8 May 2001
Ruth Monahan
WCNF, Ogden Ranger District
507 25th Street, Suite 103
Ogden, Utah 84401
Dear Ruth:
This letter is in response to the Wheeler Creek Trail Complex Environmental Assessment, dated 6 April 2001. The comments herein represent the official position of the Ogden Group Sierra Club, which has more than 350 members living throughout Weber, Morgan, Box Elder, and northern Davis Counties.
In brief, we commend the Forest Service for the modifications made to the original proposal described in the Scoping Document. Many of the concerns with the proposal that we expressed in our comments dated 4 April 2000 are no longer applicable to the new Preferred Alternative (Alternative 4), which we mostly endorse. However, we still suggest that the Preferred Alternative be modified in several ways.
Trailhead improvement
The trailhead improvements described in the EA are appropriate and necessary, and we endorse these. We also support the proposed improvement of 1/4 mile of the Art Nord Trail to accomodate wheelchairs. We would encourage the placement of interpretive signs at each trailhead, to help visitors better appreciate the streams, wetlands, geology, flora, and fauna of this ecologically important area.
Trail reconstruction
We strongly endorse the improvement and reconstruction of the existing Wheeler Creek trails. Better trail alignment and engineering around creeks and wetlands is especially important, given the damage currently being caused by horses and bicycles. It is important, of course, that after realignment, obsolete trail segments be rehabilitated.
However, we question the need to widen all of the Wheeler Creek trails to the proposed 48 inches, clearing vegetation to a width of 8 feet. We notice on page I-8 that a width of 36 inches is considered sufficient for at least some of the proposed trails within the developed ski area; surely a trail in an undeveloped recreation area should be no wider than in a developed recreation area. To minimize visual impacts and damage to vegetation, we suggest that, on trail segments that are more than 1/4 mile from the nearest trailhead, the tread width not exceed 36 inches and the region cleared of vegetation not exceed a width of 6 feet.
According to information provided to us by the Forest Service, some of the existing Wheeler Creek trails pass through or near known populations of sensitive plant species. A population of Maguire draba lies just across the creek from the lower Wheeler Creek (Art Nord) trail, just below the intersection with the Wheeler Cutoff trail. To keep hikers away from these plants, we would suggest that the Wheeler Cutoff trail be relocated to the east side of the creek if this is feasible. Also, a population of penstemon platyphyllus apparently exists along the Middle Fork Wheeler Creek trail. Without knowing the precise location of these plants it is hard to make a specific recommendation. However, it would be prudent to clear as little vegetation as possible in this area, in order to avoid actual or potential habitat for this species.
Ski area trails
The "Modified Proposal" (Map #2a) for the system of trails within Snowbasin Ski Area appears to be mostly reasonable. We agree that the additional switchbacks shown on Map #1.3.4 ("Full Proposal") are unnecessary and would probably be short-cut by trail users.
We would suggest some further changes to the Modified Proposal in the vicinity of Allen Peak, in order to keep recreationists away from draba populations and simply to avoid building trails that are not needed. The proposed high trail that would traverse below the ridge from Strawberry Bowl to No Name Peak should end just northeast of Mt. Ogden, where it could intersect a maintenance road without losing too much elevation. This would keep recreationists farther from the large draba population along the Ogden-Allen ridge, where so many plants have already been destroyed. The entire trail loop north of the Allen Peak maintenance road should be eliminated, because it is unnecessary and would serverely disturb this alpine area. We realize that most of this loop would be on private land. Still, a portion of it would be on Forest Service land, and we expect the Forest Service to work with Snowbasin to protect the ecology of the entire mountain. If it is felt that a trail to No Name Peak is needed, we recommend that it be a simple spur trail from the maintenance road, rather than a loop.
Trail connecting Cold Water Canyon to Overlook
We understand the appeal of this proposed trail segment, and in principle, we support its construction. However, our understanding is that nobody from the Forest Service has yet walked the entire route, to determine whether a suitable alignment can be found. By a "suitable" alignment, we mean one that does not entail excessive damage to rock or vegetation, and that produces only a minimal visual impact when viewed from the Indian Trail across Cold Water Canyon. A suitable alignment should also offer interesting hiking and expansive views, rather than merely providing a "connection."
Last spring I spent half a day exploring this area with Tony Botello, and we encountered an alarming number of limestone cliffs on the east wall of Cold Water Canyon. Navigating around these cliffs will not be easy. I would be happy to return to this area with Tony to try to find a suitable trail alignment. Meanwhile, we recommend that you not commit to building this trail.
