was legal. This has lead to consistent and historical use of many miles of trails that have never been officially designated as part of the Forest Service System, yet have been enjoyed legally for many years. While the desire to move to a “designated system” is understandable and agreeable, appropriate interim steps must be taken to first inventory the existing routes, and then designate into the system the appropriate and valued trails before banning use from these existing assets.

Previously, 107,800 acres within the Hermosa Watershed was available to mountain bikes. With the additional 2014 Wilderness and Wilderness Study Areas in recent years and due to the new management changes, the loss of mountain bike areas is a significant loss to the public. Trails 2000 was an integral partner in the community collaboration of creating the Bill and supported the process because it was intended to

create a compromise that retained access outside of the Wilderness boundaries; now that access is being threatened from this current proposal. The future negative economic impact to the outdoor recreation economy of the region due to the proposed closures of the following list of existing trails should be considered and their value weighed in any decisions. While the addition of West Cross Creek as a system trail is a positive development, it does not remedy or replace the trails that are being closed in the proposed Travel Management Plan. Trails 2000 urges the Forest Service to implement an interim “limited to existing” policy until adequate inventory and review can take place.

Trails 2000 attended all but one of the Hermosa site visits and has been actively involved with the process and in creating solutions. Please consider these specific items in developing the final plan to remedy the loss of mountain bike access include:

A. Maintain access to existing trails by establishing an interim policy of “limited to existing”

While legislative constraints need to be considered, an interim plan alternative to establish key cross-country routes as “designated” is desirable under the Plan. In other words, while we can support a policy limited to designated trails and routes, a thorough process to establish a designated system must first take place before making a switch to limited to designated. These historic routes (listed below) have been used over the past 30 years, which indicates that there is a need for these routes and that they are valued by the public. However, it is problematic that these existing established routes are currently being utilized as “cross-country” as these routes have not yet been designated as part of the system.

Trails 2000 understands it will take time to designate these routes and that some routes may pose resource or other concerns that must be addressed; therefore, we would like to propose an interim approach by providing assessment and GPS services for these routes, which will be shared with FS staff. The interim approach is a "limited to existing routes" approach that can provide for a fair, balanced and reasonable compromise to public access while the FS goes through a more thorough NEPA review to designate an official system. This solution will allow management of the trails and access for mountain bikers during the interim, until routes can be officially designated. The interim approach assists with compliance and buy-in as opposed to turning the switch from open to closed after three decades of use. We believe this

approach is a fair and balanced compromise to help achieve the Forest Service goals while preserving public access and enjoyment of our public lands, all the while creating a transparent public process to appropriately prevent unmanaged recreation.

B. Routes to be included as designated:

1. Big Lick: This trail has been open to mountain bikes and cross-country travel for 30 years. The trail connects both “the Divide” and the Hermosa Park road to the Hermosa Trail, a great connect. The Wilderness area provides endless access of exclusive use for hike and horse travel, and creating more share the trails opportunities when they are available seems very much in line with the trail communities’ expectations. The FS Roundtable has successfully promoted share the trail ethics for almost a decade; we believe more multi use access is appropriate, particularly when the Wilderness already allows exclusive horse and hike access. The mountain bike community is growing and seeking more opportunities, not less. Trails 2000 will adopt and/or assist with any current adopters to maintain this section of trail.

2. Relay Creek and Graysil: There are several trail maps going back at least 20 years, some of which were produced by a FS employee (see attached Bicycle Routes on Public Lands of Southwest Colorado), which promote the Relay Creek access loop utilizing single track and old gated logging roads, which continue to be used by mountain bikers today. A detailed map and description appears in the attachment. Please include this route as a system/designated route in the released plan. Trails 2000 will adopt and maintain this section of trail.

