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Old 06-24-2006, 02:18 PM
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Default left hand canyon decision....it's long

had to do this in multiples cause i got an error message stating i was long winded


Lefthand Canyon Off-Highway-Vehicle Area
Travel Management Plan
Decision Notice and Finding of No Significant Impact
USDA Forest Service
Arapaho and Roosevelt National Forests and Pawnee National Grassland
Boulder Ranger District
Boulder County, Colorado
May 2006
Introduction

Location
The Lefthand Off Highway Vehicle (OHV) Area is located on north-east portion of the Boulder
Ranger District on the east side of the Continental Divide in Boulder County, Colorado in Township 2 North, Range 71 West, sections 15, 16, 17, 20, 21, 22, 27, 28, and 29 in the 6th Principal Meridian. The Lefthand OHV Area is located in the James Creek Geographic Area, as described in the 1997 Arapaho and Roosevelt National Forests and Pawnee National Grassland Land and Resource Management Plan (Forest Plan pgs. 70 to 74).
Map 1: Location

Background
The Lefthand Canyon OHV Area has been a highly popular recreation area for off-highway-vehicle
enthusiasts for the past several decades in the Boulder area. Forest Service budgets and staffing levels have not been able to keep pace with this growing trend of use in Lefthand Canyon, and as a result, the majority of off-highway-vehicle activity has gone unmanaged. This has led to extreme resource damage, watershed degradation, motorized intrusion into a core habitat area designated by the Roosevelt National Forest as critical for wildlife, the creation of numerous user-created routes, user conflicts, trespass issues, and illegal parking and congestion in the State highway right-of-way. The Lefthand Canyon OHV Area needs to be managed to provide quality recreation experiences for users while avoiding resource damage, irresponsible and unsafe use, and trespass onto private lands. Impacts of concern include the disturbance and/or displacement of wildlife, degradation of riparian and aquatic ecosystems, erosion and compaction of soils, and watershed health degradation. Designation and proper location of roads, trails and trail heads, in conjunction with law enforcement are the most effective ways of providing for quality recreational experiences, longterm resource protection, and protection of private land. In order to provide a variety of travel experiences within the capability of the resource, the Boulder Ranger District has proposed and analyzed a network of trails and roads and infrastructure improvements for continued, long-term use in the Lefthand Canyon OHV Area.

The purpose and objectives of this project are to:
Implement Forest Plan Direction (Forest Plan Chapter 2, pages 70-74)
Motorized travel on 4WD routes and single track trails will be featured in the Lefthand
OHV area. Pursue the possibility of formally managing the area through a concession permit or
some other type of partnership. Designate an appropriate system of roads and single-track trails to meet management area objectives. This may include relocation of some roads and trails and closure of others to prevent damage to meadows, dry drainages, and riparian areas.
Consider the development of a trailhead with safe parking, area information, and sanitation.
Fairview Peak Core Area: Minimize recreational impacts on wildlife populations and ecosystems by discouraging additional recreational use. Protect natural resources while providing quality recreational experiences within the Lefthand OHV Area.

• Provide and maintain a sustainable and manageable road/trail system.
• Obtain required easements for access for administrative use and the public.
• Eliminate unclassified routes and cease the creation of more undesignated routes. Close any
user created routes on discovery.
• Restore impacts caused by motorized use.
• Decrease the spread of noxious weeds.
• Provide facilities/improvements that fit into the landscape.
• Decrease vandalism, partying, trashed out camping areas.
• Provide protection for the wildlife core habitat area at Fairview Peak.
• Increase/improve signage and install traffic control devices to keep people on route.
• Decrease trespass onto private land.
• Promote responsible use through education.
• Provide and maintain safe and adequate parking/staging areas.

Decision
Based upon my review of the Lefthand Canyon Off-Highway-Vehicle Area Travel Management Plan
Environmental Assessment (EA), public comments on the EA, the responses to these comments, and
information contained in the project record, I have decided to implement Alternative B with
modifications. My decision is to implement the following:
Management Actions:
• Charge fees for use of the OHV area. Fees will be charged at the two entrance areas, or an
annual permit may be purchased at the office. The Forest Service will collect the fees. This
does not exclude the possibility of an external partnership to help formally manage the area.
• Dusk to dawn closure with authorized exceptions. Work with private landowners for their
night-time access.
• Pursue legal public access where needed to provide a sustainable road and trail network
where there is private land, and to also provide legal access for private landowners. Pursue
acquisition of isolated private in-holdings.
• Allow permitted trials bike events, provided the designated rock crawl route can meet their
needs.
• Provide education to promote responsible use including a handout with recommended items to
have (tree strap, spill kit etc). Use Tread Lightly and Leave No Trace programs as well.
• Have a map to hand out which will include rules and regulations
• Decrease user conflict and increase user safety by:
o Establishing a right of way (who has the right-of-way)
o Establishing One-Way routes (those rated as extreme) and providing pull-outs where needed on the other routes.
o Provide trail ratings
Road and Trail System Actions:
• Eliminate connecting motorized/mechanized recreational uses to Fairview Peak and the core
habitat area. Close Fairview Peak to motorized and mechanized use and pursue administrative access only for enforcement purposes.
• Provide a rock crawl route that uses 286.1B to RC-A to 286.1D. Maintain 286.1D at a high
difficulty rating (though not as a rock crawl route exclusively) and provide rock crawl obstacles that users can bypass if they desire. Please see included map for locations.
• Identify and put into place a sustainable and manageable road and trail network.
• Provide signing to meet Agency signing standards and provide enough signs along routes and
in critical areas.
• Close roads within creeks.
• Close or relocate roads causing damage to streams, wetlands, or riparian areas. Harden roads
where needed to reduce erosion/water issues if critical to road and trail network.
• Close or relocate roads traveling through private land if public use easements can not be
obtained for them.
• Use existing routes- keep creation of new ones to a minimum (e.g. re-routes and connectors
are okay) when designing a sustainable road and trail network.
• Build two trailhead/staging areas with parking, trash receptacles, information boards, toilets, and administrative storage (locations are on Appendix A map in this document). The entrance road to the main staging area near 286.1A will be widened and improved to accommodate
vehicles with trailers. The second staging area will be placed at the gated draw north of the
main entrance.
• Determine and assign route difficulties to all designated routes using guidance from Forest
Service Manual 2309 (please see EA Appendix B route spreadsheet for rating definitions).
Provide signs with difficulty ratings and maintain those routes to their difficulty rating.
• Provide single-track for motorcycles and mountain bikes only. No ATVs/OHVs on these trails
as they are not designed to accommodate ATVs/OHVs.
• Routes will be multiple use routes for all users with the exception of single-track - no
ATVs/OHVs on single-track.
• Provide post and cable or other traffic control devices where needed to protect resources and
to keep motorized users on route.
Please see Appendix A to this document for a map of the decision.

Modification
This section describes the modifications made to Alternative B for this decision. The modifications are based on comments received during the 30-day public comment period on the EA and input from the project Interdisciplinary Team.
1. Add to the decision from Alternative C:
Re-route the northern portion of Castle Gulch (route 287.1 that runs east to west) in order to
mitigate resource impacts occurring on the route provided access can legally be obtained or
access can be provided via re-routes around private property along 287.1.
Add a single-track loop opportunity using routes 845.1 to 286.1B to 286.1 (or route U-at, both
will be available to the rider) to routes U-av to U-aw to U-ay, to U-bc connecting back to 845.1. The northern portion of U-aw will need to be re-located out of the draw and onto the ridge, and the southern portion closed. In addition, a connector will need to be constructed to join U-bc to 845.1
2. Add to the decision from Alternative D:
Fires will only be allowed in designated fire-rings. 5 locations were identified for the placement of the fire-rings (please see Decision Map in Appendix A). They are:
1) Bottom of U-ag
2) 5-points 3) Intersection of U-BJ and 286.1D
4) Intersection of 286.1 and 286.1D
5) Intersection of 286.1A and east end of U-bp
• Provide toilet, trash, and information facilities at 5-points.
• Provide a Rock Crawl route using routes 286.1 to access the rock crawl route, to 286.1.D to
RC-B to U-bj. This will require that 286.1 be widened in order to accommodate traffic heading
to the rock crawl route. 286.1D will have rock crawl obstacles and bypasses around those
obstacles so that non-rock crawl off-highway-vehicles may also find opportunities along this
route.

Mitigation and Project Design
Effects of Alternative B with modifications, which I have selected, are addressed through project design and mitigation measures. These will be implemented as part of my decision.
Recreation:
1. All designated system routes will have difficulty ratings (per FSH 2309.18) and will be maintained at those ratings. These routes will be signed with route number and difficulty rating.
2. All designated system routes rating as “extreme” will be one-way routes for safety purposes.
3. All user-created routes created and/or discovered after this decision will be immediately closed.
4. Post and cable (or another type of traffic control device such as post and pole) will be added where needed (e.g. on a road or surrounding an area needing protection) after use patterns develop which are outside regulations.
5. Impacts from motorized use will be restored where needed within the designated system.
6. Obliterate access points on routes scheduled for closure.
7. Closed routes/areas will be rehabilitated to a natural state.
8. Barriers will be provided at single-track access points to prevent full size vehicles from entering those trails.
9. Fees will be structured to have negligible impacts on users and should not exclude people from using the area.
Scenery:
10. Ensure revegetation mimics color, distribution and texture of the natural ground cover and/or forest conditions.
11. Minimize site disturbance and unnatural contouring such as cut and fill slopes and linear features.
12. Buildings and structures should be low profile, located at transitions (the edge of clearings), simple compact forms, with foothills roof profile (per FS, BEIG 2001), clustered, not isolated.
13. Building materials should be native rock, wood and other natural materials when they are
available and practical to use. Substitute manufactured materials, such as synthetic rock, if they can achieve the appearance of natural materials.
14. Whenever possible building materials, including signage and traffic closure devices should blend in color and/or texture with the natural environment (such as integral colored concrete sidewalks).
15. In U-az and/or FS Road 286.1 at CR 94, use a combination of berms, vegetation, boulders and/or low rock retaining walls to buffer views of parking areas and/or rock crawl areas, and buildings as viewed from County Road 94.
16. In U-az, locate rock crawl area 150 to 200 feet from County Road 94.
17. Minimize signs throughout the development, and minimize unprimed galvanized sign backs and
signposts.
Water/Riparian:
18. All designated system routes in water (riparian areas) will be rerouted out of the riparian areas where possible.
19. Stream crossings will be improved (hardened or culvert or bridge – depending on need).
20. All designated system routes in wetlands will be rerouted out of the wetlands.
21. A 50 ft. buffer around streams will be protected in the design of facilities with the method that best fits the area.
22. Sediment control and pollution control for chemicals from vehicles will be designed and built where determined necessary (i.e. downslope from the rock crawl areas).
Wildlife:
23. Design rock crawling area RC-B on the ground to protect the effective habitat to the northeast, considering visual and noise impacts from this new activity. Confine use to the designed area with appropriate and effective barriers, especially keeping users from expanding to the northeast, onto and over the ridge.
24. During construction, staging areas for equipment must be in areas that are permanently affected, offsite, or that are outside Preble’s meadow jumping mouse potential habitat (300 feet from the 100- year floodplain or as determined by project biologist).
25. Restore at least 0.9 miles of potential Preble’s habitat in Carnage Canyon. Along with the 0.9 miles, 2.2 acres of Preble’s habitat will be restored as native shrubs, grasses and sedges are planted within the riparian corridor (20-foot wide corridor along 0.9 miles will equal 2.2 acres of restored habitat.)
26. Submit a report to USFWS describing the success of restoration efforts 3 years after the initial restoration of the 2.2 acres of habitat in Carnage Canyon. Pictures of the areas to be restored, both before and after restoration, will be included.
27. In the unlikely event that a Preble’s mouse (dead, injured, or hibernating) is located during construction, the Colorado Field Office of the Service (303) 275-2370 or the Service’s Law Enforcement Office (303) 274-3560 shall be contacted immediately. Plants and Weeds:
28. Treat invasive plants in areas where ground disturbance is planned, prior to the ground-disturbing activity, and continue monitoring and treatment after project implementation.
29. Require off-road equipment to be used in this construction project to be free of soil, seeds, vegetative matter, or other debris that could contain or hold seeds, prior to entering National Forest System lands.
30. Require Forest Service approval of any seed mixes and additives used by contractors, partners, volunteers, etc.
31. Comply with FS Rocky Mountain Region Order No. R2-2005-01 requiring the use of certified
weed-free hay, hay cubes, straw, grain, or other forage or mulch product. Use certified weed-free straw instead of hay for mulch, erosion control, etc. to minimize risk of introduction of noxious weeds and minimize germination of the grass species comprising the straw.
32. Purchase only “Certified Seed” (blue tagged) or “Source Identified Seed (yellow tagged) (ARP Forest Re-vegetation Policy, September 2001). Require independent testing of seed purchased for re-vegetation for presence of noxious weeds as follows: Test purchased seed for “all States noxious weeds” according to the Association of Official Seed Analysts standards, certified in writing by a Registered Seed Technologist or Seed Analyst as meeting the requirements of the Federal Seed Act and the appropriate State Seed Law regarding testing, labeling, sale and transport of Prohibited and Restricted noxious weeds. Include seed labels in the project file.
33. If populations of any Forest Service sensitive plant species are found, they will be documented and evaluated by the project botanist. Adjustments will be made to the project if needed. If populations are found for which anticipated project impacts would change the determination of impacts made in Section V of this report, the determination will be revisited and appropriate additional documentation will be prepared and /or project activities will be adjusted.
34. As per Forest Plan direction (USDA Forest Service 1997), if previously-undetected fens,
wetlands, or wet meadows are encountered within the project area, consultation with a botanist or hydrologist will occur to avoid and minimize potential impacts to sensitive habitat.
35. The project botanist will consult on restoration or rehabilitation projects resulting from this analysis.

Project Monitoring
Monitoring:
• Monitor compliance for users staying on route. Non-compliance will result in area closures or
the installation of traffic control devices such as post and cable (or others).
• Monitor for effectiveness of closures.
• Monitor route through Castle Gulch. Should route become degraded, or repeated trespass on
private land occur, the route will be closed to the public.
• Monitoring will be conducted during and immediately following project implementation to
determine if proposed design criteria, mitgation measures, and watershed conservation
practices were implemented. Effectiveness monitoring will also be conducted twice a year to
determine whether design criteria, mitgation measures, and watershed conservation practices
were effective in protecting soil, water, and aquatic resources.
• Monitoring to evaluate the effects of treatment will be conducted by the project botanist for: noxious weed establishment and spread, riparian areas, aspen stands, and known
occurrences of Larimer aletes. Results may be used as the basis to modify project design in
the future.
• Monitor restored areas at least twice annually to ensure successful establishment of
vegetation and assess drainage concerns. Take corrective action if needed. Corrective action
could range from recontouring, erosion control, and revegetation. Monitoring will continue as
long as the area is managed for OHV use.
• Monitor the extent of Preble’s habitat affected to ensure that it does not exceed the area
authorized in the December 1, 2005 Biological Opinion from the USFWS (1,800 square feet).