Trails eliminated from the Preferred Alternative
We are especially happy with the deletion from the Preferred Alternative of the proposed trails to Sardine Peak (and eastward from there) and ascending the north ridge of Allen Peak. Again, these trails are unnecessary (given the levels of use that could reasonably be expected in the next several years, and given the large number of other trails in the area), while their construction would be both laborious and destructive of the natural environment. We hope that these trails will remain absent from the final adopted plan.
Beus Trail construction
We are also pleased to see that construction of the upper portion of the Beus Trail has been added to this project. This will remedy a serious problem with the existing trail system on Mt. Ogden. However, we would remind the Forest Service that other portions of the Beus Trail (especially through Fern Valley and on the north-facing slope just above Fern Valley) are also in serious need of reconstruction. We would prefer to see a proposal that addresses the entire trail, not just the upper portion of the trail.
Trail from Strawberry Ridge to Beus Trail
We remain opposed to the proposed trail connecting the Beus Trail to Strawberry Ridge. From discussions with Rick Vallejos and Tony Botello, our understanding is that this trail's main purpose would be to accomodate lift-served recreationists who wish to descend part or all of the west side of Mt. Ogden. Leaving aside the question of whether public funds should be spent promoting commercial profit in this way, we oppose this trail out of concern for the safety of recreationists, preserving the broad spectrum of recreation experiences on the mountain, and preserving the natural flora in this alpine area.
This proposed trail would create safety problems because it would encourage inexperienced hikers and bikers to attempt the five-mile, 4000-foot-vertical descent to Ogden without proper equipment or preparation. While a few hikers would undoubtedly attempt this descent even without the trail, the number would be far greater with the trail, and the trail would encourage not only hikers but also bicyclists. However, many portions of the lower Beus trail are rough, narrow, steep, and especially unsuitable for mountain bikes. In general, downhill-only hiking and biking present a host of dangers to inexperienced hikers and bikers who may be incapable of turning around when the going gets tough. While the developed ski area offers a relatively safe place for this kind of recreation, the west side of Mt. Ogden is far more hazardous.
This proposed trail would also alter the recreational atmosphere on the Beus Trail, increasing traffic (especially bicycle traffic) and thus lessening the feel of remoteness from civilization that hikers currently have. The very sight of the new trail, on a sagebrush-covered slope where it will be impossible to hide, would serve as a reminder of the restaurant and ski lift just over the ridge. Goal #5 of the Forest Plan is to "provide a broad spectrum of low cost dispersed recreation opportunities." Currently, the Beus Trail is the only nonmotorized trail in the Ogden Ranger District that climbs above 9000 feet elevation. If the upper portion of this trail becomes a playground for lift-served recreationists, a significant portion of the current spectrum of opportunities will have been eliminated. We do not oppose the promotion of lift-served recreation within the developed ski area. However, the Forest Service should do all it can to contain this kind of recreation within ski area boundaries.
Finally, we are convinced that this proposed trail would lead to significant damage to alpine flora, both along the margins of the trail itself and along the upper Beus Trail (which would be used to make a loop over the Mt. Ogden saddle). The heavy traffic that it would bring, especially bicycle traffic, would inevitably impact the trail margins, as users pass each other or step off the trail to take a break. The high ridge between Strong's and Burch Canyons would be especially vulnerable to this increased traffic, and unofficial paths would probably develop along a number of ridge tops near Mt. Ogden. We understand that some damage would also result if the trail is not built, from hikers descending cross-country from Strawberry Ridge directly to the Beus Trail. We believe that this damage will be minimal, especially if the Forest Service uses signs to redirect interested hikers over the Mt. Ogden saddle.
Page IV-46 of the EA states that one purpose of this trail would be to direct hikers away from the ridgeline and away from known populations of Maguire draba. We do not believe it would accomplish either of these goals. If the Strawberry lift operates during the summer, thousands of tourists will still want to wander along the ridges to Strawberry and De Moisy Peaks, whether the proposed trail is built or not. The only way to prevent this ridge from being completely trampled will be to construct an official trail along the ridge, not one that descends steeply to the west. As for avoiding the draba plants, Forest Service maps show that no draba populations exist near De Moisy Peak, along Strawberry Ridge, or on the slope west of Strawberry Ridge where this trail would go. If there were a known draba population on that slope, and if the trail could be routed away from that population, then the argument in the EA would make sense, but there is no such population. At the same time, the overall damage to alpine flora would almost certainly be greater with the trail (and the traffic it would bring) than without.