3. The BRNRT: This BRNRT (listed on the Lat 40 map) is a fantastic existing trail connection between Purgatory ski area, designated for recreation, and the upper Hermosa Creek Trailhead. This is an important connection that reduces road congestion, and allows users to access trails from Purgatory into Hermosa and onto Relay Creek. As you know, upper Hermosa and the campground see a substantial amount of truck, trailer, and 4wheeler traffic. Allowing bikes to access Hermosa Creek from Purgatory to the trailhead will help keep people off the road and is significantly safer access providing a much better user experience. Trails 2000 will adopt and maintain this section of trail.

4. Seth’s Trail: The trail (as listed on Lat 40 map) provides a safe connection parallel to FS 516 between the lower Hermosa Creek Trailhead and CR 201. As you know from closing the campground, the

area receives heavy car traffic. Moving bike traffic off the road is very helpful for all users. A local mountain biker was hit head on by a car on the lower road; a very serious accident. We would like the route from the campground down the road to the first cattle guard to be open for bike and foot traffic to alleviate conflict and provide a safe alternative. Trails 2000 will adopt and maintain this section of trail.

5. Hermosa Creek to the Colorado Trail: At the time of the Hermosa Wilderness planning, Trails 2000 met with the San Juan Citizens Alliance and the Wilderness Society to develop an alternative to closing 37 miles of the Colorado Trail and Hermosa Creek to mountain bikes, per the Forest Service plan. We developed the original proposal offering the suggestion of the Special Management Area surrounding the Wilderness in order to keep both iconic trails open to bikes. Mountain bikes have been on the Hermosa and the CT for 30 years. The economic impact of bike access in La Plata County cannot be understated. More national, world Champions and Olympians live in Durango than any other town in the country per capita. Fort Lewis College and their 20 time national championship cycling team and the DEVO junior development mountain bike program are two of the most successful in the country. Mountain bikers have been riding, maintaining and caring for the area for decades. We value their input as stewards of the lands.

As part of our coalition building for the Hermosa Creek Wilderness, Senator Bennet requested to FS Supervisor Mark Stiles that an alignment to connect the CT to Hermosa be analyzed in this planning (letter is attached). There are four major southern connectors (Big Bend, South Fork, Cape of Good Hope and Clear Creek) now closed to mountain bikes per the Wilderness designation. The request to study a connector was to provide access to mountain bikes.

Buck Creek is an unusable mountain bike route, and the topography precludes changing that fact; therefore, we would like to request the proposal Trails 2000 submitted be analyzed, studied in NEPA, and included as an alternative in this plan, to be built as funds allowed.

6. The 1990 County Trails Plan includes a Colorado Trail to town connector, a top five priority decided through a multi year public process. Included in that is a Hermosa to town connect. We request the Forest Service work with Trails 2000 to develop a connector from lower Hermosa road, over the creek to Tripp Creek. A bridge and connection would be wonderful for fishing, bike access, and to reduce

shuttles on the road by providing a bike access (road and mountain bike) from CR 203 or Tripp Creek to Hermosa.

7. All trails in Purgatory and the re-opening the 1993 World’s downhill run should be open to mountain bikes with the understanding that changes will be implemented to address sustainability.

8. Ebikes are a new and popular mode of alternative transportation. We request the Forest Service allow an EBike route perhaps as consideration for inclusion on a non motorized yet mountain bike accessible route, such as West Cross Creek and Hermosa Creek.

Funding. Trails 2000 understands the budget constraints the Forest Service faces. As a result, Trails 2000 is offering to adopt more trails, GPS more trails, assist with certified saw crews to clear more trails and promote donations to the Forest Foundation Fund.

Language. Regarding the "designated routes" language, the International Mountain Bike Association has in other places found a remedy for this by working directly with the land manager as the land management travel plans are finalized. We understand the Special Management Area language is different from the Travel Management Area language. We would like the historic routes enjoyed by mountain bikes that are located inside the Travel Management Area, but outside the SMA, to remain.

Thank you for your time in preparing the plan, and we look forward to working with you on the continued iterations as the plans develop.

Sincerely, Mary

Mary Monroe Brown Executive Director Trails 2000

CC: John Whitney, (Senator Bennet) Darlene Marcus, (Congressman Tipton) Aaron Clark, IMBA Government Relations