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HomeMy WebLinkAboutresolution.council.015-00 RESOLUTION# I~ (Series of 2000) A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ASPEN, COLORADO, ADOPTING COMMENTS ON THE WHITE RIVER NATIONAL FOREST DRAFT FOREST PLAN, DRAFT ENVIRONMENTAL IMPACT STATEMENT, AND TRAVEL MANAGEMENT PLAN WHEREAS, the United States Forest Service has proposed updated management plans for the White River National Forest, including a Preferred Alternative (Alternative D), and the City of Aspen wishes to comment on these plans during the official comment period, and WHEREAS, the City Council of the City of Aspen has jointly with the Pitkin County Board of County Commissioners conducted public meetings, and solicited input from as wide a range of forest users as possible, and wishes to make joint comments with Pitkin County, as described in the attached letter, and WHEREAS, the City Council wishes to suggest ~mprovements to the proposed plans, including better assessing socioeconomic impacts of activities on Forest lands, requesting that the Forest Service purchase all private inholdings on Forest lands in Pitkin County as quickly as possible, requesting a land swap to create affordable housing for local employees, recommending an improved approach to carnivore habitat improvement, supporting efforts to separate conflicting uses, and allowing for reasonable expansion of the visitor economy while recognizing that only limited growth is sustainable if we are to preserve our natural heritage, NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF ASPEN, COLORADO: The City Council of the City of Aspen hereby approves and adopts the attached letter and comments on the proposed changes ~n management plans for the White River Dated:Sati°nal Forest.c~// / ~.~7~/,~/7~~ RaChel E. Richards, I~layor I, Kathryn S. Koch, duly appointed and acting City Clerk do certify that the foregoing is a true and accurate copy of that reso_s_s_s_s_s_s_s_s~o~n adopted by t~he City Council of the city of Aspen, Colorado, at a meeting heldJ~~-- /5t , 2000. KC~n'yn S. Koch, City Clerk L/ WHITE RIVER DRAFT FOREST PLAN COMMENTS The following comments are directed toward the Draft Forest Plan and accompanying Land and Resource Management Plan map. Comments in this section follow a citation from the draft document. AIR QUALITY (Page 2-3) Standard: 1. Meet state and federal air quality standards, and comply with local, state and federal air quality regulations and requirements, either through original project design or through mitigation, for such activities as prescribed fire, sin' area development or expansion, mining, and oil and gas exploration and production. Comment: The Aspen area is listed as a Non-Attainment area from the Clean Air Act. The movement of skiers and other recreation users to and from Forest Service recreation sites exacerbates our PM-10 problems. PM-10 is a proven hazard to the health of area residents and visitors. The City and County spend over $10,000,000 each year on public transportation in an effort to minimize the impact of transportation on air quality. Last year, over 700,000 visitors were moved to and from Forest Service permitted ski areas. In addition, over 80,000 visitors were transported to the Maroon Bells by RFTA bus. The City and County strongly support the Forest Service direction of constraining future ski area development to currently permitted areas. While the Plan must provide some flexibility for permit adjustments that allow for minor improvements to existing ski areas, new ski areas, particularly those which are not adjacent to downtown areas, will encourage additional automobile travel and pollution. The same concern applies to non-skiing developed recreation. Future recreation activities will need to be accessed by non-motorized means or with transit. WATER QUALITY (Page 2-5) 9. Maintain enough water in perennial streams to sustain existing stream health. Return some water to dewatered perennial streams when needed and feasible F~CP Handbook). Comment: As the skiing has evolved from a series of family-owned ski areas to a four- season, recreation and development industry, the reliance on snowmaking has increased exponentially. Visitors are now guaranteed skiing in November regardless of natural conditions. While there are economic benefits to snowrnaking, remowng water from streams during this low flow season increases danger to flora and fauna in the area. A policy and implementing Standard for discouraging additional snowmaking based on seasonal stream flows is recommended. Any future expansion of snowmaking would be encouraged to use groundwater or stream flows which have been captured during high stream flow periods. Seasonal flows would be 4 permitted if other options are not viable or were previously approved. Approvals for any additional snowmaking should incorporate a drainage and erosion control plan to address the added water content to soils. The City and County are also concerned about possible water quality damage from construction of new roads to service timber cuts. ADMINISTRATIVE (Page 2-34) 3. Opportunities to convey lands shouM consider the following: · lands in developed areas that have lost or are losing their national forest character · lands within, and immediately adjacent to, expanding communities to assist public and private projects that have the mutual concurrence o f federal, state, and local governments · to states, counties, cities, or other federal agencies when disposal will serve a greater public interest · lands that will contribute to community growth, development, and economic prosperity Comment: Two of the most critical issues facing our community are affordable housing and transportation. During the last decade and next decade, over $400 million in local, state, and federal funding will be spent in an effort to address these issues. Affordable housing is a national issue which is particularly acute in our community: The average single family home in the Aspen area sells for over $2 million. Like many other resort communities, workers have been priced out of the free market and rely on government-subsidized or deed-restricted housing units to avoid long commutes. Those who purchase homes in distant communities face long commutes and generate the need for additional highway capacity. Additional traffic exacerbates air quality problems and creates the need for heavily subsidized parking facilities. For that reason, Pitkin County, the City of Aspen, and Town of Snowmass Village agreed in 1995 to limit traffic into Aspen to the level in 1994. The current Aspen District Forest Service office is an ideal location for a land swap which meets the criteria above. The current site requires visitors who are seeking Forest Service information to drive into the most congested area of Aspen and then return to their desired destination. While less than ideal for an office, the site would be excellent for affordable housing. Conversely, relocation of the Forest offices to the Brush Creek site provides significant air quality benefits and better service to Forest users. The site provides a more direct transit hub to the Snowmass and Maroon Bells areas and the opportunity to significantly upgrade visitor facilities. Pitkin County and the City of Aspen have approached the Forest Service to propose a land swap to facilitate affordable housing and mitigate transportation issues. Land at the 5 intersection of Brush Creek Road and Highway 82 would be exchanged for the 7th and Main site. The Brush Creek site would provide improved access for visitors and the potential for Forest