The other argument given in the EA for building this trail segment is to realign the Great Western Trail, avoiding the ski area maintenance roads. However, one can see from Map #1.3.3 that the GWT would still follow a service road for some distance on the east side of Strawberry Ridge (in Strawberry Bowl). The length of service road included would be no greater, it appears, if the GWT were simply routed via the Beus Trail over the Mt. Ogden saddle, then down a service road until picking up the first single-track path shown in Map #2a. Furthermore, we do not believe that vehicle travel on the service roads will be as frequent as is implied on the bottom of page I-6, at least after the current construction phase has been completed. If anything, we would expect less vehicle travel near the Mt. Ogden saddle than near the Strawberry restaurant. The claim on page I-10 that the roads are "excessively steep" is contradicted by the fact that hikers as young as three and a half years old have ascended these roads, self-propelled, all the way to the Mt. Ogden summit. In any case, the goal of avoiding service roads should not take precedence over the more serious safety issues and environmental issues discussed in the preceding paragraphs.
Nordic recreation
We are pleased that the Forest Service wishes to encourage the use of the Wheeler Creek trail system for Nordic skiing and snowshoeing in the winter. The proposed trail reconstruction, brush clearing, and rerouting of the trails will be the most important steps toward this goal. Also important, we believe, will be marking Nordic routes in some way, so novices will be less likely to become lost.
Some limited trail grooming may also be appropriate, especially near the lower parking lot and the Art Nord trailhead. However, in the interest of providing "a broad spectrum of low cost dispersed recreation opportunities," we oppose the proposed grooming of the entire Wheeler Creek trail system. Currently, the Wheeler Creek drainage is the only public land in the Ogden Valley area where beginner and intermediate skiers can enjoy backcountry skiing, with good snow conditions, away from snowmobiles and safe from avalanche danger. An extensive system of groomed trails is already available in Weber County's North Fork Park. To groom all of the Wheeler Creek trails would therefore duplicate an opportunity that is available nearby, while eliminating an opportunity for less developed recreation.
We therefore encourage you to modify the Preferred Alternative to eliminate, or greatly reduce, the grooming of the more remote Wheeler Creek trails. We would like to work with Forest Service staff in identifying the most appropriate trails to leave ungroomed. One reasonable alternative, however, would be to groom only the trails north of SR226, leaving the East Fork and Middle Fork trails ungroomed.
General comments on the EA and NEPA
We are struck by the language in the EA repeatedly expressing the goal of providing loop trails and through-routes. Relatively few hikers in this area undertake long-distance one-way hikes, so we would not put a priority on accomodating this type of recreation. While loops do have their appeal for hikers and bikers, we believe that destinations are even more appealing. For instance, along the Wasatch Front in Ogden, two of the most popular hikes are in-and-out routes to Waterfall Canyon and Malan's Peak. Yet nowhere in the EA is there any mention of what destinations will attract hikers and bikers to any of the new trails. The most obvious destinations would be major and minor peaks and other points from which one has an expansive view.
Although we do not advocate the No Action alternative, we believe that the discussion of this alternative in Chapter 2 shows bias against it. For instance, the claim that there would be no "viable loop system" (page II-18) is false, as is the claim (page II-19) that it would be unsafe for hikers and bikers to use the ski area maintenance roads. The safety of hikers and bikers sharing primitive roads with motor vehicles has been amply demonstrated in places like Canyonlands National Park, where many hiking routes lie partially along roads that are open even to private four-wheel-drive vehicles. Once the current construction phase is completed, we would expect the roads within Snowbasin ski area to be driven much less frequently than those in Canyonlands.
Finally, we would like to point out that recent editions of the WCNF Schedule of Proposed Actions ("NEPA Quarterly") have significantly understated the scope of this project. For instance, the Winter 2001 edition says that only three miles of new trails may be constructed outside the ski area (the actual proposed trails are longer than this), and makes no mention of the much more extensive proposed trail construction within the ski area. Public participation in the NEPA process requires that the public be given accurate information in all Forest Service publications.
Summary
While we mostly endorse the Preferred Alternative as described in the EA, we would like to see it modified in the following ways, for reasons described above: 1. Install interpretive signs at trailheads; 2. Construct most trails to a tread width of 36 inches rather than 48 inches, and clear vegetation to a width of 6 feet rather than 8 feet; 3. Route the Wheeler Cutoff and Middle Fork trails to avoid known populations of sensitive plant species; 4. Eliminate a portion of the high trail below the Ogden-Allen ridge, as well as the proposed loop to No Name Peak; 5. Construct the trail between Cold Water Canyon and the Ogden Canyon Overlook only if a suitable alignment can be found which is not overly destructive; 6. Reconstruct damaged and poorly aligned portions of the lower Beus Trail, or better, prepare a comprehensive plan for construction and maintenance of all trails on the west side of Mt. Ogden; 7. Eliminate the proposed trail connecting the Beus Trail to Strawberry Ridge; 8. Restrict grooming of Nordic routes to trails that lie closest to trailheads, leaving the East Fork and Middle Fork trails ungroomed.
Sincerely yours,
Daniel V. Schroeder
Chair, Ogden Group Sierra Club
1444 Binford Street
Ogden, UT 84401