DATE: September 10, 2012
TO: Ms. Kelly Larkin-McKim
FROM: Matt Miller
SUBJECT: High Peaks to Headwaters Watershed and Fisheries Restoration Project - EA
Dear Ms. Larkin-McKim,
My name is Matt Miller, and I am the Land Use Coordinator for Rising Sun 4x4 Club of Colorado. As you probably know, our club participates in the Adopt-a-Road program with the U.S. Forest Service, and the Leavenworth Creek Drainage is our Adopt-a-Road within the Clear Creek Ranger District of the Arapaho National Forest. We have sponsored many regular cleanups of the Leavenworth Creek area, and I thank you for sending us the notification letter regarding the drafting of the Environmental Assessment for this area.
Rising Sun 4x4 Club of Colorado is a club that is committed to promoting responsible recreation and stewardship of our National Forests and public lands. In the past we have shown this in the Leavenworth Creek area by donating volunteer hours to help with projects such as the closure of illegal user-created routes and the installation of signage and carsonite to promote respectful use of the area. Every summer we perform trail cleanups of the Leavenworth Creek road system, and a fair number of us frequent the area for purely recreational purposes as well. Through these experiences, we have seen what damage could be caused by inappropriate trail usage, and understand some of the challenges that must be faced to keep the entire area open to recreation.
After reviewing the proposed action in the Watershed and Fisheries Restoration Project, I have some comments that I hope will be included in the final decision process for this area. Most of the proposed activities appear to be reasonable and effective for enhancing instream fish and toad habitat and improving the watershed, but I do have some concerns regarding the decommissioning of some of the dispersed campsites and also some of the roads.
As a 4x4 club, travel by road is of necessity to our recreation. Having lost many miles of roads during the MVUM process, and in subsequent processes thereafter, our entire community is very sensitive to the prospect of losing additional miles of travel surfaces. In the past, Rising Sun has shown our dedication to keeping roads open by offering volunteer time and money to harden riparian areas, stabilize road surfaces, and install post and cable to clearly identify the road surface and prevent off-road travel. Most of these projects have been done within the Boulder Ranger District, on our other Adopt-a-Road, Jenny Creek. However, we have also felt that by closing illegal user-created routes in the Leavenworth Valley we have also been contributing to the sustainability of the area and to keeping legitimate roads open.
Getting to the specifics of the proposal, I looked at all the road numbers slated for decommissioning, and I have concerns and suggestions regarding several:
1. 248.1K. This is the first on the list that is slated for decommission. I believe I know why. Above 248.1 there is a slightly steep climb that has some large exposed rocks and I suppose might be a source for excessive erosion that is adding to the streambeds. Here’s the problem: aside from it being a legitimate established road, this is in fact the historic wagon road that paralleled the railroad up to the town of Waldorf. By decommissioning this road, its historical value will be lost. I must stress this point, being personally acutely interested in the amazing mining and tourism history of the area. I would propose that more discussions are held with clubs such as Rising Sun and with the Georgetown Historic District Public Lands Commission (HDPLC) to work out ways to harden the travel surface of this road and stabilize it in order to keep it open. Rising Sun has available volunteers and available funds to help with this effort. Furthermore, it seems excessive that the entire 0.83 mile stretch of this road be decommissioned as a result of such a small length of the road being problematic. In fact, the large majority of the road (I’d estimate almost 75%) doesn’t appear to see regular travel of any type, and erosion doesn’t appear to be a problem at all! Most people appear to travel up 248.1K to 248.2A and continue that way. Closing the entire section of 248.1K doesn’t make sense, but hardening the travel surface and continued monitoring and repair does make sense.
2. 248.1L. This road appears to be on the decommission list because it crosses Leavenworth Creek, goes to a campsite, and then continues up to a dead-end. Unfortunately this is a favorite campsite of some in the club. Would a bridge crossing of the creek provide a feasible and effective alternative to just closing the campsite and the road?
3. 248.1J. This road is labeled as already closed to the public. My MVUM still shows this road as open, so I do not understand the discrepancy there. As I recall, this road services a campsite that is well and away from the wetlands area of the Leavenworth Valley, so I question how its use impairs water quality.
4. 248.2B. This road appears to access a cabin, and I understand that this road travels through a low-lying area (I have not yet visited the cabin myself, though I have meant to for several years). If there are no other problems with accessing the cabin site and location, would it be possible for volunteers to harden the road base and stabilize the area to prevent water quality issues?
Regarding the remainder of the listed roads, especially the 189-numbered roads, I have no specific questions and/or input, but rather I would like to offer Rising Sun’s assistance to explore alternatives to closing and decommissioning the roads listed. Rising Sun feels that our efforts to maintain our Adopt-a-Road has greatly benefited the entire Leavenworth Valley, and we would like to participate in continuing to keep the area as pristine as possible with the fewest number of road closures possible.
Another thought I would like to offer: if we must give up some existing roads, would it be possible to gain any back in return? When the MVUM was developed, a connecting road was missing from the map. I commented on the proposed MVUM during the public comment process to add the road to the map, but it was never added. It appears to be in very stable condition and offers convenient access for us on our cleanup days as well as for recreational users on the weekends to go between the “upper” and “lower” roads of the Leavenworth trail system. The intersection of this road to the “upper” road is at 39°40.810' N, 105°43.659' W. The intersection of this road to the “lower” road is at 39°40.818' N, 105°43.518' W. Please consider adding this road to the environmental assessment if it would be possible to add this road back to the system.
Finally, I would like to say that Rising Sun is here to help the Forest Service in any way we can pursuant to our Adopt-a-Road agreement. We are committed to providing manpower and monetary funds in support of keeping our public lands healthy and enjoyable, and again commit to responsible recreation and management of our public lands. Thank you so much for involving us in the comment process, and we look forward to continued involvement!
Sincerely,
Matt Miller
Land Use Coordinator – Rising Sun 4x4 Club of Colorado