Service employee housing. We request that the Forest Plan embrace and recommend this land swap. FOREST CARNIVORES (Page 3-66) These areas generally are above 9. O00 feet in elevation in the conifer, aspen, and alpine cover types. Most natural processes are allowed to continue, however, vegetation may be intensively managed to enhance habitat characteristics for carnivores. Management activities will provide opportunities for timber harvesting and grazing. Vegetation may be intensively managed to provide suitable habitat characteristics to assure foraging, denning, and movement capabilities_for lynx and wolverine. Lynx habitat characteristics include dense downed logs, which are often found in late-successional forests and used as denning habitats; dense regeneration of conifer forest types, which provide suitable habitat for snowshoe hare used as food by lynx; and forested habitats, which provide secure travelways between denning and foraging habitats. Habitats important for wolverine include hzgh-elevation talus and boulder fields for maternity dens. Comment: The City and County support the designation of Carnivore Habitat Areas on the forest. We support research on lynx and wolverine habitat. We are however troubled by the single-minded approach that relies on disturbance from timber harvesting to create habitat improvements. Very little scientific data exists regarding the best way to enhance habitat for lynx in Colorado. Our review of the literature suggests that a very cautious and experimental approach is advised. For example, there is sufficient evidence that mature and old growth gap phase, rather than early successional, forests provide the best combination of prey densities and microclimatic conditions for lynx in the southern Rocky Mountains1 That stands in opposition to heavy reliance on timber harvesting, including up to 80 acre clear cuts, prescribed in the Forest Plan. A preferred approach would be to identify habitat areas in the plan with a variety of possible approaches to meeting habitat improvements, including fire. There are clearly areas on the forest which provide the appropriate habitat and which could use fire for disturbance. Other areas would use roadless selective cuts to move into the desired state and smaller clear cuts could be tested in areas with existing roads~ During the next Forest Plan revision, measures would be employed to assess the success of each approach. In addition, we anticipate that lynx introduced in the San Juans in 1999 and 2000 will provide us with invaluable information by indicating which habitats they prefer. We strongly recommend continued research efforts and monitoring to better understand lynx and wolverine habitat before pursuing clear-cutting for habitat reasons. The current proposal is unacceptable and fails to recognize impacts related to roads and loss of forest mosaic. See Buskirk, S.W. et al. 1999. Comparative Ecology of Lynx. USDA Forest Service Gert Tech. Rep. KMRS- GTR-30, Chapter 14. 6 Historically, Pitkin County and the City of Aspen have established policies and provided funding to preserve open space and wildlife habitat. We respectfully request that the Forest Service work in step with us in this effort and involve our County Wildlife Biologist during consideration of habitat improvement measures. INHOLDINGS Comment: The Draft Forest Plan fails to identify and address forest inholdings in Pitkin . County. Local governments are very concerned that mimng claims and land grants could become private resorts in secluded and difficult to serve locations. Pitkin County has exhausted millions of dollars and countless hours trying to resolve conflicts between community desires and private fights related to inholdings and mining claims. The Forest Plan needs to address this critical issue for our furore. Recent land use proposals by Tom Chapman and the proposed Piano Creek Ranch project near Pagosa Springs have made the consequences of inaction clear. Pitkin County struggles to provide the level of services desired by our existing population. Providing services to residents or visitors at remote locations surrounded by forest lands would create great financial risk for our government. The attached article from the New York Times describes the issue. ,Undiscovered crisis, -- developers invade wilderness Tuesday, November 2. 1999 By MICHAEL JANOFEKY TNE NEW YORK TIMES PAGOSA SPRINGS. Cole, --Nestled in the San Juan National Forest in southwestern Colorado lsa small recuangle of mountains and a valley that straddles the meandering East Fork of the San Juan Rlver. For now, the recuangle's 2 780 acres are indistinguishable from the surrounding landscape, a dream scene of 1.8 million prlsulne acres au the Continental Divide,where ~he only sounds are the water rushing over rocks the wind and the occasional cry of birds high overhead. But that is about ~o change. Like more than $0 million other acres inside the United States' naZional parks and forests, only a fraction of the total, the acreage is privately owned. It was one of thousands of land grants made available, in some cases almost 140 years ago, for homesteading, mining and railroads. Although most of the private tracts remain undeveloped, owners of the rectangle here are planning to build a members-only resort on 200 acres that they call Piano Creek Ranch, where membership shares cost $385,000 to $535,000. Designed to accommodate 395 ~amilies, the resort would include spacious houses, lodges, a golf course and an equestrian center. A ski area would be built on another part of the rectangle, Already, 175 families have signed up, and ground breaking is scheduled for June, with completion planned in two years. 7 Preservationists sa9 developments like Piano Creek represent only the beginning of a ma]or problem throughout federal lands, It is "the undiscovered crisis." says the National Park Trust, a non-profit group that buys land and donates it To the park system. ,,This is one of the results of the booming economy and a lot of new disposable wealth "said Steve Thompson, senior vice president Of the TrUst for Public Land, another non-profit organization that works to preserve national park lands and forests. ,,With population pressures and beautiful places disappearing, people of means are saying, 'I'11 get my little corner of Paradise and they do what they want with it."Thompson said. "They have the legal right to do it. But it's sad that resources that are so spectaculax so beautiful would nou be made available =o a broader audience only to a limited group.' And with land prices soaring in areas within some of the country's more popular parks and forests, the federal government and non-profit agencies that buy land for preservation may be u~able to compene with prlvaEe lnves~ors. With growing frequency, owners of "iaboldings are developing acreage for commercial gain, seuElng off intense fights with preservation groups and community organizations concerned that development COUld damage the ecology. "It has become a manor concer~," Interior Secretary Bruce B~bbitt said of prlvaue developmen~ inside federally owned lands. "We need the resources to buy them out before problems star=, and ~here are willing sellers for mos~ of them. But we don't have the money, so the willing seller decides uo sell on the open commercial market.' Each year, the major federal land managemenu agencies -- the National Forest Service, the National Park Service, the Bureau of Fish and Wildlife and the Bureau of Land Management -- provide Congress with a list o~ privately held property they want to buy. The park service list alone has a backlog of 