Rationale for the Decision
I have made this decision after careful consideration of the environmental analysis of the effects of the four alternatives, Alternatives A, B, C and D. My decision meets the requirements of the National Environmental Policy Act (NEPA), responds to the purpose and need for this project described in Chapter 1 of the EA, and addresses the issues identified during the planning process and comments received from the public during scoping and the public comment period. I have made this decision based on the rationale described below.
I first considered whether the proposed activities would achieve and comply with the Forest Plan general direction and then looked at the desired conditions and specific standards and guidelines in the Lefthand Canyon Off-Highway-Vehicle Area (Forest Plan, pp. 71-74). (These examples are not a complete list and are used for illustration only)
Some of the specific goals and desired conditions listed are (p. 73): Motorized travel on 4WD routes and single track trails will be featured in the Lefthand OHV area.
Pursue the possibility of formally managing the area through a concession permit or
some other type of partnership. Designate an appropriate system of roads and single-track trails to meet management area objectives. This may include relocation of some roads and trails and closure of others to prevent damage to meadows, dry drainages, and riparian areas.
Consider the development of a trailhead with safe parking, area information, and sanitation.
Fairview Peak Core Area: Minimize recreational impacts on wildlife populations and
ecosystems by discouraging additional recreational use. Alternative B with modifications best meets Forest Plan and James Creek Geographical Management Plan direction for the Lefthand Canyon Off-Highway-Vehicle Area. The No Action Alternative, Alternative C and Alternative D meet some of this direction, but not to the extent that Alternative B with modifications does. Alternative A (the No Action Alternative) does not meet this direction. Secondly, I considered which of the alternatives would best meet the purpose and need of the project (EA, pages 3 and 4). It was especially important to me to ensure that the project objectives were met.
These include: Implement Forest Plan Direction (Forest Plan Chapter 2, pages 70-74) as decribed in the paragrah above.
• Provide and maintain a sustainable and manageable road/trail system.
• Obtain required easements for access for administrative use and the public. • Eliminate unclassified routes and cease the creation of more undesignated routes. Close any user created routes on discovery.
• Restore impacts caused by motorized use.
• Decrease the spread of noxious weeds.
• Provide facilities/improvements that fit into the landscape.
• Decrease vandalism, partying, trashed out camping areas.
• Provide protection for the wildlife core habitat area at Fairview Peak.
• Increase/improve signage and install traffic control devices to keep people on route.
• Decrease trespass onto private land.
• Promote responsible use through education.
• Provide and maintain safe and adequate parking/staging areas.
I am not selecting the No Action Alternative (Alternative A), because is does not fully meet the purpose and need. Maintaining the status quo as Alternative A does, is not in keeping with the mission of the Forest Service nor does it meet Forest Plan direction for the Lefthand Canyon Off- Highway Vehicle Area as described in the James Creek Geographical Area. In addition, Alternative A is not in the best interest of the public which uses the Lefthand Canyon Off-Highway-Vehicle Area. This is because increasing Front Range populations are expected to bring additional visitors to the Lefthand Canyon Off-Highway-Vehicle Area and the Forest Service is responding, within the capacity of the area, by improving the recreation experience by adding facilities, developing a high quality, sustainable road and trail system, and enforcing regulations, which will mitigate the expected increased visitation. When compared to the other action alternatives (C and D), Alternative B with modifications will best
meet the stated objectives by proactively protecting natural resources while providing a quality recreation experience and enhancing visitor safety. The Lefthand Canyon Off-Highway-Vehicle Area will best be enhanced through Alternative B with modifications by establishing a sustainable road and trail network, providing a designed rock crawl course, providing protection from wildfires through campfire restrictions, providing staging areas and facilities throughout the Off-Highway-Vehicle Area including 5-Points, providing resource protection by prohibiting off route travel, closing unauthorized routes, and by repairing resource damage through restoration. In addition, visitor safety would be enhanced under this decision by providing visitor maps, education, and by establishing route difficulty ratings and vehicle right-of-way procedures. Trespass issues are also best addressed under Alternative B with modifications by the closure of access to Fairview Peak and by pursuing easements both for visitors and private landowners within the plans project area boundaries. Conflicts between
users and neighbors will be reduced by the dusk to dawn closure of the area. No motorized or mechanized access to the Fairview Peak area is included in this decision because legal public access to the area is not likely to be granted by the neighbors and the cost of building/rerouting a road/trail around the private lands is prohibitive from a dollar and environmental effects perspective. A further reason behind not including this area for this use is that some motorized singletrack incursion is already currently incurring into the core habitat area to the north of Fairview Peak despite the difficulty of reaching the area. The open character of the landscape in that area makes a ‘defensible boundary’ extremely difficult at best. Allowing Fairview to be open to motorized and mechanized use would be extremely difficult to enforce and would drain resources from the management of the entire OHV area.
I reviewed the EA site-specific analysis that was completed for the project area by resource area and issues raised by the Interdisciplinary (ID) Team and by the public and feel there has been sufficient site specific environmental analysis completed on each of the alternatives. Other Alternatives considered For this analysis I considered three other alternatives, Alternative A, the No Action Alternative, and Alternatives C and D. A comparison of these alternatives can be found in the EA on pages 16-23. Alternative A: No Action (EA, pp.8)
Under Alternative A, the No Action Alternative, the current management of the Lefthand Off-Highway- Vehicle (OHV) would remain unchanged, which would leave the project area in its present condition. Present trends would continue and the area would experience the impacts created by future unmanaged recreation use in the OHV area. This alternative represented the existing condition of the project area and was used as a baseline against which to compare the other alternatives. This alternative complied with 40 CFR 1502.14 (d), which requires that a no action alternative be included in the analysis. Alternative C This alternative was a modification of Alternative B and responded to public comment: to provide access to Fairview Peak, to not be charged a fee, to add mileage to the single-track trail network, not to provide a rock crawl route, to re-route the northern portion of 287.1 (Castle Gulch) and not to allow
campfires. Actions proposed in Alternative C include:

Management Actions:
• No open fires or campfires at any time. Fires will be permitted in gas stoves only.
• Dusk to dawn closure with authorized exceptions. Work with private land owners for their
night-time access.
• Pursue legal public access where needed to provide a sustainable road and trail network
where there is private land, and to also provide legal access for private landowners. Pursue
acquisition of isolated private in-holdings.
• Allow permitted trials bike events, provided the designated rock crawl route can meet their
needs.
• Provide education to promote responsible use including a handout with recommended items to
have (tree strap, spill kit etc). Use Tread Lightly and Leave No Trace programs as well.
• Have a map to hand out which will include rules and regulations
• Decrease user conflict and increase user safety by:
o Establishing a right of way (who has the right-of-way)
o Establishing One-Way routes (those rated as extreme) and providing pull-outs where
needed on the other routes.
o Provide trail ratings
Road and Trail System Actions:
• Provide motorized single-track access to Fairview Peak using routes 281, 281.A and U-bx.
This will then form a loop with U-bx and 285.1. This alternative will require that a new singletrack route be constructed to connect 281.A to U-bx in order to bypass private land (please see map of Alternative C for an illustration of this new connector). All other routes in the Fairview Peak area will be closed. Re-route the northern portion of Castle Gulch (route 287.1 that runs east to west) in order to mitigate resource impacts occurring on the route.
Add a single-track loop opportunity using routes 845.1 to 286.1B to 286.1 (or U-at, both will be available to the rider) to U-av to U-aw to U-ay, to U-bc connecting back to 845.1. The northern portion of U-aw will need to be re-located out of the draw and onto the ridge, and the southern portion closed. In addition, a connector will need to be constructed to join U-bc to 845.1
• Identify and put into place a sustainable and manageable road and trail network.
• Provide signing to meet Agency signing standards and provide enough signs along routes and
in critical areas.
• Close roads within creeks.
• Close or relocate roads causing damage to streams, wetlands, or riparian areas. Harden roads
where needed to reduce erosion/water issues if critical to road and trail network.
• Close or relocate roads traveling through private land if public use easements can not be
obtained for them.
• Use existing routes- keep creation of new ones to a minimum (e.g. re-routes and connectors
are okay) when designing a sustainable road and trail network.
• Build two trailhead/staging areas with parking, trash receptacles, information boards, toilets, and administrative storage (locations are on maps for all action alternatives B, C and D). The entrance road to the main staging area near 286.1A will be widened and improved to
accommodate vehicles with trailers. The second staging area will be placed at the gated draw
north of the main entrance.
• Determine and assign route difficulties to all designated routes using guidance from Forest
Service Manual 2309 (please see Appendix B route spreadsheet for rating definitions).
Provide signs with difficulty ratings and maintain those routes to their difficulty rating.
• Provide single-track for motorcycles and mountain bikes only. No ATVs/OHVs on these trails
as they are not designed to accommodate ATVs/OHVs.
• Routes will be multiple use routes for all users with the exception of single-track - no
ATVs/OHVs on single-track.
• Provide post and cable or other traffic control devices where needed to protect resources and
to keep motorized users on route.

Alternative D
This alternative was a modification of Alternative B and responded to public comment: to add mileage to the single-track trail network, to re-route the northern portion of 287.1 (Castle Gulch) and decrease potential fire danger caused by recreationists.
Actions proposed in Alternative D include:

Management Actions:
Fires will only be allowed in designated fire-rings. 5 locations were identified for the placement of the fire-rings (please see alternative D Map). They are:
1) Bottom of U-AG
2) 5-points
3) Intersection of U-BJ and 286.1D
4) Intersection of 286.1 and 286.1D
5) Intersection of 286.1A and east end of U-BP
• Charge fees for use of the OHV area. Fees will be charged at the two entrance areas, or an
annual permit may be purchased at the office. The Forest Service will collect the fees, this
does not exclude the possibility of an external partnership to help formally manage the area.
• Provide toilet, trash, and information facilities at 5-points.
• Dusk to dawn closure with authorized exceptions. Work with private land owners for their
night-time access.
• Pursue legal public access where needed to provide a sustainable road and trail network
where there is private land, and to also provide legal access for private landowners. Pursue
acquisition of isolated private in-holdings. • Allow permitted trials bike events, provided the designated rock crawl route can meet their
needs.
• Provide education to promote responsible use including a handout with recommended items to
have (tree strap, spill kit etc). Use Tread Lightly and Leave No Trace programs as well.
• Have a map to hand out which will include rules and regulations
• Decrease user conflict and increase user safety by:
o Establishing a right of way (who has the right-of-way)
o Establishing One-Way routes (those rated as extreme) and providing pull-outs where
needed on the other routes.
o Provide trail ratings
Road and Trail System Actions:
• Eliminate connecting motorized/mechanized recreational uses to Fairview Peak and the core
habitat area. Close Fairview Peak to motorized and mechanized use and pursue
administrative access only for enforcement purposes.
• Provide a Rock Crawl route using routes 286.1 to access the rock crawl route, to 286.1.D to
RC-B to U-bj. This will require that 286.1 be widened in order to accommodate traffic heading
to the rock crawl route. 286.1D will have rock crawl obstacles and bypasses around those
obstacles so that non-rock crawl off-highway-vehicles may also find opportunities along this
route.
• Widen 286.1 for two- way traffic to accommodate for increased traffic to the rock crawl route.
• Add a single-track loop opportunity using routes 845.1 to 286.1B to 286.1 (or U-at, both will be available to the rider) to U-av to U-aw to U-ay, to U-bc connecting back to 845.1. The northern portion of U-aw will need to be re-located out of the draw and onto the ridge, and the southern portion closed. In addition, a connector will need to be constructed to join U-bc to 845.1
• Re-route the northern portion of Castle Gulch (route 287.1 that runs east to west) in order to mitigate resource impacts occurring on the route.
• Identify and put into place a sustainable and manageable road and trail network.
• Provide signing to meet Agency signing standards and provide enough signs along routes and
in critical areas.
• Close roads within creeks.
• Close or relocate roads causing damage to streams, wetlands, or riparian areas. Harden roads
where needed to reduce erosion/water issues if critical to road and trail network.
• Close or relocate roads traveling through private land if public use easements can not be
obtained for them.
• Use existing routes- keep creation of new ones to a minimum (e.g. re-routes and connectors
are okay) when designing a sustainable road and trail network.
• Build two trailhead/staging areas with parking, trash receptacles, information boards, toilets, and administrative storage (locations are on maps for all action alternatives B, C and D). The entrance road to the main staging area near 286.1A will be widened and improved to
accommodate vehicles with trailers. The second staging area will be placed at the gated draw
north of the main entrance.
• Determine and assign route difficulties to all designated routes using guidance from Forest
Service Manual 2309 (please see Appendix B route spreadsheet for rating definitions).
Provide signs with difficulty ratings and maintain those routes to their difficulty rating.
• Provide single-track for motorcycles and mountain bikes only. No ATVs/OHVs on these trails
as they are not designed to accommodate ATVs/OHVs.
• Routes will be multiple use routes for all users with the exception of single-track - no
ATVs/OHVs on single-track.
• Provide post and cable or other traffic control devices where needed to protect resources and
to keep motorized users on route. Other alternatives were considered during the planning process, but were not studied in detail. They
were dropped from further analysis because they did not meet the purpose and need of the project. These alternatives and reasons for their elimination are described in the EA on pages 15.

Public Involvement
On July 12, 2004 a scoping letter was mailed to over 250 people, organizations, and local
governments. The purpose of this letter was to inform the public that the Boulder Ranger District was beginning the Lefthand Canyon OHV Area travel management planning process and that the District was asking for issues that people were experiencing with the area. Three public meetings were also held, July 26, 29, and August 4, 2004, to ascertain the same information.
On January 21, 2005 a second scoping letter was mailed to over 350 people, organizations, and local governments. With the comments from the July 12, 2004 scoping letter and meetings, the
Interdisciplinary Team (IDT) for the Lefthand Canyon OHV Area Plan constructed six alternate themes to resolve the issues heard by the public. This scoping letter asked for input on those themes and for input on what the public would like to see in the Lefthand Canyon OHV planning area to resolve the issues. Two public meetings were also conducted, February 12 and 15, 2005 to collect the same input.

