San Carlos Ranger District -

Thank you for the opportunity to comment on the San Carlos Ranger District’s Draft Travel Analysis. Please consider my comments to be part of the public record.

First, I will address certain roads that are mis-categorized in terms of benefit and risk.

1. Road 173B (North Taylor Creek above the Rainbow Trail). Whereas lower portions of 173 allow Rainbow Trail motorized and non-motorized users to enter and exit the trail, the upper portion dead ends at the wilderness boundary, making it less desirable for motorized recreation. Its location is highly susceptible to sheet erosion in spots, and there is very little parking for users of the North Taylor Creek Trail.

To prevent further erosion and protect elk habitat on the ridge between North Taylor and Verde creeks, FSR 173 should be  decommissioned and converted to a trail above the Rainbow Trail crossing, with some provision made for trailhead parking at that point.

2. Roads 322, 328, and 329 off of the Ophir Creek Road. Access to these roads currently is blocked by the owner of the inholding that they cross, who has installed a locked gate. Thus their recreational use benefit is clearly zero, as indicated in the spreadsheet. A lack of public access will impact use of these roads for fuelwood cutting, hunting, mushroom-hunting, etc. Decommissioning these roads or converting them to administrative-use only should be considered.

3.  Road 119 (Music Pass) above the Rainbow Trail. This road is in poor condition above the Rainbow Trail. It dead ends into the wilderness area and does not offer the sort of loop that offroad vehicle users enjoy. Most horseback riders are forced to leave their trailers lower down below the Rainbow Trail crossing, and many hikers prefer to leave their vehicles there as well, walking up to the pass on a combination of the road and the trail that parallels it.

4. Road 406 presents several problems. First, it crosses a big game migration corridor between the San Luis and Wet Mountain valleys. Second, part of it appears to be in the Great Sand Dunes National Preserve, and I question whether the National Park Service welcomes the opportunities for poaching, etc., that it offers. It should be converted into a foot/horse/bicycle trail, which would still leave it open for hunters and outfitters.

Removing that motorized traffic would also protect elk habitat on in a considerable area, as it would mean no motorized traffic in the Sangres between the South Colony and Médano Pass roads, as listed below.

To continue with the protection of elk calving and winter habitats, the San Carlos RD needs to be more proactive with seasonal closures, for elk-production areas in particular, as set forth in the Pike-San Isabel Forest Plan, which specifies that managers should “protect elk calving and fawning concentration areas from habitat modification and disturbance from May 15-June 30. Likewise, more attention should be paid to mule deer and bighorn sheep winter range. 

Roads passing through 5B Big Game Winter Range should carry and H/H designation and receive seasonal closures. For elk in particular, these include Roads 119, 198, 332, 332A, 337, 338, 412, and 412A.

In conclusion, the Colorado chapter of Backcountry Hunters and Anglers urges that planners seriously consider the negative effects of road density on big game habitat and work to reduce it wherever possible.

Thank you again for this opportunity to comment.

                                                                                    /s/ Chas S. Clifton

                                                                                    Colorado Chapter

                                                                                    Backcountry Hunters and Anglers