10,184 private tracts ~n 145 parks that officials say would cost the governmenu S1.35 billion to buy for preservation. But Congress never approprlaues enough money ~o satisfy all the needs, so which properu~es are bought depends on the threat Of development, the willingness of the owner uo sell and the prlce. In recen= years, Babbitt said the four agencies have received a combined S300 million ~o s400 million annually for the acquisition of private land. In the Denali National Park and Preserve in Alaska. developers are planning ~o turn an old 20-acre mining site into a remo~e lodge. For access which the federal governmenu is required uo provide, the developers are asking the park service uo improve a 10-mile road through park land that would cross a valley creek 27 times. Park officials fear that the imp=ovement will e~courage other land holders to develop slEes near the road Given the kigh property values in Pitkin County and the pressures for development, we request that the Forest Service directly address this issue in the Forest Plan. Specifically, we ask the Forest Service to aggressively pursue Land and Water Conservation and other federal funding for purchasing inholdings in Pitkin County. While Pitkin County has enacted local legislation, known as Rural and Remote zoning, which would minimize opportunities for such developmem. The Forest Service cannot rely on local policy makers to address this issue indefinitely. A review of the Forest Map indicates over 50 inholdings exist in Pitkin County - with a majority in wilderness areas. The Standards and Guidelines should reflect a goal of reducing or eliminating all such inholdings during the term of the plan. Furthermore, it is recommended that the timeframe required for Forest approval of land trades be shortened to the extent possible. Finally, the City of Aspen and Pitkin County would like to develop a partnership with the Forest Service to acquire inholdings jointly where circumstances allow for such a coordinated effort. WEED CONTROL Forest Plan Page 1-10 Objective 3.4c __ Cooperatively work with federal, store, county agencies, and other non government organizations for control of noxious weeds. DEIS 3-145 Without a concerted and coordinated effort among local, state.,Federal agencies and private individuals, noxious weed populations can be expected to expand their ranges, threatening ecosystem integrity and function on the Forest. Comment: Pitkin County has identified noxious weeds as a threat to the natural landscape. Our residents pay a tax to manage weed issues in the county and the County has adopted a comprehensive weed plan to preserve natural vegetation. Adequate Forest Service dollars and staff devoted to weed control on forest lands in Pitkin County is a high priority. The proposed budget for weed control is insufficient to meet the forest plan goals and desired conditions in Alternative D. The Forest Plan notes that noxious weeds are one of the greatest threats to forest health. Table 3- 36 in the DEIS (page 3-146) indicates that Alternative D allows three times the number of acres of land lost to weeds due to timber cutting as other alternatives. This is primarily due to the s~gnificant amount of land proposed for Category 5 uses. This calls into doubt the amount of acreage suitable for timber and the amount of land in the Category 5 designations. The FEIS should reflect greater budget levels for weed control and a mix of category 5 lands that more closely reflects Alternative C or I. If timber cuffing is allowed, a full weed mitigation program should be strictly followed, since noxious weeds enter extensively after the native vegetation has been cleared. Pitkin County and the City of Aspen have adopted weed management programs and plans which will be most effective if we work together to prevent infestations. We support and recognize the Forest Service's commendable efforts to use native plants in their revegetation efforts. 9 ALTERNATIVE D LAND AND RESOURCE MANAGEMENT PLAN MAP Comments in this section are based on geographic areas and/or management prescriptions assigned to designated areas. MAROON TRAILS Comment: The City and County support Forest Service actions to improve safety and transit accessibility. The Maroon Bells area requires special attention and management given the unique natural features and the intensity of recreation use. While we agree that the wilderness areas surrounding Maroon Lake require careful monitoring and management, we suggest that the East and West Maroon Creek trails be kept open for public use. A monitoring program could be established which would identify management objectives specific to those areas and circumstances which would trigger future reevaluation of trail usage for possible closure. This is an area of concentrated use and very high quality hiking. Our concern is that an attempt to prohibit use will lead to more bandit trails and unintended degradation of the environment. We recommend that the Forest Service consider changing the prescription for these areas from 1.11 Pristine Wilderness to 1.12 Primitive Wilderness. OWL CREEK CORRIDOR Comment: As identified in the Burnt Mountain Final Environmental Impact Statement, this area provides a critical corridor for wildlife movement, is a critical and productive elk calving area, supports numerous Forest Service Region 2 sensitive species, and supports some of the highest biological diversity in the Roaring Fork watershed. The corridor is challenged by development of private lands to the north and developed ski areas to the east and west. This management area is proposed as 5.43 Elk Habitat in the Draft Plan. We support the wildlife designation in this area. This prescription would better reflect the management goals and critical nature of this area. It also reflects the role of this area as portal to the wilderness areas to the south. The spring closure period in this area should be extended from June 20 to June 30 to protect other species, specifically songbirds. Pitkin County has taken strides to protect wildlife movement in this area through our land use rewew process and Pitkin County Wildlife Plan and seeks coordination with the Forest Service to preserve this wildlife corridor for future generations. AERIAL TRANSPORTATION CORRIDOR Comment: Last year, almost 800,000 visitors accessed public lands from our local transit system. Most of these trip are moving skiers between Aspen and Snowmass Village and carrying visitors to the Maroon Bells. Moving people between communities and recreation areas in an l0 environmentally sound manner will continue to be a critical public issue. We expect demand for transit service to continue to expand and the community is considering significant public capital investments to meet those demands. There has been discussion of linking the Buttermilk Ski Area to Snowmass Village with an aerial transportation conSdor. The concept has been discussed for many years and was discussed as a part of the Burnt Mountain Ski Area EIS. Unfortunately, the gondola concept could conflict with the wildlife calving and movement in critical habitat in the Owl Creek corridor. Habitat protection in this corridor is of primary concern to the City and County. At this time, there is insufficient evidence to accurately assess all of the possible consequences and benefits of a gondola proposal between these recreation centers. We feel that the most appropriate process for considering an aerial transportation proposal in the future would be through a joint review process of Pitkin County, the City of Aspen, the Town of Snowmass Village, and the Forest Service. An