On April 4, 2005, a third scoping letter went out to over 125 members of the public who had
expressed the desire to stay involved in the process after the January 21, 2005 scoping letter. From the comments on the themes, the IDT built the proposed action. This letter asked for concerns, issues, or opportunities specific to the proposed action. This was also the 30- day scoping period on the proposed action. The input received during all these periods were used to develop the alternatives. Using the comments from individuals, organizations, and other agencies my interdisciplinary team of resource specialists identified several issues regarding the effects of the proposed action. Main issues of concern described in the EA on pages 5-6 included:
1. Fairview Peak
• There is no access to Fairview Peak for motorized or mechanized vehicles
2. Fees
• Charge fees only if money collected goes back into the site and Forest Service manages the
OHV area.
• Fees should not be charged at all
• Forest Service should be held accountable to the public for how fees will be spent in the OHV
area.
3. Total mileage of road and trail network
• Do not reduce mileage of the road and trail network from what is currently available.
• Too much is being closed in the proposed action, especially single-track
• There are no connectors to outside the system.
• Keep U-bc, U-aa and Uay – they provide a valuable single track experience. U-bc, 836.1,
268.1 and U-bi should be routes in the system and signed one-way. U-bi should be included
and switch backs added. These are valuable single track trails.
• Please keep 845.1 open to hikers and mountain bikes. Loss of fees would be minimal if this
access point were opened from outside the fee area and the trail is sustainable. Its a nice trail for hikers 4. Rock Crawl Routes
• No rock Crawl routes in order to protect environment.
• Don’t put a new rock crawl route in if goes through undisturbed areas.
• There are scenery management issues with building a rock crawl area.
5. Safety Issues with proposed system of roads and trails
• Having two way traffic and different modes of travel on one route promotes safety concerns
and user conflict.
6. Congestion
• The proposed rock crawl route RC-A will promote congestion by requiring vehicles to stage in
a small area at the proposed staging area and entrance to the rock crawl route off of Lefthand
Canyon Road.
7. Wildfire caused by recreationists in the Lefthand Canyon OVH Area.
• No campfires, open fires, or smoking should be allowed.
8. Castle Gulch Access
• Castle Gulch should be Administrative use only given the private land issues.
• There are resource damage issues at the northern end of Castle Gulch (the part of 287.1
that runs east to west). The road needs to be re-routed.
9. Environmental
• Water Quality in the watershed located in the project area is below standard per Forest
Service and Federal guidelines
• Erosion and sediment from soil compaction is contributing to poor water quality as described
above
• Toxic Metals in water may be contributing to poor water quality
• Riparian areas are being destroyed
• Fish Habitat is being negatively impacted from inappropriate vehicle use and poor water
quality
• Wildlife
- Habitat needs to be protected (loss of soil and vegetation)
- Fairview Peak is an identified wildlife corridor that has been intruded upon
• Vegetation loss due to compaction from people driving off route
10. Public Access
• Easements across private land will be needed
11. Scenic Quality
• Addition of the rock crawl routes may reduce scenic integrity of the site
To address these concerns, the Forest Service created the alternatives described above and also
found in Chapter 2 of the EA. These alternatives were analyzed in Chapter 3 of the EA.
The official 30-day comment period began the day after publication of a legal notice in the Boulder Daily Camera on August 2, 2005. At the same time, the Lefthand Canyon Off-Highway-Vehicle Area Travel Management Plan Environmental Assessment was mailed to 102 individuals, businesses, and organizations that either responded to the Proposed Action scoping letter or expressed an interest in being notified about the project. 282 responses were received within the 30-day period. An additional 19 responses were received after the deadline. The public comments received on the project are summarized and included in Appendix B of this Decision Notice.

Other Disclosures
Endangered Species Act
Section 7 of the Endangered Species Act requires federal agencies to ensure that any action
authorized, funded, or carried out is not likely to jeopardize the continued existence of any threatened or endangered species, or for the proposed action result in the destruction or adverse modification of their critical habitats. Interagency cooperation between the Forest Service and the US Fish and Wildlife Service (USFWS) regarding proposed, threatened, or endangered species is described in Section 7 of the Endangered Species Act. Definitions relating to “consultation” and “conference” are given in FSM supplement 2600-90-6. An updated list of Federally Listed and Candidate Species for Colorado was received from the US
Fish and Wildlife Service (FWS), Colorado Field Office; Lakewood, Colorado dated August 22, 2003. The letter and list are on file in the project analysis file. The species list was used as a basis for the analysis of threatened, endangered, and proposed species for this project.
Potential effects from the proposed project to the Preble’s meadow jumping mouse and to the
Mexican spotted owl were addressed through formal consultation and concurrence was received on
December 1, 2005 for the Preble’s meadow jumping mouse and on April 5, 2006 for the Mexican
spotted owl. The biological assessment, opinion and supporting documentation are on file in the
project analysis file. Therefore, consultation has been completed for this proposed project
Effects of Alternatives on Social Groups There would be no overall differences between alternatives in effects on minorities, Native American Indians, women, or the civil liberties of any American citizen.

Effects on Floodplains and Wetlands
There are minor floodplains associated with Left Hand Creek and it’s tributaries in the project area. These areas should not experience any significant adverse effects from management activities. The floodplains within the project area would not receive measurable impact by upstream influences. The action items of closing roads in stream channels or improving creek crossings or hardening roads where needed would reduce or eliminate current impacts to floodplains and wetlands in the project area. Management activities designed to protect these resources conform to the federal regulations for floodplains (Executive Order 11900) and wetlands (Executive Order 11990).

Energy Requirements and Conservation Potential of Alternatives
The energy required to implement the alternatives in terms of petroleum products would be
insignificant when viewed in light of the production costs and effects of the national and worldwide petroleum reserves.

Effects of Alternatives on Prime Rangeland, Forest Land, and Farm Land
The alternatives presented are in compliance with Federal Regulations for prime lands. The definition of prime forestland does not apply to lands within the National Forests. The project area contains no prime farmlands or rangelands. In all alternatives, Federal lands would be managed with the appropriate consideration to the effects on adjacent lands.

Environmental Justice
Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations directs federal agencies to integrate environmental justice considerations into federal programs and activities. Environmental justice means that, to the greatest extent practicable and permitted by law, all populations are provided the opportunity to comment before decisions are rendered on, are allowed to share in the benefits of, are not excluded from, and are not affected in a disproportionately high and adverse manner by government programs and activities affecting human health or the environment (E.O. 12898 and Departmental Regulation 5600-2). None of the action alternatives would have a discernible effect on minorities, American Indians, or women, or the civil rights of any United States citizen. No alternative would result in a disproportionate adverse impact on minorities or low-income individuals.

Roads Analysis
Any project decision signed after January 12, 2002, that involves road construction or reconstruction including temporary roads, must have a completed Roads Analysis. A Roads Analysis has been completed for the Lefthand Canyon OHV Area Travel Management Plan and is located in the project analysis file.

Finding of No Significant Impact
After considering the environmental effects described in the EA, I have determined that these actions will not have a significant effect on the quality of the human environment considering the context and intensity of impacts (40 CFR 1508.27). Thus, an environmental impact statement will not be prepared. I base my finding on the following:
1. Context and Intensity
This project is located at a very popular recreation area for off-highway-vehicle enthusiasts, which has been in use for the past several decades. Visitors, largely, are from the Front Range cities of Colorado, though some do visit the area from other states. This project is designed to improve visitors’ recreation experience and minimize any environmental impacts to the area. No significant effects on local regional or national resources were identified in the EA.
Project design and mitigation measures will keep project impacts below the level of significance. Forest Service representatives will regularly inspect project operations to assure conformance with the terms of the EA, the Forest Plan and appropriate State and Federal laws. Specialists who participated in analysis of this proposal will be involved with design and on-site layout of the road and trail system, rock crawl routes, and of the facilities/staging areas to assure that design criteria/mitigation requirements described
in the EA and included in my decision are met. In addition, this project is within the scale and context of current development and recreation management activities within the Lefthand Canon Off-Highway- Vehicle Area. Impacts associated with the project are discussed in Chapter 3 of the EA and the project record. The impacts are within the range of those identified in the 1997 Revised Forest Plan. Alternative B and modifications will not have significant impacts on resources identified in the EA. After careful consideration of the EA, the project record, and in documented consultation with resource specialists, it is my finding that the effects of these projects are not significant. My finding that the impacts are not significant is not biased by the beneficial impacts described in the analysis.
2. Public Health and Safety
Proposed activities will not significantly affect public health and safety due to the mitigations/project design included with this decision and from experience implementing and monitoring similar projects. A goal of the project is to provide a quality and safe recreation experience for visitors.
3. Unique Characteristics of the Area
This project is located within Lefthand Canyon Off-Highway-Vehicle Area. The project will not
adversely affect unique characteristics of this Off-Highway-Vehicle area such as historic or cultural resources, wetlands, or ecologically critical areas. My determination is based on the discussion of effects found in the EA, Chapter 3. There are no parklands, prime lands (forest, farm or range), historic or cultural properties, roadless areas, or wild and scenic rivers associated with the project area. By adhering to the project’s construction standards and design criteria/mitigations, impacts to watersheds, wetlands, environmentally sensitive or critical areas and wilderness and roadless values will not be significant.
4. Controversy
The activities described in Alternative B with modifications do not involve effects on the human environment that are likely to be highly controversial (40 CFR 1508.27). Public comment regarding this project focused primarily on the motorized recreation experience, access issues, fees, wildfire, improving visitor safety, protecting the visual quality, and protecting wildlife and other natural resources. These concerns were addressed during alternative development, are discussed in Chapter 3 of the EA, and are also addressed through project design criteria/mitigation. I find the effects on the human environment are not highly uncertain, are unlikely to involve unique or unknown risks and are not likely to be highly controversial and are, therefore, not significant.
5. Uncertainty
The activities described in my decision will not involve effects that are highly uncertain or involve unique or unknown risks (40 CFR 1580.27). Pertinent scientific literature has been reviewed and incorporated into the analysis process and the technical analyses conducted for determinations on the impacts to the resources are supportable with use of accepted techniques, reliable data and professional judgment. Impacts are within limits that are considered thresholds of concern. Issues of public concern and possible environmental effects of the selected alternative have been adequately addressed in the analysis of this decision. Therefore, I conclude that there are no highly uncertain, unique or unknown risks.
6. Precedent
My decision to implement the activities included in Alternative B with modifications does not establish a precedent for future actions with significant effects or represent a decision in principle about a future consideration. I have made this decision based on the overall consistency of the proposed activities with Forest Plan standards, guidelines and management practices, and the capabilities of the land.
7. Cumulative Impacts
The EA includes all connected, cumulative and similar actions in the scope of the analysis. The
cumulative effects of past, present and reasonably foreseeable actions are considered and disclosed in the EA, Chapter 3, and there are no significant cumulative effects.
8. Properties On or Eligible for the National Register of Historic Places
One archaeological site was determined to be eligible for the National Register of Historic Places (5BL375, the Burn Cabin) however the site is located on a private in-holding in the analysis area and lies outside the area of potential effect. No other sites found within the project area are eligible for inclusion on the National Register of Historic Places. Heritage resource specialists based this determination on a Class I literature review of the proposed project and 21 acres were surveyed for cultural resources in the project area of potential effect. Forest Service archaeologists documented a determination of no historic properties affected for this project. The State Historic Preservation Officer (SHPO) has concurred on this finding. The clearance letter from SHPO and the cultural resource specialist report are included in the project file. Should an unknown cultural resource site be discovered during project implementation, it will be protected under the requirements of Federal law.
9. Endangered or Threatened Species or Their Critical Habitat
The action will not adversely affect any endangered or threatened species or their critical habitat (Endangered Species Act of 1973). The Forest Service Biological Assessment dated August 1, 2005 resulted in a determination of effects for implementation of Alternative B of “may affect, but is not likely to adversely affect” for the Mexican spotted owl and “may affect, likely to adversely affect” for the Preble’s meadow jumping mouse. No critical habitat for either species occurs in the project area. The U.S. Fish and Wildlife Service (FWS) issued a Biological Opinion on December 1, 2005, concurring with the determination for Preble’s meadow jumping mouse and containing additional required terms and conditions. Implementing these terms and conditions as part of the proposed project will minimize impacts of incidental take that might otherwise result from the proposed action, thereby avoiding jeopardy to the mouse. On April 5, 2006 the FWS issued a letter concurring with the determination for the Mexican spotted owl. No endangered or threatened plant species or their habitats are present in the project area.
10. Legal Requirements for Environmental Protection
The action will not violate Federal, or applicable State and local laws or requirements for the
protection of the environment. The action is consistent with the 1997 Revised Forest Plan as required by the National Forest Management Act.

Implementation Date
Implementation of this project will not occur for a minimum of 50 days (45 day appeal period and 5 day stay if no appeal is received) following publication of the legal notice of this decision in the Boulder Daily Camera, Boulder, Colorado. If an appeal is filed, implementation will not occur for a minimum of 15 days following disposition of the appeal. If multiple appeals are filed, the disposition date of the last appeal will control the implementation date.

Administrative Review or Appeal Opportunities
My decision to implement Alternative B with modifications is subject to appeal pursuant to 36 CFR 215. Any written notice of appeal must be consistent with 36 CFR 215.14, Content of an Appeal, including the reasons for the appeal (see below). An appeal may be filed by any person who, or any non-Federal organization or entity that has provided comments or otherwise expressed interest in this Proposed Action by the close of the comment period. Any appeal must be filed with the:
USDA, Forest Service, Region 2
Attn: Appeal Deciding Officer
C/O Appeal Reviewing Officer
P.O. Box 25127
Lakewood, CO 80225-25127
If you fax an appeal, please include a cover page stating how many pages you are faxing.
Fax: 303-275-5134
Email: appeals-rocky-mountain-regional-office@fs.fed.us
It is an appellant’s responsibility to provide sufficient activity-specific evidence and rationale, focusing on the decision, to show why the Responsible Official’s decision should be reversed. An appeal submitted to the Appeal Deciding Officer becomes part of the appeal record. At a minimum, an appeal must include the following (§ 215.14):
(1) Appellant’s name and address (§ 215.2), with a telephone number, if available;
(2) Signature or other verification of authorship upon request (a scanned signature for electronic mail may be filed with the appeal);
(3) When multiple names are listed on an appeal, identification of the lead appellant (§ 215.2) and verification of the identity of the lead appellant upon request;
(4) The name of the project or activity for which the decision was made, the name and title of the Responsible Official, and the date of the decision;
(5) The regulation under which the appeal is being filed, when there is an option to appeal under either this part or part 251, subpart C (§ 215.11(d));
(6) Any specific change(s) in the decision that the appellant seeks and rationale for those changes;
(7) Any portion(s) of the decision with which the appellant disagrees, and explanation for the
disagreement;
(8) Why the appellant believes the Responsible Official’s decision failed to consider the substantive comments; and
(9) How the appellant believes the decision specifically violates law, regulation, or policy.
Notices of Appeal that do not meet the requirements of 36 CFR 215.14 will be dismissed.
Pursuant to 36 CFR 215.9(a), if no appeal is filed, implementation of this decision may occur on, but not before, the fifth business day from the close of the appeal-filing period. All appeals must be filed within 45 days of the date that the legal notice appears in the Boulder Daily Camera, Boulder, Colorado.

