Colorado Parks and Wildlife                                                                                                                        September 19, 2018

State Trails Program

13787 US Hwy 85

North Littleton, CO 80125

Public Comment – 2018 Colorado the Beautiful Grant:

Pioneer’s Redefined – West End Trails Master Development Plan

Thank you for the opportunity to comment on the West End Trails Master Plan submitted for your consideration under the Colorado the Beautiful grant program. I am submitting my comments on behalf of the Colorado Chapter of Backcountry Hunters & Anglers, where I voluntarily serve as the Regional Director for the Central West Slope. I am also a 30-year resident of Norwood, Colorado, and retired wildlife biologist from the Norwood and Ouray ranger districts of the GMUG National Forests.

I wish to express several concerns with the planning proposal as submitted, primarily with the potential impacts of trail development upon wildlife in the areas identified in the application.

Big Game Winter Range: All seven of the proposed planning areas are located within big game winter range. In the past, such projects as Burn Canyon and Thunder Trails included seasonal closures to mitigate impacts to wintering elk and mule deer.  However, user compliance with these closures has been a complete failure. Both the BLM and Forest Service have placed kiosks and trail signs at various locations to notify the public of the closures, but signing has been ineffective at preventing mountain bikes from riding the trails. There is very little to no agency law enforcement presence at either trail system either. 

In addition to this use, both trail systems have become cross-country ski trails in the winter months when snow conditions are favorable. Both agencies have allowed this use to develop without further analysis of the impacts to wildlife. In fact, Norwood Parks and Recreation is now designating and grooming cross-country ski trails in the Busted Arm area after receiving approval from the US Forest Service.

Both projects have greatly increased recreational use within these big game winter ranges, and displaced elk and mule deer from preferred winter ranges to adjacent private lands or to lesser quality winter range on public lands. There is no reason to think that any new trails within the planning areas will not have the same result. The State Trails Program through its representatives on the grant committee must recognize this fact and understand that the proponents and the federal agencies will not be able to enforce any compliance with such mitigation, and that any development will displace big game from their preferred winter ranges and result in a loss of big game habitat capability.

During my career with the Forest Service, I served on the Uncompahgre Habitat Partnership Program committee for 11 years. Our mission was to help landowners and producers with conflicts they were having with damage to fences and forage from large concentrations of big game. One of the biggest problems we faced, and which continues today, is elk migrating into the Nucla area during the winter and spring. We implemented several habitat improvement projects on adjacent public lands to attract and hold elk with some success. We also instituted additional private land elk hunts and game damage hunts to discourage elk from staying on the affected private lands.  

Three of the five planning areas around the town of Nucla are located exactly within the areas we have been trying to attract and hold elk to reduce conflicts with the local landowners and producers. Those areas include the Nucla North area and the two Nucla East areas. Based on the location of these areas and ineffectiveness of seasonal closures, any trail developments in these polygons will very likely result in additional game damage and conflicts with agriculture in Nucla.

Burn Canyon Area: The application includes a proposal for 10 miles of trail within the Burn Canyon area near Norwood. In November of 2014 the BLM completed a travel management plan for the Burn Canyon area and approved the construction of single-track mountain bike and motorcycle trails, trail head parking lots, and decommissioning various roads. To date, the mountain bike trail system has been constructed and a few roads decommissioned within the project area. The motorcycle trails have not been constructed yet.

This has all been recently evaluated under NEPA and included public input from people beyond the original proponents; people such as ranchers, sportsmen, conservationists, and other interests. As I mentioned previously, the BLM decision includes seasonal closures to mitigate impacts to big game on their winter range. This project area lies within a 32,000 acre wildfire that occurred in 2002, which created a significant winter range area within the San Miguel watershed. Unfortunately, compliance with the seasonal closures is a failure, and other uses such as cross-country skiing have developed since the trails were constructed. Additional trails within the same project area just do not make any sense. Ten more miles of trail would only exacerbate the existing problems in this area.

Busted Arm Area: The application also includes an estimated 10 miles of trail within the Busted Arm area of the Uncompahgre National Forest. In 2002 the Forest Service completed a travel management plan for the Uncompahgre National Forest which includes this area of the Norwood ranger district.  Following that forest-wide travel plan, the District evaluated and approved a system of single-track trails in the Thunder Trails area in 2011. Since that time all of the trails and dispersed camping sites were constructed and several miles of road decommissioning was completed by the Forest Service and its partners.

The Busted Arm area was included in this NEPA document. Based on their analysis and public input, trail development was specifically excluded from the Busted Arm area under any alternative considered in detail to “prevent unacceptable impacts to Gunnison sage grouse nesting habitat and to big game travel through the Goshorn Creek drainage” (page 8 Thunder Trails project EA).

The situation on the ground has not changed since the 2011 decision. Gunnison sage grouse and big game habitat remains relatively intact. Additional mountain bike trails previously proposed in this area were already determined to likely result in unacceptable impacts to wildlife. It makes no sense to proceed with another analysis to end up with the same conclusion. This area is not suitable for single-track trail development.

Craig Grother

Regional Director, Central West Slope

Backcountry Hunters & Anglers