aerial transportation project would require amendment of all of our plans. We note that any such study would need to consider the community transportation benefits and impacts of aerial transportation on other forest users, including other recreation users and wildlife. At this time, we support the Forest Service 5.43 designation between Buttermilk and Snowmass. COAL BASIN Comment: Pitkin County is very interested in any proposals for developed and motorized uses in Coal Basin. The county has worked toward public investment and remediation in the area. During mining of the area, wildlife was protected and proliferated because general access was very limited. It is recommended that the area be managed to preserve the diverse and healthy habitat which resulted from limited access. The area is now recovering from coal mining activities with active reclamation of roads and revegatation of disturbed areas. It is expected that over the term of this plan, the site will show little sign of human disturbance. Any proposed management prescription for this area should reflect these ongoing efforts. Based on the difficulties in enforcement for this area, geological makeup of the land, avalanche concerns, lack of adequate developed parking, desires to Support wildlife and the natural setting, and the plan's movement toward segregation of uses, we would recommend a 1.31-Backcounty Recreation Non-Motorized designation for this area. Such a designation would restrict recreation uses to non-motorized users but allow for the possibility of permits for limited recreation uses, such as a snowcat skiing operation. SKIING Comment: Skiing continues to play an important role in our regional economy. Maintaining and enhancing skiing facilities on public lands is primarily a private sector activity. However, any such improvements affects land use, transportation, and community viability. We look forward to a new era of working together with the Forest Service to analyze and require mitigation for impacts of ski area improvements on both public and private lands. The current bifurcated review process does not allow for comprehensive and cumulative review. We support the Aspen Skiing Company's request to amend the Forest Plan Burnt Mountain Area permit Boundary to allow an East Burnt Mountain Traverse. We also support the Skico request to include the previously approved trail between Teaser and Jacob's Ladder. WILDERNESS Comment: The designated wilderness areas in Pitkin County are cherished for both their cultural and utilitarian values. A majority of.the Forest Service land in Pitkin County has been designated Wilderness through cooperation of local government, citizen groups, the Forest Service, and our congressional delegation. We believe that this has benefited both our culture and economy. The roadless areas that still exist in the White River National Forest represent the most important management opportunity on public lands. These areas hold a key to preserving sustainable ecosystems in our region. While many will disagree on specific scientific and management findings, we can agree that roadless areas in our region are critical to preservation of our natural heritage. Therefore, examination of Roadless areas for Wilderness designation is a critical element of our review of the Draft Forest Plan and Management Area prescriptions. Visitors are central to the economy of Pitkin County. A recent survey done by the Aspen Chamber Resort Association found that 81% of guests to the area list their number one criteria in choosing a destination resort as~"scenery." The value that tourism brings to the community is far more important in economic terms than any extractive industry. The Wilderness areas surrounding Aspen and Snowmass Village provide visitors with incredible vistas and opportunities for experiencing the natural environment while renewing their "mind, body, and spirit". This experience is an aspect of the "Aspen Idea" of human renewal which has guided the development of our resort community. We see the nearby wilderness areas as central to our economy and way of life. Recent studies have shown the economic benefits of natural landscapes and environmental protection. In the book, Lost Landscapes and Failed Economies: The Search For a Value of Place, Professor Thomas Powers of the University of Montana, documents the volume of data suggesting that land preservation serves the economic needs of local and federal governments better than extractive uses. A Forest Service paper titled, Economic Well-Being and Environmental Protection in the Pacific Northwest, also concludes that, "a healthy environment is a major stimulus for a healthy economy". Finally, the University of Colorado published the article, A New Look at Old Vistas: The Economic Role of Environmental Quality in Western Public Lands by Ron Raskler which documents the economic value of wilderness areas. During his announcement of the President's initiative to protect 40 million acres of Roadless Forest Service lands, Secretary of Agriculture Dan Glickman stated: 12 "Public opinion and extensive scientific work have pointed to the ecological and social importance of roadless areas. These areas have unique values that provide Americans with significant benefits such as clean water, wildlife habitat, food for hunters, and recreational opportunities. As part of the national dialogue we are beginning, we need to discuss how to best protect these unique values for our children and our children's children. We also need to discuss the issue of where the agency should invest its limited resources. For example, entering roadless areas is expensive. Timber sales in unroaded areas require environmental impact statements and tend to be very contentious. In fact, many of the lawsuits the Forest Service has faced and lost in recent years involved plaintiffs eying to prevent the Forest Service from building new logging roads into roadless areas. The Forest Service also has a tremendous amount of forest health work to do in roaded areas. For example, the regional science report for the 75 million acre Columbia Basin said that more than 80percent of existing forest health problems occur in roaded areas. Other roaded areas across the country face similar problems. Indeed, forest managers almost always get a bigger bang for their buck by investing in forest health projects in roaded areas rather than roadless areas. Some have argued that this propasal aims to limit Americans' access to their public lands. Nothing could be further from the truth. In reality, the public is likely to lose more access to the national forests from deterioration of the existing road system than it ever would from a temporary or permanent reduction in new road building in roadless areas. Given budget realities, th~ Forest Service is having difficulty maintaining its current road system. In fact, since 1990, the American people have lost nearly 10,000 miles of road access due to failed maintenance and deterioration, while the Forest Service has built less than 5300 miles of new road into both roaded and roadless areas." Given the Secretary's statements above and the volume of information regarding the social and economic value of preservation, the modest amount of land proposed for Wilderness and the new roads proposed in roadless areas seem counter-indicated. Of the 298,000 acres ofroadless areas, only 42% of those lands are proposed for MA 1.2 or Group 1. Given that any other designation is likely to result in roads and/or developed uses, this points out a weakness in the Preferred Altemative. The Wilderness Act provides direction for identifying and proposing Wilderness areas to Congress. The Wilderness Act gives the statutory definition of Wilderness (Section 2(c)): ' ~A Wilderness, in contrast with those areas where man and his own works dominate the landscape, is hereby recognized as an area where the earth and its community of life are untrammeled by man, where man himself is a visitor who does not remain. An area of Wilderness is further defined to mean in this Act an area of undeveloped federal land retaining its primeval character and influence, without permanent improvements of human habitation, which is protected and managed so as to preserve its natural conditions and which: t'l) generally appears to have been affected primarily by the forces of nature, with the imprint of man's work substantially unnoticeable; (2) has outstanding opportunities_£or solitude or a prim#ive and unconfined type of recreation: (3) has at least 5. 