Contact
For additional information concerning this decision or the Forest Service appeal process, contact:
Cat Luna, Project Leader, Boulder Ranger District, Arapaho and Roosevelt National Forests and
Pawnee National Grassland, 2140 Yarmouth Avenue, Boulder, CO 80301 or telephone at (303) 541-
2500.
__/s/ Christine M Walsh _______________________ ____5/31/06___________
CHRISTINE M. WALSH DATE
District Ranger
Boulder Ranger District


Response to Public Comments
Comment Topic 1: Alternatives
1) I would also like to know where these alternatives came about and what the thinking is
behind closing these types of areas instead of coming up with solutions to keep them open or
even opening new areas as alternatives. 282

Response: The alternatives are issue driven as required by NEPA. The Ea analyzes a reasonable
range of alternatives (solutions) that address the Purpose and Need, key issues and is responsive to the needs of the motorized community, local landowners, and the general public. Please refer to the EA to better understand the issues, actions under each alternative and details about environmental consequences for reasoning of how each alternative addresses the issues. Refer to other related responses in this section for additional clarification.

2) The action alternatives play good guy/bad guy against the users and pit user against user.
The effect of splitting available opportunities between different alternatives inevitably splits the user community into competing factions thereby diluting the effect of citizen response to the EA. This is unethical and maybe illegal as it contravenes the intent of the NEPA. 232

Response: The action alternatives are intended to reduce user conflict while balancing motorized use opportunity with adequate resource protection. Design/mitigation and monitoring measures were developed to ease potential environmental impacts and user conflicts the various alternatives may cause. Refer to EA Section 2.2, Design/mitigation and Monitoring Measures, pages 12-15.

3) None of the alternatives differ substantially in terms of miles of route opportunity provided. None of the alternatives allow any substantial new route construction. All alternatives result in the closure of the majority of the current routes. NEPA requires that an agency consider an alternative that addresses unresolved conflicts. None of the alternatives does this. Instead the EA considers no change versus three alternatives that are all but indistinguishable as to the areas and road/ trail segments that would be closed. This does not resolve the resource conflicts but simply substitutes one set of conflicts for another. 226, 280, 296

Response: Each action alternative maximizes motorized use opportunities given limited viable
biophysical resources, parameters for reasonable sustainability, user conflict and many other factors. The Lefthand Canyon Off-highway Vehicle Area Roads Analysis Report -2005 (In Project Record)) identifies opportunities and priorities for developing the Lefthand OHV Area transportation system. The Road Analysis used a variety of risk indicators to help understand/assess the roads/trails in the area and provides recommendations to achieve plan objectives. The difference and effectiveness of each action alternative is a direct result of using these recommendations, engaging in constant public involvement and following detailed requirements of NEPA.

4) The alternatives offered by the USFS are absolutely unacceptable. 124,135,145, 226, 274,
291

Response: Alternatives B, C, and D are reasonable, issue driven by public input, and address the Purpose and Need identified for this project level EA. The No Action Alternative was also considered as required by NEPA. Each alternative was developed utilizing valuable input derived during various forums of public involvement. Please refer to related responses to comments in this section for additional clarification.

5) I would like to request that you choose to adopt Alternative C. This alternative would be a
better solution for me and motorcyclists. It would also result in less impact on the
environment since single tracks don't take as much space and won't erode as easily. This also
would provide valuable access to Fairview Peak I like the loops that would be added, making
form some great riding. I believe Alternative C would be the best choice for this area and
would appreciate your consideration. 63

Response: Alternative C was considered along with Alternatives a, B, and D with regards to meeting the purpose and need and public input.

6) I am frustrated by the fact Alternative C does not include a fee scheme. I fully support fees to help manage such an area. The list of pros and cons for Alternative C shows that it not only provides numerous recreational opportunities and does a good job of protecting plant and
wildlife habitat. The biggest draw back is no fee. Why not make an Alternative C with fees?
Such an option would serve all the interested parties in this area much better. 52

Response: All alternatives were considered with regards to meeting the purpose and need and
public input. The decision does include charging fees at the Lefthand Canyon OHV Area. Please
refer to the Decision Notice for details.

7) I support the recommendations proposed in the Lefthand Canyon OHV Alternative D Travel
Management Plan. Boulder County is concerned that OHV use would negatively impact the
closed and protected areas of parks and open space. Heil Valley Ranch in particular will
benefit by not having OHV use in the Fairview Peak area. Alternative D is balanced and
protects critical wildlife areas and concentrates OHV use in appropriate areas. 6

Response: Each of the action alternatives in the EA consider the affects OHV use would have within and adjacent to the planning area. Your concerns have been considered and will be addressed no matter which alternative or set of actions is determined to most effectively manage use in the vicinity of Fairview Peak. Effectiveness monitoring will ensure compliance with applicable use regulations, while protecting natural resources/critical wildlife habitat.

8) Alternative D offers even better resource protection, so I would advocate for that if the agency can swing it. 9

Response: Alternative D is reasonable and compliments the spectrum of alternatives identified in the EA. Please refer to number 7 above for additional information.

9) The only acceptable alternative in this EA is Alternative A. This is not because Alternative A is desirable but because Alternatives B, C, D are much less desirable than Alternative A.
There is no need for a decision on travel management of this area that is so pressing that users must settle for a bad action alternative. Therefore, I support Alternative A for as long as it takes to generate a truly good and useful action alternative to supplant those offered in this EA. 232, 247, 249, 252, 254, 256, 259, 266, 271, 274, 275, 277, 280, 281,292, 293, 258, 296, 297, 298, 300

Response: To be proactive in recreation management while protecting natural resources, it is necessary to plan for and manage the Lefthand OHV Area. The purpose and objectives are to implement Forest Plan direction and resolve long-standing issues plaguing the area. A reasonable range of alternatives, including the No Action Alternative, were developed and analyzed as required by NEPA based on the Purpose and Need and issues received during public scoping. The action alternatives are reasonable, while the No Action Alternative reflects an unacceptable existing situation. Please refer to related comment responses in this section for additional clarification.

10) Plan A (no action): I have noticed that 4x4 activity requires more trail/road maintenance, especially when steep grades are involved. LHC gets a lot of 4x4 traffic and the effects are obvious and need attention. 167

Response: We agree that increased use coupled with steep and oftentimes very challenging motorized opportunities requires additional road/trail maintenance and the need for specialized related services. Reference to these issues can be found throughout the EA.

11) We respectfully ask that all of our comments and information be used to justify motorized access and motorized recreational opportunities in the project area and to counter any opposition to those opportunities. The following is a checklist of issues that affect motorized recreationists and define the current management situation. This checklist is provided with
the request that it be used to develop, select, and defend a reasonable multi-use alternative. 217

Response: The 103 page document is clearly not specific to the Lefthand Canyon OHV Area Travel Management Plan EA. Examples of why the Forest Service believes the 103 page document is not specific to this project include but are not limited to (this list is for illustrative purposes only and is not complete): “We respectfully ask that the selected action for the Butte RMP Travel Plan Project be structured to produce this end result by implementing the comments provided”. “The concept of area closure is not consistent with Forest Service regulations as established by appeals to the Stanislaus National Forest Travel Management Plan”. “Montana Department of Fish, Wildlife and Parks (MDFWP) is focused and managed as a fish and wildlife management agency. We request that MDFWP actively promote OHV recreation and OHV tourism. We also request that MDFWP increase the level of OHV management to a level that addresses the needs of motorized recreationists, enthusiastically promote OHV recreation opportunities and enthusiastically develop OHV tourism”. “"Special designations" should be deleted from the proposed alternative”. (The alternatives in the Lefthand Plan do not identify any “special designations”) “The process used puts the average working class citizen at a great disadvantage. The process is inordinately confusing, cumbersome and intimidating to the members of the public who are not organized or experienced which is the majority of the public. The process is inordinately demanding of participation and has unreasonable expectations for the involvement of individuals and families. A 300-page draft EIS and finally a 300+page final EIS is too much for the general public to understand and participate in”. (This is an EA and not an EIS) “The prevailing trend of the past 35+/- years has been to close motorized recreation and access opportunities and not create any new ones. Additionally, roads or trails closed to motorized access are seldom, if ever, re-opened. The underlying objective of the BLM and Forest Service has been to restrict the public to a few major roads within public lands. We request that the cumulative negative effect of these policies be thoroughly evaluated so that a reasonable travel management decision is made”.
(Not site specific to this EA) “We request that the significant impact from all cumulative statewide motorized closures on all of these visitors must be included in the environmental document. A statewide analysis is required because cumulative negative effects are forcing all motorized visitors to travel farther and farther to fewer and fewer places to find motorized access and recreation opportunities”. (Not site specific to this EA) Only comments specifically referencing the Lefthand Canyon OHV Area travel Management Plan EA project by name will be addressed in this Response to Comments and will be addressed in their appropriate sections. The remaining comments will not be addressed because they are not site specific to this project, and it cannot be discerned whether the comment refers to this project or the Butte RMP Plan, Stanislaus National Forest Travel Management Plan, or some other project.
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Comment Topic 2: Collective Comments
1) Some comment letters asked the Boulder Ranger District to collaborate with OHV clubs and
individuals as partners and volunteers in the maintenance and management of the Lefthand
Canyon OHV Area. Other letters asked the Forest Service not to alienate the volunteer OHV
constituency otherwise they may take their contributions somewhere else where they are
appreciated. It was also stated that the EA fails to recognize the past efforts and fund raising clubs and volunteers have contributed to the management of Lefthand. Additional letters
suggested that routes should not be closed given the volunteer efforts that have gone in to
managing the OHV area. 37, 42, 43, 65, 177, 232, 238, 240, 247, 252, 253, 259, 275, 277, 278, 281, 292, 293, 297, 300

Response: The Boulder Ranger District greatly values its partnerships with the OHV community.
Several rehabilitation, restorations, and road maintenance projects would not have been
accomplished without the contributions of the OHV community and many of its clubs. It is the
District’s intent to continue to work with the OHV and environmental communities to provide and
maintain sustainable OHV recreational opportunities which would not otherwise be possible given the District’s limited resources to manage these opportunities. The EA does acknowledge these
contributions in various places in Chapter 3. While the District greatly values the contributions from the OHV community, this does not preclude travel management planning. Because a club or other constituent adopts or maintains an area or road does not guarantee that it will not be closed if travel management planning and analysis calls for its closure.

2) Some commenters said that restoration efforts are important and that concern for the
environment must be paramount. Waterways must be protected from toxic spills. Those
using off-road travel in the area needs to be controlled and restricted. Those using the trail
systems in the area in an uncontrolled manner are rapidly facilitating the natural erosion in the area. The main question to ask is why they are accommodated at all when they do such
tremendous damage. USFS should do all in your power to protect our forests. 4, 23, 25, 157

Response: The Purpose and Need for action and the objectives for this project (Chapter 1 page 3 of the EA) support the concerns addressed in this comment. It does so by developing a sustainable road and trail system that is designed to maximize both recreational use and environmental protection, by rehabilitating the impacts from motorized uses, and by installing traffic control devices to keep people on route. Chapters 2 (page 12 under Mitigation and Monitoring), and Chapters 3 (page 58 under Water, Soil, and Fish) describe how the plan protects water and soil resources. The Forest Service does recognize off-highway-vehicle use as a legitimate use of National Forest public system lands and the agency feels that with proper management, the damage caused by inappropriate OHV use on the Forests can be controlled.

3) Some commenters provided suggestions on how to manage the Lefthand Canyon OHV
Area. These suggestions are: Cross country travel and the constructions of new trails by horses, bicycles, and motorized vehicles should be controlled and restricted. Speeding by bicycles and motorized vehicles needs to be controlled and restricted. 23 The cost of roadway and trailway maintenance can be prohibitive to some governmental agencies, but, waving the maintenance of many of these areas to the recreational user and posting as non-maintained and enter at your own risk can make these areas more attractive to some users and they will maintain appropriate to their usage. 170 No roads or trails should be closed until ALL the new roads and trails have been completed and opened. 65 I support instituting good management by including signs, user education, restoration and trail maintenance. 5 Good management includes trail maintenance, signage and public education. 58 Requirements for closure should be required to: Post and educate for responsible usage for a minimum of two years prior to environmental impact surveys. Posting as a non-maintained trail with guidelines listed will in most cases promote responsible usage by serious OHV users that will police their own offenders. 170 Maybe you could put some railings in or something to direct traffic better and have some educational programs for users to teach them how to use the resource better. 114 Increase the use of signs and visitor education to help forward restoration and trail maintenance. 7

Response: The Forest Plan states that there will be a motorized emphasis in the Lefthand Canyon
OHV Area (EA, page 3). However, multiple-use is not prohibited by the plan. Horses, mountain
bikers, hikers, and other uses are still allowed in the area. These non-motorized uses can travel cross-country as allowed under current Forest Service regulations. Speed will be dictated by the terrain and difficulty rating of the routes as proposed in the EA (EA page 11). The designated routes after the decision will receive maintenance and will be maintained at their difficulty rating as budget allows. An implementation schedule for this project will be developed. This schedule will take into consideration when to close trails as suggested above. The implementation schedule will also include signage, route barriers, and education as all of these suggestions are included in the actions common to all action alternatives (EA, page 11).

4) One comment letter questions the definition and intent of sustainability as stated below:
The management style expressed by this EA is trying to control us, the users, when the
Forest Service’s job is to manage the natural resource for the optimal multiple uses
while doing so in a manner to ensure that uses, the outputs from the resource, will be
sustainable. The primacy of multiple use/sustained yield lies with the users. The
resources are kept usable for the sake of the users. The resources do not have to
remain constantly the same, without change, in stasis. The point of view underlying the
creation of this EA needs some adjustment. 232
The USFS vision of sustainability equates to preservation, where nothing changes.
This is an incorrect interpretation of sustainability, as pointed out above, AND it is
absolutely anti-natural. With lots of OHV activity in the area, things are different than
without, and that is natural and it is ok but it is not nearly as threatening to the future as
proposed because in the long run, "life will find a way". 232

Response: A definition of ‘sustainable” can be found in the Glossary in Appendix C (page C-5). This definition is as follows:
Sustainable – using a resource so that the resource is not depleted or permanently damaged.
This definition does not equate to preservation as implied above, but to wise use of the resources so that use of the resource can be maintained over the long term.