900 acres of land or is of su. fficient size as to make practicable its preservation and use in an unimpaired condition, and (4) may also contain ecological, geological, or other features of scientific, educa- tional, or historical value" Based on the above, we strongly urge the Forest plan to incorporate protection of the remaining roadless areas in Pitkin County. We recommend a twofold approach to providing that protection. First, in addition to the Wilderness areas proposed in Alternative D, we recommend that both the Hunter (75) and North Independent "A" (77) areas be proposed for wilderness. Both areas are natural extensions to the existing Hunter- Fryingpan Wilderness area. While neither of these sites is likely to qualify as pristine wilderness due to proximity to population and current usage, they would be excellent areas for 1.13 Semi-Primitive Wilderness. This would provide an useful edge to the more primitive and pristine areas thereby creating more core area for wildlife, recreation, and ecological renewal. We also request that the Sloan Peak roadless area be protected from roads. The boundaries of this 19,900 acre area are difficult to clearly identify based on the maps provided but it appears that the area has designations of 1.41, 1.31, 5.4, and 5.41. We support the Core Area and Backcountry Recreation designations which will allow bunters, hikers, and other non-motorized uses. The roadless areas proposed for 5.4 and 5.41 are the most troubling. We ask the Forest Service to consider additional 1.31 or 3.32 Backcountry Recreation designations for those areas. The President's Roadless Initiative may address this issue but Pitkin County and the City of Aspen wish to be on record supporting preservation of this area as roadless. HUNTER CREEK CARNIVORE HABITAT AREA Comment: The only areas identified for Carnivore Habitat Management in Pitkin County are the Smuggler Mountain/Lower Hunter Creek Area and the Upper Frying Pan area from Lime Creek to Hagerman Pass. The Smuggler area, ranging from approximately 9,000' to approximately 11,000' in elevation and dominated by Engelmann spruce forest, is inappropriate to this prescription. T.his is a very popular recreation area that would conflict with the intensive management described in this prescription. In addition, this prescription is intended to "supply...security from intensive recreation and other human uses". It is within two miles of a population base of roughly 5,000 people and 3,300 tourist beds. The Lower Hunter Creek/Smuggler/Warren Lakes area is too heavily utilized for recreation for this purpose. This area is more suited to a mix of wilderness and recreation designations. 14 The Upper Frying Pan region is appropriate given t~e type of habitat, remoteness, and history of logging activity. While this area is appropriate for the Carnivore habitat prescription, we still do not support use of clear-cuts as a management option at this time based on the data available. We would look forward to working with the Forest Service to identify the most appropriate disturbance approach for this experimental area. DRAFT TRAVEL MANAGEMENT PLAN COMMENTS The following comments on the White River National Forest Plan are specifically focused on the Travel Management portion of the plan. Staff met with representatives from the Aspen District and the Sopris District to review specific road and trail use changes and their related impacts as outlined in preferred alternative "D". The comments have been divided into four separate areas, which includes the Winter Travel Management and Summer Travel Management of the two different districts, Aspen and Sopris. Generally, the approach alternative "D" takes in regard to managing travel on the Forest is in response to technological advances in the way people travel and experience the land. Since the last White River Plan mounta'm bikes have been developed, the technology behind motorized dirt bikes is allowing riders to more effectively climb difficult terrain. Motorized four wheelers have also become increasingly popular. These three modes of summer travel are allowing people to access more remote sites with increasing regularity than ever before. This travel type, along with the general increase in forest use, has negatively impacted the forest environment. Additionally, conflicts between these modes of travel, hikers and horseback riders are becoming more frequent and with more potential for serious injury. In the winter, the forest is experiencing a similar phenomenon. The power to weight ratio of new snowmobiles and technological advances in their propelling systems are allowing people to access areas of the forest, which typically remained untouched during the winter months. Given changing technology, it should not be assumed that terrain will limit snowmobile or ATV access to any area. Technology advances, along with a greater number of people, are impacting the environment, as well as disrupting the wilderness experience many come to appreciate. Alternative "D" attempts to mitigate human travel impacts on the forest resource, while providing areas set aside for certain types of travel in order to avoid excessive human conflicts. Separating uses will more effectively ensure continued enjoyment of the resource. The City and County strongly support the policy of considering roads or trails to be considered closed unless posted as open. We also support restricting motorized and mechanized uses to identified roads and trails in order to protect the physical environment and preserve the benefits for future generations. In order for these policies to be implemented, we encourage the Forest Service to increase resources dedicated to education and enforcement. In some cases, the perceived changes that Alternative "D" presents, simply reaffirm current misunderstood travel management regulations. Also, Alternative "D" may prohibit winter travel in areas that are not physically accessible because of topographical characteristics. For instance, under the existing plan no single-track trail in the Aspen District can legally be used by motorized means; a role many currently misunderstand. Additionally, a significant portion of land Alternative "D" closes to snowmobiles is already limited to snowmobile use by its topography. Overall, the City and County agree with the approach taken in regard to travel management in alternative "D" given population increases, technological advances and related recreational impacts on the Forest. The City and County also support road closures proposed in Pitkin County. We encourage expedited reclamation of those roads and will monitor progress. We propose developing a joint plan for timing reclamation. The plan gives