5) This EA relies heavily on the notion of "quality" user experience and ignores quantity which
is an important facet of quality. The USFS speaks of quality from its point of view, not the
user's point of view. But it is the user's point of view that determines what is a quality
experience and in the users' point of view, quantity looms large. The attitude expressed in 1.3
Decision Framework, that "the proposed projects benefit the public and are in their best
interest" indicates an arrogance on the part of decision makers that they know what is good
for us better than we, ourselves, do. Reconsider what constitutes a quality, out of doors
experience. 232, 291

Response: In order to identify a sustainable road and trail system, the interdisciplinary team had to balance both the needs of the users with environmental impact concerns. Quantity was maximized given environmental constraints when designating the proposed road and trail system. Quality was also considered through user input during scoping and public meetings.
The above comment regarding 1.3 Decision Framework is out of context. The statement referred to
above is actually stating that the deciding officers reviews the Proposed Action and other alternatives to ensure that they do benefit the public and are in their best interest versus being detrimental to the public interest. This is contrary to the idea that the EA is deciding what is good for the users.

6) This EA likes to speak of "extreme disturbances" caused by OHV use. OHVs do not cause
"extreme disturbance". They just scratch the surface of the earth a little bit. Even a very large increase in OHV use at Left Hand could not result in "extreme disturbance". The term is dramatic but not realistic. 232

Response: The Boulder Ranger District disagrees with this assertion. Use patterns from three years ago up to this current plan show extreme resource damage caused by OHV use. This includes loss of soil and vegetation, soil compaction, and damage to water resources (please see example pictures that can be found in the project record).

7) If the BRD gets its act together and tries to make a good system of trails and becomes user
friendly to motorized recreationists, it should be easy to get some additional funding to
support these efforts. 281

Response: As outlined in the Purpose and Need (page 3), objectives of the plan include providing a sustainable road and trail system, protecting natural resources while providing a quality recreation experience and increasing signage and traffic control. All of these actions will potentially increase the user-friendliness of the area to motorized recreationists.

8) We would like to see a comprehensive and interagency approach to this larger problem. 238

Response: Because this is a local project and was analyzed on a project level, working on a
comprehensive and interagency approach is outside of the scope for this project. The Purpose and Need and objectives for this EA are for the Lefthand Canyon OHV Area project area only and does not take a broader view. The Forest Service does agree that this is a larger problem and a
comprehensive approach has been directed under the new OHV Rule. The Boulder Ranger District
will begin a comprehensive travel management strategy within the recent future of this decision and the public will be involved in that process as well. In addition, this decisions made in this plan will be incorporated into the District’s overall travel management planning as required by the new rule.

9) pp8 - AltA - I would be uncomfortable saying "unmanaged" for the situation. That would
imply you are shirking responsibilities. There is always some level of "management"
(oversight, patrol, tickets, we drove by and waved…). 51

Response: Given the District’s limited resources to properly manage the Lefthand Canyon OHV Area, the area is considered unmanaged. The District did however increase Forest Service presence in 2003 and 2004 in the OHV area. This was made possible by a grant received by a local OHV club specifically for Lefthand. The District is not shirking its responsibilities to manage the area, but lacks the resources to do so. The Lefthand Canyon OHV Area is an example of one of the Chief’s four threats which includes unmanaged recreation.

10) We noticed that half of the mileage proposed to be closed is unplanned, user-created
routes and 3.3 miles to be closed are already grown over and now longer in use. Very little
classified single track is being closed. 14, 287

Response: Very little classified route mileage is being closed in this plan. The majority of route closures are unauthorized routes. A complete description of route closures can be found in Chapter 2, page 8 and throughout Chapter 3.1 of the EA.

11) It would be wrong for the Boulder Ranger District (BRD) to set a precedent that if a private land owner wants a public road closed, all he has to do is cut down 100's of trees in BRD and destroy the road. 65

Response: The act referred to in this comment is outside the scope of this project. This matter, which occurred a year prior to the onset of the Lefthand Canyon OHV Travel Management planning process, was turned over to, and pursued by local Federal law enforcement authorities. It is not the intent of the Forest Service to encourage or allow the precedent of such illegal activities on National Forest public system lands. One of the objectives outlined in this plan (page 3 in the EA) is to develop a sustainable road and trail system for off-highway-vehicles. The road system developed in this plan achieves this objective and was approached without bias to the illegal action described above.

12) Travel plans are created or revised every 10 years. If 25 to 50% of the existing motorized
recreational opportunities are closed in each successive travel plan then over the course of 3
travel planning cycles or about 30 years in a given area, only 13 to 42% of the original
motorized recreational opportunities will remain at the end of the third cycle. This trend is
being ignored at all levels including the actions listed in Table 2. The plan for this project area does not recognize and address this trend. The Lefthand Canyon plan and the Arapaho-
Roosevelt Forest Plan do not adequately recognize and address this plan. Therefore, this
cumulative effect is being effectively ignored and that failure to notice will result in the
ultimate loss of any meaningful motorized recreational opportunities and the creation of
defacto wilderness from large blocks of multiple use lands. 217.

Response: The Lefthand Canyon OHV Travel Management Plan EA is on a local project level and
only analyzes actions within the project area boundary. This comment is outside of the scope of this project because it would require a Forest level analysis.

13) As you know, the 2000 Caribou "mud fest" incident graphically portrayed the damage that
can occur, even within a single day, when large numbers of OHVs congregate. We are greatly
concerned that the cumulative impacts, from hundreds of OHVs across the county, are very
difficult to discern at any given time, but are continually and slowly building to a similar level of impact at many other sites. Season after season, the impacts spread into previously unroaded areas. Some of these possible other areas of concern for increased impacts from
OHVs include: Bunce School Road, particularly at the north end; County Road 116J between
Caribou and Rainbow Lakes; continued access into the west end of the closed CR 102J; and
likely many others. We would look forward to a continued dialog on these issues. 238

Response: Looking at other areas outside of the Lefthand Canyon OHV Area project boundary is
outside the scope of this project. However, the District is equally concerned about the increasing impacts from motorized use across the District, and will continue to complete travel management projects until the entire District has been analyzed. The District will be encouraging such dialogue during ongoing travel management issues.

14) There is NO Management Plan on how the Boulder Ranger District (BRD) is going to
implement any of the alternatives except for A. The "Left hand Canyon Off Highway Vehicle
Area Travel Management Plan" states "The Left hand Canyon OHV Area has received little
management direction . . ." What has changed so that there will be some management? In
fact, to implement any of the plans except for A is going to take a lot of management direction
and presence in the OHV Area. Has BRD received more funds, more personnel? Is the fee
system the answer? Put more personnel in the field. Reduce the amount of hours logged in
the office by 50% and divert those hours to the field. To implement any of the changes, the
BRD is going to have to have a much larger presence in the OHV area. 65

Response: The decisions made in this plan will provide the management direction and will address items such as presence and funding as these are also addressed in the Purpose and Need of the plan (see Chapters 1 for the Purpose and Need and Chapter 2 for the alternatives developed to meet the Purpose and Need). When the decision has been made through the release of the Decision Notice, an implementation schedule will be developed to implement the actions outlined in the Decision Notice.

15) My family and friends enjoy this area for OHV recreation since 1995. 168

Response: Thank you for your comment.

16) OHV use is a national issue. The demand for access will continue to grow, but the National
Forests cannot, and should not, be expected to accommodate this demand. 4

Response: This comment is outside the scope of this project because this is a project level EA and not a national one and the comment above refers to a national level issue. However, the Forest Service recognizes that OHV use is a national issue. Three months prior to the expected release of the Lefthand Plan decision, the agency adopted new regulations addressing OHV and transportation access on National Forest public system lands. The agency does acknowledge OHV use as a legitimate use of the Forests and has set guidelines for management of that use.

17) I recently received information that the motorized recreation in Left Hand canyon could be
seriously restricted if a plan by the USFS is implemented. Is there anything I can do to change
the plan if it restricts motorized recreation? 69

Response: The public, private land owners, OHV recreationists, and environmental groups have
been encouraged and invited to participate in this process through public involvement letters and meetings from the initiation of the plan up to the EA and decision. The public involvement process for this project is described on page 4 of the EA.

18) As a local resident, I have always had mixed feelings about this area. On one hand, having
such an area draws in people and activities that I am often not enthusiastic about. 243

Response: Thank you for your comment and input to this travel management plan.

19) If the Boulder RD had done appropriate road and trail work over the past 30 years, the area
would show much less use than it does now. Please do not blame OHV users as if they were
the only ones who contributed to current levels of wear and tear. Yet, even without USFS
participation the area is still in good shape and most of the complaints about it are petty and
superficial. 232

Response: The Boulder Ranger District acknowledges that the Lefthand Canyon OHV Area has
received little management over the past twenty years or more due to lack of resources such as
personnel and budget. This plan attempts to reverse that trend and to provide a managed recreation area for OHV’s with a sustainable road and trail network and various challenge levels. The Boulder Ranger District disagrees however that the area is in good shape as discussed in comment number 6 of this section. 20) As one reads this EA, it becomes quite apparent that the real and actual intent of this EA is to close motorized routes. It is the only significant functional solution offered to meet the Purpose and Need stated in the EA -- BUT, that is not serving the needs of the American people nor of the lands in the Left Hand OHV area. 232

Response: The intent if this EA is outlined in the Purpose and Need found in Chapter 1 page 3.
Included in this section are also the objectives of this plan. The intent is not to close routes but to provide a sustainable road and trail system in addition to the other objectives listed. Several unauthorized routes are proposed for closure because they are either causing resource damage, or are not congruent to the main system. Routes that are necessary to keep a contiguous sustainable system within the project area boundary that are causing resource damage will be repaired and monitored as outlined in the Mitigation and Monitoring section of the EA found on page 12.

Comment Topic 3: Displacement
1) You discuss the Lefthand area as if it is its own entity where events that happen here have
no impact on other areas in the district. How can you say that #14 and #16 in Appendix A-2 are
conjecture? How can you say displacement is already occurring? Where are you numbers
that document current displacement? Do you have statistics showing that total users of
Lefthand have decreased while other areas have seen increases that correlate to this
reduction at Lefthand? 244

Response: We have not had the resources to complete scientifically credible surveys of recreation users in the Lefthand area or on other places on the District, nor are we aware of anyone else who has collected this kind of information, which is why we say that these statements are conjecture. We are not agreeing or disagreeing with the statements. The knowledge we have about displacement comes from informal interactions we have had with users both in the field, and in the extensive series of public meetings we had about the current and future use of the Lefthand area, and other areas on the District that are popular OHV areas.
The possibility of additional displacement from Lefthand into other areas of the District was brought up by members of the public as a concern in meetings, and was discussed by the interdisciplinary team (IDT) who did this Environmental Analysis.

2) Some comment letters received discussed the issues of displacement. The letters state that
by closing routes or restricting use, motorized recreationists will be displaced to other parts of the District and cause new user-created routes or resource damage elsewhere, or create more
user-created routes in Lefthand. Other Letters also stated that closing routes here would make
other areas more crowded and that closing this area increases pressure on those new
roads/areas 3, 23, 30, 33, 34, 35, 72, 80, 156, 229, 238, 240, 244, 269, 285, 298

Response: As stated above, displacement from Lefthand to other areas of the District was brought up as a concern in public meetings and was considered by the IDT. Our hope would be that by providing a range of satisfying OHV opportunities within Lefthand that displacement from other parts of the District into Lefthand may occur.
National Forest lands and funding are limited resources in a situation where public demand for this and other recreation uses seems unlimited. While we were planning for Lefthand, the Forest Service, nationwide, adopted new policy on Off Highway vehicle management. We think this new policy will help, over the long term, with management of displacement. Through this policy the District will be publishing a motor vehicle use map, starting in 2009, and will limit all motorized use to routes published on the map. The map will be updated annually to include changes that are made to our authorized system of roads and trails for motorized vehicles. This should help with displacement.

Comment Topic 4: Environmental Justice
1) Some commenters stated that many handicapped, elderly, or physically impaired citizens
can only access and recreate on public lands by using motorized roads and trails and that the
Forest Service has an obligation to allow OHV recreation for everyone but especially to
provide access for handicapped individuals. 254

Response: The Lefthand Canyon OHV Area Travel management Plan EA provides a sustainable and
manageable road and trail system. This system may be used by OHV enthusiasts and by those with
physical impairments requiring motorized vehicles for recreation in the Forest. Therefore, by
providing this system of roads and trails that the Forest Service can manage in the long-term,
motorized opportunities for persons with physical impairments is provided for and enhanced under this plan. The road and trail closures proposed in this Plan are equal to everyone and therefore are not discriminatory to those with physical impairments.

Comment Topic 5: Fairview Peak
1) Several respondents referred to the core habitat area surrounding Fairview Peak and other
respondents questioned the validity of using the core habitat area or wildlife as a reason to
close the area to motorized use. These comments are as follows:
The core habitat area is outside of the planning area and allowing motorized at Fairview
peak does not violate the Forest Plan. Reducing recreational use levels in the area as
stated in the Plan does not mean eliminating opportunities. Fairview Peak falls into the
4.3 management prescriptions in the Forest Plan, therefore eliminating motorized use
violates the Forest Plan. In addition, a buffer zone is not required around the core
habitat area and is inappropriate considering this is one of the few areas on the District
managed specifically for motorized use. Furthermore, this area will not impacted from
motorized use. 22, 57, 232, 275, 280, 296
The EA describes the need to protect a Core Habitat Area, and therefore justifies
closing the Fairview Peak Area. Yet the 1997 LMRP does not show a Core Habitat Area
in the Fairview Peak Area. The EA provides no scientific documentation on the wildlife,
and it shouldn't. If the USFS were to provide wildlife habitat information that would
change the Core Habitat Area, it would then be required to amend the LMRP and utilize
an EIS.
Wildlife in "core wildlife area" has been surviving just fine for over 100 years in
presence of humans visiting Fairview. The wildlife does not need special attention.
OHV use is not wrecking Fairview Peak area wildlife and will not in future. This EA talks
frequently about the "core wildlife area" but does not supply a substantive wildlife
inventory to justify its claimed need to increase protection of the area. In the Summary
of Impacts for Species on page 77, none of the species is shown to be threatened or
negatively impacted by any of the Alternatives, including Alternative A. Use of the
phrase, "increases the likelihood of future encroachment into Core Habitat", when
referring to Alternative A or route 285.1 in Alternative C, rings hollow. It is one of the
endless "could be", "could have", "possible", "might", etc terms which this EA uses to
propose the "expected" effects of continued OHV use. The EA tries to make 40 or 50
years of
OHV use sound like it will happen all over again in a week, unless "managed". In fact,
increased protections and increased route closures are not needed and not justified.
232, 247, 252, 259, 277, 281, 292, 293, 297, 300
Regarding core habitat for wildlife, it seems to me that the map indicates a great deal of
acreage outside the current analysis boundary for that. I have ridden U-cg which
apparently extends into this area. I liked that trail, but it would've been better if it were a
loop (versus out and back). Anyway, that area seems to have great potential for
singletrack. 167