consideration to the wide variety of uses the forest currently experiences. The City and County were unpressed with the level of detail in Pitkin County's area of the White River Forest and the following are comments about specific items. COMMENTS REGARDING OVERALL TRAVEL MANAGEMENT ASPECT · Enforcement of the plan's regulations will be a continual challenge to the USFS and will be the deciding factor in the success of any White River Forest Plan. We encourage the Forest Service to focus the human and financial resources necessary to implement and monitor this plan. The budget included in the draft seems insufficient to provide meaningful enforcement. Given the significance of the change in management, reallocating resources to this task is advised. Without enforcement, there could be numerous unintended consequences to private landowners and an inability to manage public issues and education regarding travel management, · Another weakness in the document is a lack of planning and budget for adequate parking facilities at trailheads- particularly for motorized uses. If motorized uses are concentrated into the planned areas, then developed parking facilities are needed at those sites, the final plan should address location and funding for necessary facilities. Ad hoc parking leads to unsafe travel conditions on county roads and impacts to neighbors. We also note that seasonal closures for wildlife do not appear to be represented in the Travel Management map. Seasonal restrictions should be in place on the following trails: Government Trail (FDT 1980)- 5/15 to 6/20 and 10/30 to 11/30, Tom Blake (FDT 1976)- 4/25 to 6/20 and 10/30 to 11/30, Anaerobic Nightmare (FDT 1980.1)- 4/25 to 6/20 and 10/30 to 11/30. Seasonal closures will also be required in the Owl Creek corridor between Buttermilk and Burnt Mountain. It would be helpful to have a specific description and designation for these trails on Forest Service maps to increase education and compliance. · Finally, as recreation demand grows existing developed recreation areas will need t.o accommodate additional and increased uses. We can expect additional demands for trails and other uses at these sites. Accommodating a reasonable increase in uses and users on these lands will require increased coordination of Forest Service and City/County planning processes. A joint review process will be imperative to meet the recreation demand while protecting the environment. WINTER TRAVEL MANAGEMENT - ASPEN DISTRICT · While there is no net increase in area which snowmobiles can access in the Aspen District, there will be an increase in miles of trails snowmobiles can use on Richmond Hill, This is consistent with the Richmond Hill Management Plan group and is an appropriate change based on the lack of snowmobiling opportunities around the Aspen Area. However, parking problems caused by this possible increase in snowmobile use in the Richmond Hill area has not been adequately addressed by the plan, but it is currently being developed by the Richmond Hill group in cooperation with the USFS and the County. · Pitkin County supports the Kobie Park area for snowmobile travel and the attempt to separate conflicting uses. · Given wilderness trespass problems up Independence Pass, all snowmobiles will be limited to Lincoln Creek and SH 82. Additionally, Montezuma Basin Road will be closed to snowmobile travel because of the wilderness trespass problem (It is .difficult to stay on a road when ail land is snow covered). Snowmobile use in wilderness areas is clearly prohibited and should be. We support these appropriate changes given the trespass problem. Further, County Rights-of-Way in wilderness areas are legal loopholes for snowmobile travel and the County will consider following the USFS's lead in closing certain County Roads after adoption of a final plan, which travel through designated wilderness areas in an attempt to curtail wilderness trespass. Any closures to USFS roads to snowmobiling will add user volume to county roads in the area. SUMMER TRAVEL MANAGEMENT - ASPEN DISTRICT · Generally, mechanized or motorized travel will only be able to access designated routes. The routes designated are currently the most utilized trails by these forms of travel and are consistent with the Hunter Creek Task Force recommendations. This approach is appropriate to minimize maintenance costs and environmental damage. · The current designation, which incorporates the East and West Maroon Creek Trails, should be changed from Pristine to Primitive in order to allow continued maintenance on these popular trails. · The USFS should limit all Maroon Creek Valley motorized and mechanized access to Maroon Creek Road rather than aiong river trails. This would limit impacts by these forms of travel to paved areas. · The Hunter Creek Task Force has recommended that Bald Knob Road be opened to vehicular travel up to the wilderness boundary. Vehicular access would be managed 17 through the current County ordinance limiting motorized access in this area to "hunters actively pursuing big game". The City and County endorse this proposal. · Though the trail is drawn across her property, there is no public access to Trail No. 1959.1 through Connie Harvey's property at Johnny Draw (T9S, R86W, Section 33). · There is also no formal public access easement through the Child's ranch (T9S, R86W, Section 31) to Trail No. 1962.1N. WINTER TRAVEL - SOPRIS DISTRICT · The USFS maps show the lower 1.3 miles of Coal Creek Road as a USFS road. This is clearly a County Road and should be changed on the plan. Additionally, the upper (USFS) portion of the road has been opened to motorized travel. While the appropriateness of this designation is debatable, there has not been a facility developed for parking to support this use at the end of the County Road. A more formal and adequately sized parking facility should be developed as part of this plan if the management is not changed as per our comments. · The Hay Park Trail has been designated for motorized access from Prince Creek Road to Capitol Creek Road. The wilderness trespass problems in this area have been extreme, including motorized travel up Mount Sopris. If snowmobiles are allowed to use the Hay Park Trail it is unlikely that they will remain on the trail in the open meadows through which this trail passes. This regulation would be extremely difficult to enforce. The City and County recommend prohibiting snowmobile access at the Hay Park trailheads based on the extreme nature of the current wilderness trespass violations. · A significant change is located in the Upper Frying Pan Valley where motorized access has been eliminated over the area from the Upper Frying Pan through Hagerman Pass. While this closure may be appropriate, it is unlikely the vast majority of snowmobiling activity on top of the pass, which originates in Leadville (where snowmobiling up to the pass is allowed), will comply with closures in the White River National FOrest. Changes in Forest Management Policies will need to implemented on the Leadville side of Hagerman Pass in order to ensure compliance with this closure. · The plan designates an area near McClure Pass for X-country skiing (or snowshoeing) given the area's unique pristine characteristics. This is a great effort to separate asset users and provide a quiet area for non-motorized uses for those seeking tranquility, while maintaining areas like Four-Mile for more active motorized uses. · The Eagle-Thomasville Road has been identified as the primary access for snowmobiles. This area, at the end of the County Road, is narrow and expansion for any type of parking is