Response: The Forest Plan is a guiding document for all forest management activities. The Plan also recognizes that changes in site specific conditions and further site specific or project level planning will occur during the 10-15 year life of the plan. Changes are expected to be made given evolving circumstances, or new data, as long as the effects of the change are analyzed and the public is given an opportunity to comment on any proposed change, such as is this planning process. Changes can be consistent with the Forest Plan direction, as in the Proposed Action, or inconsistent with the Forest Plan, in which case a Forest Plan amendment must be made. The commenters are correct that Fairview Peak area is in a 4.3 management area, with emphasis on Dispersed Recreation. Being in a 4.3 management area does not guarantee motorized access. Part of the guidance for that management area in the Forest Plan is: ”Open roads provide motorized recreation opportunities and restricted roads provide non-motorized opportunities”. Restricting motorized access to the Fairview Peak area as in Alternatives B and D, and to 4-wheel vehicles in Alternative C, is being proposed more in response to changed circumstances than it is to protecting wildlife in the Core Habitat area to the north, though wildlife protection is a secondary consideration. Since the Forest Plan was signed in 1998, the public and the Forest Service have been restricted by local private landowners from accessing the area across their private lands through the installation of multiple gates.
An identified Purpose/Objective for this project (EA p. 3) is to “provide and maintain a sustainable and manageable road/trail system”. Since the Forest Service has no legal motorized access to the Fairview Peak area, the manageability of motorized access would be extremely difficult at best. Access to Fairview Peak for single track motorized users was analyzed in Alternative C (see discussion of Direct and Indirect Impacts from Alternative C on Key Issues, EA p. 35) In this Alternative single track and non-motorized access would be provided around private land to Fairview Peak through the construction of a new trail. The success of implementing Alternative C is predicated on the use of effective traffic control barriers to keep single track use on the designated route. The cost of installing and maintaining traffic control devices for this area would be substantial as would be the cost of monitoring/enforcement patrols. Even with the establishment of fees for the area, the
cost/benefit trade-offs for various options must be considered given an expected limited funding stream. Regardless of the alternative selected motorized users could park their vehicles and hike the final distance from the northern most point of motorized access to experience the scenic values of the Fairview Peak. A re-routing of the road for full size motorized vehicles was considered as part of the analysis of alternatives but was determined to be infeasible due to terrain and cost. Core Habitat areas were established in the Forest Plan (p. 339) to “maintain existing habitats which were shaped primarily through natural processes”, and prohibit motorized use. Species of specific concern (MIS species) in this Core Habitat area are elk and mule deer. The Biological Report, which is part of the project record, analyzed the effects of all alternatives on these and other species and determines that Alternatives B and D, which would close Fairview Peak area to motorized vehicles, have the best overall positive influences for these species. This information was used, in addition to the changed circumstance information detailed in response #1 above to develop the Proposed Action.
Commenters are correct that the Core Habitat Area is to the north of Fairview Peak. Improving the effectiveness of that area is not the only reason considered for proposing closure of Fairview Peak to motorized use (see more detailed discussion in #1 above).
The Biological Report (p.12) also describes the importance of maintaining or improving wildlife habitat effectiveness in the James Creek Geographic area, of which the Lefthand project area is a part. In this Geographic Area 57% of the habitat was determined to be effective almost 10 years ago when the Forest Plan data was analyzed. Since that time many roads and trails have been created by users and over 3,000 acres of the Geo Area were burned over in the Overland fire in 2003, further decreasing the amount of effective habitat.
In Alternative C Fairview Peak would remain open to single track vehicles via a re-routed loop trail that does not enter the Core Habitat area to the north. See also some of the challenges of managing this area for single-track use discussed above.

2) Many commenters are opposed to closing access to Fairview Peak. This area has a long
history of tradition, the roads date back to before the Forest was created, and this area offers unique recreational opportunities to motorized users not available on other parts of the
District. Other commenters said to keep the area open and suggested specific routes that
could make this happen. Reasons to keep Fairview Peak open include, historic use, there are
already limited motorized opportunities, accessibility for mobility challenged individuals,
unique recreational opportunities found within the area, etc. Some commenters also stated
that the area should be accessible to full size off-highway-vehicles, other said it should be
accessible via single-track only. 22, 46, 53, 57, 65, 66, 67, 71, 75, 77, 79, 81, 82, 83, 84, 85, 87, 88, 90, 91, 94, 97, 98, 99, 100, 101, 102, 103, 104, 105, 106, 108, 110, 111, 112, 114, 115, 117, 118, 119, 120, 121, 122, 125, 127, 129, 131, 133, 135, 137, 138, 139, 140, 141, 142, 146, 147, 150, 152, 154, 156, 158, 160, 161, 163, 164, 165, 166, 167, 172, 173, 174, 175, 176, 178, 179, 181, 182, 184, 185, 189, 190, 192, 194, 195, 200, 202, 204, 205, 206, 207, 208, 209, 215, 216, 217, 218, 219, 220, 222, 225, 226, 227, 228, 230, 231, 232, 234, 236, 237, 239, 245, 246, 248, 251, 263, 265, 267, 276, 279, 286, 288, 295, 299, 301

Response: Please see the response to number 1 in this section and also to number 23 in the Road
and Trail Network section and to the RS2477 section of this document for further discussion on
historic routes.

3) After Jan. 31, 2006 the Fairview Peak area will reopen after having been closed for several
years due to the Overland Fire. Upon reopening, the Fairview Peak are will be ruled by the No
Action Alternative, Alternative A, unless an action alternative is implemented by this EA.
Motorized users will again visit the Fairview Peak area. The handling of this EA by the Boulder
RD seems to be striving to avoid this situation. 232

Response: On 1/23/06 the Closure of the Overland Fire area was extended for an additional year
because of a continuing need to provide for public safety and allow more time for resource recovery. Should this Lefthand decision not be in place when the closure expires, the commenter is correct that the Fairview Peak area will be governed by the regulations currently in place and covered in the No Action Alternative. There is no direct connection between this EA and that post fire closure.

4) The northern loop and connection of single-track trail to the Fairview area, Alternative C, is good and should be done. Full sized vehicles must also be accommodated. 232

Response: Please see the response to number 1 above.

5) Many letters received support the closure of Fairview Peak for various reasons ranging from
protection of resources such as wildlife and soils, to the reduction of improper user-created
routes in the Fairview Peak area. 4, 8, 10, 12, 14, 25, 28, 49, 54, 58, 59, 113, 197, 199, 238, 239, 269, 287

Response: Please see the response to number 1 above. Additionally closure of the Fairview Peal
area to motorized and mechanized travel would benefit soil, water and aquatic resources in the
project area because new routes would not be created and existing routes would be closed and
stabilized.

6) Fairview peak has been inaccessible since the tree downing incident, and fenced off after
the fire. It is currently shut off with no known/posted date or way for access. Plan A mentions
the Peak as being accessible and continuing to be, which seems to be inaccurate. 167

Response: Please see the response to number 1 above.

7) The idea that the Core Habitat Area, which goes all the way to Button Rock Reservoir to the
north needs a buffer zone carved out of almost half of the only area on the Boulder Ranger
District that is to be managed with a high priority to motorized recreation seems to violate the Forest Plan. 22

Response: Please see the response to number 1 above.

Comment Topic 6: Fees
1) Several respondents were opposed to fees to use the Lefthand Canyon OHV Area. Some of
the reasons cited are as follows:
OHVers who have gotten at $230,000 in grant money and put in countless hours of
volunteer work for the Lefthand Canyon OHV Area, and now they may be charged to
use the area. Fees should not be charged and it is preferred that OHV groups
volunteers and grants be used to manage the area.
The USFS is supposed to operate on appropriated tax monies. I expect the Forest
Service to fight in Congress to get my taxes so that my taxes can be put to use as I
have specified. I already pay taxes and I shouldn’t have to pay to use public land.
It seems inappropriate to charge fees to use the area when you are reducing or
degrading the motorized recreation opportunities available in the area.
Fees are discriminatory against motorized recreationists, as the USDA Forest Service
isn’t charging fees for non-motorized recreationists in the Boulder Ranger District.
If you create a fee where one was not before, you can possibly eliminate people who
can’t afford the fee from using the area.
Several letters did not state reasons as to why they are opposed to fees.
53, 74, 81, 117, 127, , 141, 148, 164, 202, 205, 224, 244, 226, 232, 247, 252, 259, 271, 274, 275, 277, 281, 282, 291, 292, 293, 297, 300

Response: The Boulder Ranger District sincerely appreciates its partner’s good faith effort in
providing much needed support for managing the trail system within the Lefthand OHV Area. Recent efforts have established a strong sense of land stewardship and improved OHV opportunities. The District has emphasized partnership coordination and funds/supports a variety of on-the-ground projects in the area. The District continues to follow through with its OHV-related commitments in Lefthand while facing declining federal budgets and at the cost of deferring much needed travel management in other critical areas. There remains a fiscal responsibility associated with authorizing more than routine road/trail maintenance, additional system road/trail, and facilities to support OHV opportunities. Fee collection helps provide consistent long term management of the area by facilitating fiscal flexibility.
We currently charge a fee to non-motorized recreationists for overnight backcountry camping in the Indian Peaks Wilderness. This small fee has no impact on civil rights because the permit is equally available to all persons. Fee revenues support increased patrols, trail maintenance, backcountry signs and other Wilderness resource protection activities. Fees collected for specialized services provided in Lefthand OHV Area will also be equally available to all unless specifically exempted otherwise.

2) We do not want private concessionaires -- they understand only money; they have no ethic
of public service; they are expensive; the very notion of private authorities ruling on public
lands is offensive. I oppose the hiring of any “for profit” company to charge riders and drain
money that should be used for preservation of the trails. 232, 278

Response: The Granger/Thye (G-T) Act authorizes the Forest Service to utilize private
concessionaires to help manage/operate in areas such as the Lefthand OHV Area. Use of
concessionaires requires strict adherence to rigid guidelines. Properly prepared business plans
and/or prospectus for concessionaire management would ensure the operation fair and equitable for all people, ethically operated and would provide the greatest investment back into the area. Success in utilizing this authorization is exemplified by our concessionaire operated campgrounds and day use areas through the Forest-wide GT permit with Thousand Trails, Inc.

3) The position that motorized user displacement will result from charging fees leading to
increased resource damage around the District was expressed in several letters. It was also
expressed that travel management should be done on rest of the District before charging fees
at the Lefthand OHV Area. 3, 14, 16, 64, 239, 269, 278

Response: The decision to charge a fee in this planning effort is specific to the Lefthand OHV Area project area. The Boulder Ranger District will begin addressing travel management concerns outside this project area in an upcoming comprehensive travel management planning effort. For clarification on motorized use displacement, please refer to Displacement Section in this document.

4) Many letters supported charging fees, but only if the money went back into the management
of the OHV Area. Still, other letters objected to the fee, but stated if one was to be charged
that all money collected should go back into the management of the site. Other letters asked
the Forest Service to be accountable for the fees charged through public review to avoid
abuse of fees and that fees be charged on a trial basis first. 8, 9, 10, 14, 20, 22, 25, 32, 44, 57, 61, 65, 66, 68, 71, 75, 76, 77, 79, 82, 83, 84, 85, 87, 88, 90, 91, 92, 94, 96, 98, 99, 100, 101, 102, 103, 104, 105, 106, 108, 110, 112, 114, 115, 117, 120, 122, 123, 125, 129, 133, 135, 137, 139, 140, 142, 146, 147, 148, 150, 151, 152, 156, 158, 160, 161, 163, 165, 167, 173, 174, 176, 178, 179, 181, 181, 184, 185, 190, 192, 193, 194, 195, 197, 198, 200, 204, 206, 207, 209, 212, 215, 217, 218, 219, 220, 222, 225, 227, 228, 230, 231, 236, 237, 238, 245, 246, 248, 251, 263, 265, 267, 276, 278, 286, 288, 295, 299, 301

Response: The Federal Lands Recreation Enhancement Act (REA) authorizes the USDA Forest
Service to retain recreation fee revenues to supplement appropriations and other funding sources to repair, improve, operate, and maintain recreation sites and areas to quality standards and to enhance the delivery of recreation services to quality standards. The Forest Service remains accountable for using fee revenue as identified in its fee business plan which is approved by the Regional Forester. A total of 80 percent of fees collected in Lefthand OHV Area will be returned directly back to the area. The remaining 20 percent will be held by the Regional Office to help support the region-wide fee program and to add to funds intended to supplement special emphasis fee projects such as fee area start up costs for areas like Lefthand. The 80%/20% split is required per Forest Service fee regulations. Please refer to number 8 below for additional business plan information.

5) Although it looks like fees are coming to the National Forests in many places, and I am NOT
entirely opposed to that, I am opposed to fees for this area as a standalone assessment. The
Left Hand motorized route area should NOT set a precedent that would be used to charge fees
for Rampart, Woodland Park, Taylor Park, et al. 232

Response: The decision to charge a fee in this planning effort is specific the Lefthand OHV Area project area. The decision is not intended to set a precedent for making fee related decisions elsewhere on publicly managed land. As required by REA (see above), the process for formally approving the fee ensures consideration of its implementation on a more comprehensive scale.

6) The law authorizing the USFS to charge fees assumes that the fees will be assessed on
physical facilities, e.g. parking lots, camp grounds, and entrance fees for national parks. The
law expressly prohibits entrance fees for the National Forest System. (ref)3(e)(2). The fees
proposed in the EA also appear to violate law also because they would charge visitors to use
public roads. 247, 252, 256, 259, 260, 275, 277, 280, 281, 292, 293, 296, 297, 300

Response: As required by REA, a fee can only be assessed if all criteria authorizing the fee can be met. The Boulder Ranger District will review criteria requirements and special management needs in Lefthand to remain in compliance with REA. The fee will not be assessed to simply gain access. It will more likely be tied to providing specialized services such as designed public roads for rock crawl routes, and staging areas for example.

7) BCNA remains wary of a fee structure if it in anyway leads to privatization of our public
lands or lends user-groups undue leverage in resource management decisions. We will
continue to support increasing federal appropriations for the forest service and other public
land agencies. 28

Response: By law, the Forest Service is required to remain compliant with national policy and related federal regulations. This compliance ensures all stakeholders are afforded an equitable voice in determining effective management of public lands. We appreciate your support and local public land stewardship efforts.

8) pp9 - AltB - fees. If you could give some estimate about the fee structure/system. Any info
about a system or pass. Even if you don't have numbers, a ballpark figure would probably be
welcome. 51 Presenting a conceptual fee model and/or estimating a fee without first preparing a fee business plan would be inappropriate. Developing the fee business plan and justifying the final permit cost requires thoughtful consideration of many factors including that of the OHV users. Prior to implementation, the fee and related business plan would need to be reviewed by the Forest Service Regional Fee Board and, where appropriate, be reviewed by a Recreation Resource Advisory Committee, and approved by the Regional Forester. This process ensures adherence to REA while authorizing a fee that makes sense for managers and users of the area.

9) While fees are appropriate in this case, this should not be an excuse for further reduction in federal support of our public land agencies. 4

Response: The Boulder Ranger District does not anticipate any reduction in appropriated funds by implementing a fee program in Lefthand OHV Area.

10) The travel management plan needs to encompass a business plan for the feasibility of
promoting and maintaining the proposed fee area. With the 50+% of reduced mileage will the
fee area be successful as a self-sustaining area? 66

Response: A business plan will be prepared prior to implementation of fees (refer to number 8
above). This business plan will document special management needs and provide details about the
area, how fees will be used, and what special management/specialized services are to be provided.
The Boulder Ranger District is optimistic that fees will help balance the funding mix to more
adequately meet goals and objectives defined in the EA.

11) I do not agree with the changes that you are about to make and feel you should let the US
tax payers aid in your decisions. Off roader's already pay road taxes on the fuel they use for
off road why can't those funds be used? 126

Response: The tax-paying public has been afforded constant opportunity to provide input throughout the planning process. Based on that input, the Boulder Ranger District intends to explore the use of various alternative source funding mechanisms such as the Federal Recreation Trails Program (gas tax), Colorado Lottery (voluntary) funds and OHV Sticker collections via Colorado State Parks and several other grant sources. These funds are not automatically distributed. Instead, they remain available given specific criteria and considerable competition through a grant process. The District remains confident that diversifying the use of funding mechanisms will promote long-term sustainability of the Lefthand OHV Area.

Comment Topic 7: Fire
1) Your analysis should include an analysis of the likely effects of climate change on fire
danger in this area. As we heat up the planet we dry out the interiorism of continents
increasing the risk of forest fires. This should absolutely be included as part of your analysis. 134

Response: The study of climate change on fire danger in this area is outside the scope of this
analysis because it is not related to the purpose and need as described on page 3 of the EA.

2) The Proposed Action reduces somewhat the risk of fire by eliminating nighttime campfires.
I would also recommend the Proposed Action restrict fire to designated fire rings; All fires
must be in designated fire rings; unless the plan goes to the next step and bans day-time fires
the risk continues. Restricting fires to gas stoves and designated fire rings: this area is just up the Canyon from Boulder and fire management should be a very top priority. Fires should
absolutely be restricted to gas stoves and designated fire rings, with an option open for the
USFS to prohibit all open flames. To do anything other than to restrict fires to gas stoves and
designated fire rings is to completely abdicate your responsibility since fires started by
careless recreationists clearly do not qualify as prescribed burns! 14, 56, 59, 60, 134, 287

Response: Managing Forests to limit the threat of wildfire is a high priority. The Boulder Ranger District agrees that the dusk to dawn closure as proposed in Alternative B, and restricting use of campfire to designated campfire rings as proposed in Alternative D is effective in reducing risk of wildfire associated with escaped campfires. After review of public input and further consideration, restricting campfires to designated fire-rings has been included in the decision. Promoting defensible space by clearing ignitable vegetation around these designated campfire areas will further mitigate the potential for an escaped campfire. In addition, use of campfires and other flame sources (gas stoves, cigarettes, etc.) in dispersed use areas on the National Forest such a Lefthand OHV Area will remain subject to seasonal fire ban regulations.

3) Despite the obvious and significant impacts of forest fires, the EA fails to distinguish the
magnifying impact of the recent forest fires in this area. 247, 252, 259, 275, 277, 281, 292, 293, 297, 300

Response: Various sections of the EA refer to recent wildfire activity (i.e. Botany Section pages 87- 95). Please refer to Fire Section number 2 above for additional information.

Comment Topic 8: Forest Plan and NFMA
1) The proposed action deviates significantly from the LRMP. The LRMP states: "This area is
classified for motorized backcountry use." To conform to the LRMP, the area must be
managed to achieve that objective, rather than close half of the area to dispersed motorized
recreation use. Your alternatives are to select Alternative A, the No Action Alternative, or to
abandon this EA proposal and start over with an EIS (Environmental Impact Statement) to
amend the LRMP. 249, 252, 259, 275, 277, 280, 281, 292, 293, 296, 297, 300

Response: The Lefthand Canyon OHV Area as shown on Forest Plan page 73 has a Management
Area Direction of 4.3: Dispersed Recreation. The area does not have a Management Area Direction
of 3.3: Backcountry Motorized Recreation in the Forest Plan (page 73), therefore, this EA does not deviate from the Forest Plan and does not require a Forest Plan Amendment. Additionally, this EA does meet Forest Plan Direction for this area (Forest Plan page 73), and it also meets the Management Area Direction for 4.3: Dispersed Recreation as demonstrated in the objectives of the Purpose and Need on page 3 if the EA. Management Area Direction for 4.3 Dispersed Recreation states in the Forest Plan that “Ecological values are managed to provide recreational use, but are maintained well within levels necessary to safeguard overall ecological functioning systems” (Forest Plan page 328). Route closures were necessary to meet this direction and to provide a sustainable road and trail network that protects natural resources as described in the Purpose and Need of the EA (EA page 3). The majority of routes proposed for closure in this EA are non-designated routes and are not a part of the official road and trail system of the Forest. In addition, this EA does provide a motorized emphasis in the Lefthand Canyon OHV Area as directed in the Forest Plan (page 72) and as demonstrated in the Objectives under the Purpose and Need on page 3 of the EA. All of the action alternatives go on to enhance motorized recreational opportunities by providing a sustainable road and trail system, staging areas, better signage, a map of the area, and by the addition of either single-track trails or rock crawl routes.

2) The travel management plan is a project under the Arapaho-Roosevelt Land & Resource
Management Plan ("A-R LRMP") and must conform to the management direction or the LRMP
must be amended or revised. Here the EA incorrectly states that the travel management plan
is implementing the LRMP when it is actually adopting a significant amendment without
disclosing to the public that this is occurring. In order to close the area to OHV use, the FS
must amend the management prescription for the plan and inform the public that it is actually
changing the Lefthand Canyon OHV geographical area boundary. When considered in the
context of other issues, the closures require an EIS given the significance of the change and
the relative scarcity of OHV opportunities. 280, 296

Response: The Lefthand Canyon OHV Area Travel Management Plan EA is in compliance with the
1997 Revision of the Land and Resource Management Plan (Forest Plan) and does not require a
Forest Plan amendment. The travel management plan does not close the area to OHV use as cited in this comment. Closing the area to motorized use was considered as an alternative but was dropped from detailed study because it does not meet the Purpose and Need of the project (please see the EA page 15 for more details). In addition, the Lefthand Canyon OHV Area is within the James Creek Geographical Area in the Forest Plan. The area boundary used in this plan is a project boundary and not a geographical area boundary. Therefore, this travel management plan is not changing any geographical area boundaries as described above in this section. This travel management plan emphasizes and enhances motorized recreation in the Lefthand Canyon OHV Area as described in Chapters1 and 2 of the EA. For further discussion please also see the response to comment number 1 above.

3) The Travel Management Strategy for Lefthand, entirely in a 4.3 Management Area, states
that "The existing transportation system is adequate for identified uses and will be mostly
retained in the future, some swaps may occur." "Conversion of ways to the system are likely
(net increase of travel miles)." "New roads and/or trails will most likely be constructed in this planning period." "less than 5 miles will most likely be added to the system in this
management area within the planning period. "No Obliterations will be carried out within this
planning period." 22, 53

Response: This information was taken from the Travel Management Strategy table for the James
Creek Geographic Area on page 74 of the Forest Plan. This table outlines the existing transportation system and provides a strategy for the extent of proposed changes expected to occur during Plan implementation. “Decisions about which roads and trails to keep open or to close will be implemented under formalized travel management plans”. (Forest Plan page 45) However, since the Forest Plan, new routes have been created within the project area and therefore outside of the strategy of this table. The table is a strategy meant to help develop overall travel management plans along with sitespecific analysis (Forest Plan page 45). This formalized Travel Management Plan for the Lefthand Canyon OHV Area takes into account both the table and site-specific analysis (including newly developed routes since the Forest Plan). The proposed system of roads and trails meets Forest Plan direction for the area (Forest Plan page 73). Please also note that the majority of routes identified for closure are not included in the Forest Plan and have been created since the Forest Plan.

4) The plan will move the area into greater compliance with Forest Plan direction by setting
standards and guidelines that discourage motorized routes near waterways and sensitive
resources, establishing route densities and habitat effectiveness standards, and using
ecological parameters to determine how much recreation the forest can handle. 287

Response: This travel management Plan does not set any new standards and guidelines nor does it
establish route densities. To do so would require a Forest Plan amendment. The Forest Service
does agree however that the plan will move the area into greater compliance with Forest Plan
direction.

5) The proposed action would also close the southern part of the planning area between Castle
Gulch Road and Lefthand Canyon Drive. This area is also to be managed for Dispersed
Recreation as an OHV area. Thus the extent of the closure is also not consistent with the
LRMP under which this area was dedicated to OHV use. 280, 296

Response: The Lefthand Canyon OHV Area management direction in the Forest Plan is 4.3
Dispersed Recreation (please see page 328 in the Forest Plan for 4.3 management direction
information). It does not fall under any management direction in the Forest Plan as an “OHV Area” despite the name of the area. This EA is in compliance with the 4.3 management direction in the Forest Plan as discussed in number 1 above in this section. The proposed action does not close the southern portion of the project area. It does however change access to the southern portion of the area. This was required due to legal access issues across private land and safety issues. Please see the Response to Comments section Road and Trail System #3 for more discussion. In addition, the decision adds single-track trails (845.1 U-at, U-av, Uaw, U-ay, and U-bc) in this southern portion of the area.

6) The management direction 1.41 would "minimize recreational impacts on wildlife
populations and ecosystem by discouraging additional recreational use." Thus, the proposed
action to close the area to all motorized recreational use is far more extreme than minimizing
"additional recreational use." The LRMP provides that a core habitat area would remain open
to OHV recreation use. 280, 296

Response: The Lefthand Canyon OHV Area Travel Management Plan EA project area boundary falls
within the 4.3: Dispersed Recreation Management Area Direction. Only a very small portion (approximately 15-20 acres out of the 2544 acre project area) falls in the management direction of 1.41 Core Habitat. The proposal to close this area was not based on the 1.41 designation within the project area boundary, though wildlife would have secondary benefits. Please see the Response to Comments section Fairview Peak #1 for a discussion on the proposed closure to the Fairview Peak area. In addition, the 1.41 management direction does prohibit motorized use as a standard (page 340 of the Forest Plan).

7) The Forest Plan recognizes the need for more motorized opportunity in this area. 232

Response: The Lefthand Canyon OHV Area Travel Management Plan EA is in compliance with the
Forest Plan for this Area. The Forest Plan does recognize the need for motorized opportunity and places a motorized emphasis in the Lefthand Canyon OHV Area, it does not however require “more”. The EA is in compliance by having a motorized emphasis that will provide a long term sustainable road and trail system and it also provides new opportunities such as new single track trails, or rock crawl routes as proposed in the various action alternatives.

8) The EA fails to explain the reason for not retaining or rehabilitating more roads and trails. While closure is an option, it is only one course of action and the LRMP direction requires the FS to consider mitigation through rehabilitation. It does not do so for more than half of the affected roads and trials and this violates NFMA. The sole response is to close the roads and trails to all motorized recreation use. In some cases, the closure is unrelated to any resource issue. This is inconsistent with the LRMP and FEIS and thus violates NFMA. 280, 296

Response: There is no reference in the Geographic Area (pages 71-74), 4.3 Management Area
Direction (page 328), or Forest Wide Direction (pages 1-42) of the Forest Plan that requires the Forest Service to consider mitigation through rehabilitation of roads and trails versus closure, however this was considered by the Interdisciplinary Team during identification of the proposed official road and trail system for the Lefthand Canyon OHV Area. Some of the roads and trails in this EA are identified for rehabilitation or re-reroute in order to retain them in the system. Please refer to the spreadsheet in Appendix B of the EA for specific information on each route. The northern portion of 287.1, 844.1 and U-aw are examples. The reasons for each route closure can also be found in this spreadsheet. Almost all are for resource issues, others are for redundant parallel or braided routes and for private land access issues as well.
To keep any of the routes open that were identified for closure in this travel management plan would not meet the purpose and need of the EA as described on page 3, and it also would not be in compliance with the Forest Plan direction for this area (Forest Plan pages 73 and 328). Forest Plan direction for this area states that: Forest Plan page 73: “Designate an appropriate system of roads and single-track trails to meet management area objectives. This may include relocation of some roads and trails and closures of others to prevent damage to meadows, dry drainages, and riparian area.” Management Direction from Forest Plan page 328 states:
“Ecological values are managed to provide recreational use, but are maintained well within levels necessary to safeguard overall ecological functioning systems”. The proposed road and trail network in this EA meets both directives. Retaining any of the roads and trails identified for closure would not meet these directives, therefore, this EA is consistent with the Forest Plan and NFMA. Please also note that the majority of routes identified for closure are not official Forest Service system routes. Very little of the existing designated road and trail system is identified for closure. Some nonofficial routes are proposed for conversion to official routes and some new construction is also proposed in each action alternative. Please see the table on page 8 of the EA, or the Recreation discussion on pages 25- 44 in Chapter 3 of the EA for actual mileages and further discussion. Therefore, the sole response is not to close the roads and trails to all motorized recreation use, but to provide a sustainable road and trail system that protects natural resources while providing quality recreational experiences within the Lefthand Canyon OHV Area (EA page 3).

9) It is difficult to estimate how much land is now closed to OHV use, but it appears as if one
half to 40% is. This is a significant change in management direction that requires a plan
amendment and full disclosure to the public that the original decision to provide OHV use in
this area is being radically changed. 280, 296

Response: Forest (and recently National) policy requires that motorized vehicles stay on designated routes. Cross-country travel is not permitted, as such, this travel management plan does not close any land to OHV use because that use is already prohibited by a Forest Special Closure Order (please see or request a copy of the Forest Special Closure order which is held at all Forest offices for details).
Also, this travel management plan does not change the management direction for this area and does not require a Plan Amendment. As discussed in number 8 above, this EA is in compliance with Forest Plan direction as stated on pages 73 and 328 for the Lefthand Canyon OHV Area (please see the above comment for further discussion). All route closures and the related percentages to closures are fully disclosed on pages 27, 30, 37, and 41 of the EA. Please also note that the majority of routes identified for closure are not official Forest Service system routes. Very little of the existing Forest Service authorized road and trail system is
identified for closure (refer to EA Appendix B spreadsheet). Recreational use on unofficial or unauthorized routes is also prohibited by the Special Order referred to above. Therefore, since the majority of routes being closed are currently not permitted for use, there is little change to the Forest Plan direction to keep a motorized emphasis in this area. In actuality, this travel management plan enhances OHV use in the area by providing a sustainable road and trail system, staging areas, better signage, a map of the area, and by the addition of either single-track trails or rock crawl routes.