limited by its topography. The USFS should identify parking alternatives for users of this snowmobile access point in the Forest Plan. SUMMER TRAVEL MANAGEMENT - SOPRIS DISTRICT · The plan does a good job of separating uses around the Thompson Creek and the Four-Mile areas. · Some trails in the Thompson Creek area end at private lands (private landowners have nor yet prohibited public use), rather than continuing on to connect with other public roads or trails. The USFS should pursue acquiring these parcels or securing trail easements in order to ensure continued use of these trails through private lands and allow users ro complete popular continuous looped trails in the area. · . The plan does a good job in the Thompson Creek area of utilizing seasonal trail closures for elk calving. · Coal Creek Road has been designated for non-motorized use at the end of the County Road (1.3 miles). It would be more appropriate for this designation to begin at Bradrieh Creek, a couple miles up from the end of the County Road. This would allow a more significant parking area to be used, rather than the limited parking at the end of the Court .ty Road. · The USFS portion of the trail extending from the Arbaney-Kittle Trailhead is identified as open for motorized use. This cooperatively developed trail between the DOW, USFS and Pitkin County was originally identified as a non-motorized hiking, equestrian and biking trail only. The lower portion of the trail begins on County property and enters BLM before finally becoming a USFS trail. The popularity of this trail for equestrian, hiking and biking uses will not blend well with motorized uses. The safety of both hikers and motorized users will be compromised if this trail is designated for motorized use. This trail should remain a non-motorized trail for its entire length for safety reasons. · Due to safety concerns relating to conflicts between horseback and bikers, Perham Creek Trail should be designated foot and horseback only. Draft Environmental Impact Statement Comments The following comments are directed toward the DEIS. SOCIOECONOMIC IMPACTS Comments: The relationship between impacts from developed recreation on forest lands and development approvals on private lands is ignored in the DEIS. As we have learned ~9 about the importance of habitat continuum from public to private lands, we must study and consider the relationship between land use decisions on public and private land. A lack of analysis regarding these relationships has existed historically and still needs to be addressed in the FEIS. Forest Service employees, Bev Driver among others, have begun m examine the relationship to Forest Service uses on private lands, through the "Human Dimension" studies. One of the great learnings of the late 20th century is the evolution of thinking around ecosystem management. We are learning to examine connections and relationships between actions on the landscape. The same lessons need to be learned with regard to the Human Dimension- particularly with regard to the socioeconomic benefits and impacts of developed recreation. The DEIS fails to satisfactorily address the revision issue of Urbanization. The treatment of this topic would be difficult to justify in the NEPA process. After a significant issue is identified, the process calls for a review of impact by alternative and proposed mitigations or avoidance. There is no evidence in the document that such an analysis was performed or how the issue was used in selection of the Preferred Alternative. In addition, Forest Service regulations require the Line Officer to review and consider local Comprehensive and Master Plans (Title 36, Chapter II, Subpart A, Part 219, Sec. 219.7 (c)) during Forest Planning. While City and County staff have appreciated the level of support and interaction with Forest Service staff, there is no evidence of consideration or review of our planning documents or goals. Our analysis of the DEIS in relationship to local Comprehensive and Master Plans concludes that only Alternatives D or I could be refined to successfully_ integrate land use goals between private and public lands. That conclusion is based on meeting wildlife, transportation, enwromnental protection, quality of life, and economic development goals. Pitkin County and the City of Aspen have made bold strides in protecting natural resources in our region and we look forward to working with the Forest Service to refine the Preferred Alternative into a seamless plan for protecting resources on private and public land. Unfortunately, the current WRNF position on economic growth can be summed up in the following quote from the DEIS.: "Socioeconomic changes in the seven-county planning area are caused by actions initiated by businesses, govemmems, and other organizations." This statement is contrary to what we have learned about ecosystem management. The theory is that employment and income tied to private sector development and market expansions will increase rapidly, while employment and income related specifically to FS regulated activities will increase, but more slowly than private sector development. Skiing is the most significant economic engine regulated by the Forest Service. According to the DEIS, skiing accounts for about 94% of the jobs generated by Forest Service regulated activities (31,996 jobs region-wide in 1997). The WRNFS DEIS states that skiing-related economic growth is waning in 2O importance, and other activities occtlrring on private land like construction of second homes, conferences, and ~ummer festivals are increasing in importance. The document ignores the obvious relationship between permitted uses on the forest and development off the forest. The DEIS relies on the IMPLAN model to assess socioeconomic impacts. The "input/output" model provides useful but very limited analysis of the symbiotic relationship between forest uses and economic activity. For example, below is a summary of the WRNF methodology for calculating skiing related jobs: Estimated user days and skier day increases for the various alternatives based primarily on past trends. Used available data for estimating per user or per skier expenditures. Used IMPLAN model to estimate the employment and income implications of the estimated number of users. The IiVI~LAN model was benchmarked with employment, income, and population numbers generated by the demographer~s office and confmued by local governments. Sueh an analysis ignores the multiplier effect of economic activity and completely ignores secondary impacts. Below is a critique of methodology: · Skier expenditure data is based on state averages and does not reflect the continual efforts of the skiing industry in our County to extract more dollars from each customer. The $184 per day per skier for destination skiers figure used by WRNFS does not reflect the expenditures required to ski and lodge in the Aspen Area. With the average "economy" lodging unit renting for about $240 per night and a day pass for an Aspen Skiing Company mountain at over $60, $184 per day per person would not go far in this valley. · The analysis only considers impacts directly linked to visiting skiers. It does not ineinde "local" skier expenditures. The lines between locals and visitors becomes increasingly blurred in resort areas where part-time residents are spending more and more time in residence. In fact, Post Construction Residential Workforce Dynamics (Preston, 1999) indicated that the more "local" a part-time resident is, or the greater the occupancy of a part- time residence, the greater their economic contribution. "Locals" in resort areas increasingly spend money locally that originates from outside of the eommnnity (dividends, investments etc.), and therefore have the same effect as a tourist on the local economy. · A model driven by skier days does not take into account the relationship of ski areas to demand for real estate at or near the base areas. On mountain improvements most often happen hand-in-hand with base area real estate development as part of the continual upgrade of the skiing environment. Local examples include the concurrent on mountain improvements at Aspen Highlands, the Highlands Village development, thc townhomes and condos at the Tieback base area of Buttermilk, and the upgrading of the Tiehack lift. Real estate developers capitalize on the on-mountain improvements and that ultimately such developments increase real estate values in or near the base area and make the area more attractive for development purposes. · Admittedly, local governments are ultimately responsible for up-zonings and subdivisions that finally enable such developments, but ski area improvements, by increasing the attractiveness of real estate near the ski area, contribute to the demand for real estate development. On mountain improvements are regulated both by the forest service and by the Connty, and so the burden should not be placed on either entity. Rather, the County and the FS should begin analyzing on-mountain improvements at a larger scale. We would welcome discussion of a joint review process which addresses issues comprehensively while working within the regulations which guide each jurisdiction. It would benefit the public throughout the region, if the Forest Service would revise it's socioeconomic modeling to address off-site impacts related to on-site activities. Obviously, the relationship between private activities and Forest Service management are inter-related and accountability works both directions. We need to move beyond finger-pointing and into collaborating on solutions and better analysis. Pitkin County staffwould be available to participate in a task force to improve Forest Service modeling for forest planning and review of permits. Given the modest proposals for increased development in Alternative D, this problem is minimized. Should additional developed recreation or another Alternative with more developed recreation be considered, our concerns would be much greater. ACTIVE MANAGEMENT VS. CONSERVATION BIOLOGY Comments: Few people believe that either approach, active management or conservation biology, hold all of the answers to managing our forests. Each situation calls for decisions based on the best available information at the time. Given the current direction toward ecosystem management, the roadless initiative, and growing interest in conservation biology, it seems prudent that a plan for the next 15 years would err on the side of conservation biology. While the goals of immediate intervention to support'biological resources are important, the consequences of a timber cutting and clear cutting approach will limit future choices for resource managers. The Forest Service would be wise to engage the greater community in a dialogue about the role of natural disturbance, specifically fire, in the region. We need to share information regarding the benefits and challenges to using natural disturbance for long term ecological health. This issue is not acute in Pitkin County, but we encourage the Forest Service to consider these comments when considering any possible alterations to the Preferred Alternative or the FEIS. Moreover, adequate funding must follow adoption of this plan; the management and prescriptions will be completely ineffective if there is not landing and personnel for enforcement. AIR QUALITY AND NOISE POLLUTION Comments: The City of Aspen and Pitkin County have undertaken a number of costly and difficult measures to keep air quality as clean as possible. These include emissions resting in Pitkin County, diesel vehicle standards for contractors, the state's second-largest mass transit system, our extensive network o£bike/pedes~an pathways - ail in an attempt to keep our air as dean as possible. This effort is hampered by activities that generate large amounts of air pollution. According to the Forest Service analysis of alternatives, Alternatives D and I most successfully protect overall air quality in the National Forest. This is an important issue for the residents of the City of Aspen and important for the town's economy as well. We ask Forest Service staff to confirm that the air quality analysis presented adequately assesses the impacts of snowmobiles on air quality. Air pollution emissions from snowmobiles are very high. Levels of particulate, carbon monoxide and hydrocarbon emissions in areas where use is common, are a health concern to people who may be visiting and/or exercising in the area. Primary pollutahts of concern from snowmobiles are particulate matter, nitrous oxide, carbon monoxide, and hydrocarbons. A modern snowmobile emits about 225 times the carbon monoxide and 1,000 times the hydrocarbons and nitrous oxides of a modern car. Two-stroke engines power nearly all snowmobiles. According to the U.S. Environmental Protection Agency (EPA), two-stroke engines dump up to 30 % of their fuel, a mixture of gas and oil, directly into the environment. By contrast, automobiles are driven by four-stroke engines which release 97% fewer emissions than two-strokes. Furthermore, new EPA and CARB regulations have reduced pollution on new automobiles even more, creating an even larger gap between two-stroke snowmobiles mad the much cleaner automobiles. The California Air Resources Board (CARB), using data from the International Snowmobile Manufacturers Association, concluded that one hour on a typical snowmobile produces more pollution than driving a modern car for a year. Noise is another concern as snowmobile use has grown. The decibel reading (db) at 10 feet from an idling snowmobile (stock machine) is approximately 65 db, and at open throttle approximately 90 db. A prolonged (eight hours) noise level at 90 db can cause a loss of hearing and physiological stress. Pitkin County's and the City of Aspen's noise ordinances restrict noise levels in residential areas to 50 db at night and 55 db in the daytime. There may be some expectation that noise levels in National Forests would be less than levels in residential areas. In any case, the noise levels in areas where snowmobiles are in use exceed the standards for residential areas in Pitkin County and the City of Aspen, and when a number of snowmobiles are present, would be likely to exceed the levels in the codes even for highway noise. The noise generated by snowmobiles may not meet the expectations of some users of local ski areas or other backcountry users. 23 Although we recognize that improvements to snowmobile engines are likely during the scope of the Plan, we strongly support the restrictions the Preferred Alternative places on motorized users and the segregation of snowmobile uses. We believe that such a policy will minimize impacts on public health and other forest users. Any attempt to dilute the motorized policies in the Preferred Alternative in Pitkin County cannot be justified with today's technology and would fail to address the benefits of segregating motorized uses. FIRE PLAN Comment: We were unable to find a commitment for funding or completing fire plans in wilderness and other areas where natural disturbance would be utilized. The Forest Service needs to immediately fund and initiate such plans in Pitkin County. We look forward to working with staff on those plans.