10) This EA cuts the potential for future motorized opportunities because of reduced route
mileages and reduced area in which to build future routes. This may be in violation of NTSA.
232

Response: If this comment is referring to the National Transportation Safety Act, this Travel
Management Plan is not in violation. This is because the EA does not preclude another travel
management plan for the same area at a future date that may address future routes and motorized
opportunities, or the possibility of an amendment to the EA that addresses needs as they arise in the future that were not prevalent at the current writing of this travel management plan. Likewise, this EA does not preclude travel management plans for rest of the District that could provide larger areas for motorized opportunities and increased route mileages. Therefore this EA does not reduce the area for future route construction nor does it cut the potential for future motorized opportunities because of reduced route mileages as described.

11) Your analysis should also include a discussion of what is referred to as the ISD syndrome.
ISD equals interference, suppression and displacement. Council on Environmental Quality
report from the 1980s. It clearly applies in this case. The OHV community has so severely
damaged these areas that they have not just interfered with or suppressed other recreation
activities they have effectively displaced most other recreational uses. This is a very serious
situation and should have been more thoroughly addressed in the EA. 134

Response: The displacement of other recreation users from the area was addressed in the Affected Environment for Recreation on page 26 of the EA. The EA does not prohibit non-motorized use or other recreational uses from the area, but the Forest Plan does give this area a motorized emphasis in which motorized travel will be featured on 4 wheeldrive routes and single track trails (see Forest Plan pages 72-73 for more information). Because this area is a motorized area featuring motorized recreation, the Forest Service expects displacement of
non-motorized recreationists to other areas of the District because of differing recreational
experiences being sought by both groups. Though non-motorized use in this motorized area is very low, some non-motorized use does occur in the area despite the motorized emphasis. It is unknown if displacement of non-motorized users is caused by the damage in the area from motorized use, or if it is due to differing desired recreational experiences as noted earlier. Also, because the area is to be managed as a motorized area by Forest Plan direction, a study as the one proposed in this comment would not meet the purpose and need of the plan (EA page 3)
The EA does acknowledge and address the damage caused by motorized recreation (see EA
Chapters 1 and 3) in this area and proposes to mitigate and repair this damage as described in the Purpose and Need Objectives (EA page 3-4) and in the Monitoring and Mitigation section on pages 12-15 of the EA.

Comment Topic 9: Impacts
1) Some commenters stated that reducing the opportunities or access points to the Lefthand
Canyon OHV Area would concentrate use into a smaller area. This would increase the impacts
and congestion because greater use is now concentrated on a smaller area. This has been left
out of the EA. 55, 97,183, 232, 258, 261, 280, 296

Response: The Boulder Ranger District acknowledges that the action alternatives concentrate use on fewer roads and that this may result in some crowding on higher use days within the OHV Area. The Boulder Ranger District does not agree however that this will increase impacts in the area. By requiring vehicles to stay on route, providing a sustainable road and trail system as identified in all of the action alternatives, and providing signage and vehicle barriers to keep riders on route where needed, impacts in the area will be deceased. The decrease in impacts will result from riders no longer driving off routes and causing resource damage, and by providing a road and trail system that the Forest Service can manage and maintain.

2) While the differences in miles of routes being closed and opened are not significant among
the alternatives, the resulting reduction in impacts in the Proposed Action is significant. EA
states that any fewer closures would fail to meet the plan's objective of designating a system
that is sustainable and manageable (p l31) within existing financial, managerial and ecological
constraints. 287

Response: We agree with you comment. For specific route closure information, please see the
Alternative maps and spreadsheet in Appendix B of the EA. Chapter 3 of the EA also provides more detail regarding impacts by alternative.

3) Unless you add the improvements outlined below, the plan will be inadequate and may be
subject to appeal for failure to properly protect soil resources and to manage fire risks in a
very sensitive area. Forest Service needs to go a bit further in order to adequately protect the resources that belong to all Americans -- not just a few who want to degrade them with
destructive motorized uses.
i) Eliminating the rock crawling in this area.
ii) Reroute Northern portion of Castle Gulch
iii) Relocating the Northern Portion of U-aw
iv) Restricting fires to gas stoves and designated fire rings
(paraphrased from letter 134)

Response: The EA does properly protect soil resources and manage for fire risks. It does this by providing a sustainable road and trail network while protecting natural resources, eliminating unclassified routes, and by restoring the impacts caused by motorized use (EA page 3). Each action alternative also identifies management and road and trail actions and monitoring and mitigation measures that also protect the resources mentioned above. Further discussion relating to these two resource areas can also be found in Chapter 3 of the EA under Recreation (for fire) and under Water, Soil, and Fish for a discussion on soil resources. With regard to the specific actions above:
i) Eliminating the rock crawling in this area: Please see the response to comment number 1 in the Rock Crawl section of this document.
ii) Reroute Northern portion of Castle Gulch: This is proposed in Alternatives C and D. This is
included in the decision provided the Forest Service can obtain a public easement across private land to this portion of the route.
iii) Relocating the Northern Portion of U-aw: The single-track addition of U-aw is included in the decision, the northern portion of U-aw will be re-routed to avoid resource damage currently occurring on that route as described in the spreadsheet on page B-7 in Appendix B of the EA.
iv) Restricting fires to gas stoves and designated fire rings: Please see the response to comment number 2 in the Recreation section of this document.

4) It is frustrating as a user that the responsible users have been trying to work with the Forest Service for years through adopt-a-road programs and have been begging the Forest Service to manage the area, but the USFS approach seems to be to ignore the issues and encourage misuse until the situation gets so bad that they have an excuse to close it down. I want to see the USFS begin tackling these issues proactively, start by assessing the impact your actions in Lefthand will have on the rest of your District. 244

Response: The Boulder Ranger District has not ignored the issues within the Lefthand Canyon OHV
Area and has worked with various motorized users clubs and environmental groups to help mitigate motorized recreation impacts in the area as resources have allowed. This plan also demonstrates that the Boulder Ranger District has not ignored, but has acknowledged the issues by developing this plan. The District is not proposing to close the area, but to manage it as described in the EA. Please see the Displacement section of the Response to Comments for further discussion on impacts to rest of the District.

5) There must be sufficient discussion of the major issues to show that the agency has taken a
'hard look' at the environmental effects. The EA falls short of this mandate since it omits
significant environmental effects of concentrating OHV use on less than half of the existing
trails, fails to consider a range of reasonable alternatives, since all of the alternatives would close about half of the existing trails, and omits any consideration of whether the USFS has jurisdiction over the subject roads. Finally, there is no adequate discussion of the reasons to close both Fairview Peak and the additional "core wildlife area" to motorized recreation use, when there are no data offered to support the closure. 280, 296

Response: The EA does take a “hard look” at the major issues and the environmental affects of those issues. The issues as defined through both specialist input and public input can be found on page 5 of the EA. The environmental discussion for each resource area by alternative can be found in Chapter 3 (pages 25 to 103) that addresses the issues. See also Environmental Impact Comparisons of Alternatives on pages 16-23 of the EA for a comparison of alternatives by issue. Regarding:
a) Concentrating OHV use on less than half of the existing trails: Please see the response to number 1 above in this section of Response to Comments.
b) A range of reasonable alternatives: The EA does offer a reasonable range of alternatives in order to meet the Purpose and Need of the Plan. Road and trail system mileage is only one component of the alternatives. There is a reasonable range of management actions and road and trail actions between the alternatives that were identified to meet the Purpose and Need of the Plan in addition to the mileage of the system. The mileage of open routes was maximized in each action alternative while still meeting the objective of providing a sustainable road and trail system as described in the Purpose and Need on page 3 of the EA. Any fewer closures would fail to meet the plan's objective of designating a system that is sustainable and manageable. c) USFS jurisdiction over the subject roads: The Forest Service has jurisdiction over all of the subject roads within the project area boundary that are not county roads or roads that cross private land. The roads that are in the project area on National Forest System public lands with a Forest Service road number in the Forest’s roads database are roads that are under Forest Service jurisdiction. The exception to this are the unauthorized and/or user created routes that have no Forest Service road number and are not in the Forest’s roads database. These still fall under Forest Service jurisdiction because they are on National Forest System public lands. Therefore, there is no ambiguity or issue concerning Forest Service jurisdiction over the subject roads. Please also see the RS2477 section in the Response to Comments for more discussion.
d) Fairview Peak closure: Please see the response to comments under the Fairview Peak section of this document.

6) I recommend that the USFS begins to create a forest or even state wide initiative to account
for OHV impacts already present and to develop a plan to deal with OHV displacement and
impacts on a project-to-project basis as soon as funding and time allow. The cumulative
impacts of one project combined with existing impacts and future impacts from new projects
need to be addressed. This is no small issue. Front range OHV purchases have increased
astronomically in the last decade and show no signs of slowing. The USFS is aware of this I
know. As Forest Chief Dale Bosworth said. Due to its design the trials bike can be a potent
degrader of the Forest environment. 269

Response: Taking a Forest or State wide initiative is out of the scope of this project because this analysis is on a project level and not a Forest level scale. The Forest Service agrees however that motorized impacts across Forest units must be accounted for. The Forest Service has just recently (four months prior to this writing) implemented a national OHV rule that will help with this effort.

7) Despite its current condition, Lefthand Canyon has actually protected the county's forest
roads and trails from overuse. Because of its location and variety of terrain, just about
everybody uses that area. This keeps traffic down on the county's other trails which actually
reduces the overall impact. 61

Response: Despite the high use at the Lefthand Canyon OHV Area, the rest of the District is still showing signs of over-use and mis-use of off-highway vehicles. Some example areas include Yankee Doodle Lake, Bunce School Road, Johnny Park, Coney Flats and several others. This EA does not address county roads as they are out of Forest Service Jurisdiction.

8) Appdx A-4 - box 60 - I don't think the response box is a fair reflection (or perhaps is untrue). If you impact how traffic works or moves you should acknowledge that you are responsible for the increase. Are you not in consultation w/CDOT to build a turn/exit lane for the primary parking lot because of the safety situation created by the use? The vehicle numbers are no different. It could be included in the Environmental Justice portion? But I think you could also just acknowledge that you are aware of your impacts (and that there are impacts beyond the boundaries of your area). 51

Response: This Plan may or may not increase traffic along Old Stage Road and Lefthand Canyon
Drive, which are both outside of Forest Service jurisdiction, and outside the project area boundary and therefore not analyzed as a part of this project. The Forest Service is not in consultation with CDOT to build a turn/exit lane for the OHV Area. The safety concern present at the entrance of the OHV area along CR 94 (Lefthand Canyon Drive) is related to people parking with trailers on the shoulder of CR94 and not having a safe place to stage. The plan addresses this safety concern by providing parking/staging areas that are located off of CR94 (please see the maps in Appendix B for parking area locations). No other safety concerns have been reported or observed regarding ingress and egress from the OHV Area. If this should change in the future, then the Forest Service will address the issue.

Comment Topic 10: Jurisdiction
1) Obtain the needed easements with the land owners to continue the public motorized access
throughout the area including the Overland Fire Area and Fairview Peak; secure easements or
re-route roads around private lands. 22, 53, 66, , 232

Response: The Forest Service will pursue the acquisition of adequate rights-of-ways. Forest Service Policy is to “Acquire rights-of-way with the least impact on private lands crossed…” (Forest Service Manual 5460.3, #7). If the Forest Service makes a decision to eliminate or not include a road as a Forest Service Road, then acquiring a right-of-way across the private land would not be the least impacting to the private land.

2) In the final decision, any roads or trails that are not open to the public that cross private lands should be obliterated from the private property onto public lands. There should be no private access to public lands. Any private landowner that owns land that borders public land and does not provide public access to that public land should also be denied access to that public land under the principles of fairness and reciprocity. 22, 65

Response: Unless the Forest Service has an authorization from the private land owner, the Forest Service does not have jurisdiction or authority to do work on private property. In this Environmental Analysis, the Forest Service has proposed to obliterate roads on National Forest System land which are not needed in relation to the Lefthand Off-Highway Vehicle Area.
If a private land owner needs access to private property, then the private land owner is required to submit an application for and be granted an authorization prior to performing any maintenance to a Forest Service Road. Use of a road not included as a Forest Service Road falls under the same regulations as driving off of a designated road.

3) Our property is continually trespassed by OHVs and this Proposed Action will mitigate
these trespassers; having a place for these activities probably reduces the likelihood of people trespassing on other local adjoining land. 59, 243

Response: Thank you for your comment.

4) In the final decision, any roads or trails that are not open to the public that cross private lands should be obliterated from the private property onto public lands. There should be no private access to public lands, private property owners must access public lands the same
way the public access public lands. The only exception would be private property that would
need access across public lands. 57

Response: Unless the Forest Service has an authorization from the private land owner, the Forest Service does not have jurisdiction or authority to do work on private property. In this Environmental Analysis, the Forest Service has proposed to obliterate roads on National Forest System land which are not needed in relation to the Lefthand Off-Highway Vehicle Area. If a private land owner needs access to private property, then the private land owner is required to
submit an application for and be granted an authorization prior to performing any maintenance to a Forest Service Road. Use of a road not included as a Forest Service Road falls under the same regulations as driving off of a designated road.

5) Roads and trails through private lands should be rerouted. All of the private lands are old
mining claims. The private land is narrow and may impact a small section of the road. To lose
miles of road or trail access due to a 100-foot action is not justifiable. Reroute the road or trail. 57

Response: The proposed action and decision states to “close or relocate roads traveling through
private land if public use easements can not be obtained for them (Decision Notice and Finding of No Significant Impact page 4). Please note however that rerouting a road around private land is not always economically or environmentally feasible. For example, rerouting the road may require additional stream crossings or traversing steep hillsides making management extremely difficult. Where feasible however, routes will be rerouted around private land.

6) The roads running through the private parcels to the National Forest are also public roads
and their use is not trespass. Nor is there any need for the USFS to secure "legal access"
since these are already public roads. In addition, the discussion on page 32 of the EA is
inaccurate. The Proposed Action would close part of the Castle Gulch Road (FR287.1) to all
but USFS administrative use. The Castle Gulch Road is a public road and the USFS cannot
"close it." The road already provides access through and to private parcels and federal lands.
Thus the statements throughout the EA regarding the need to acquire legal access are also
inaccurate. Public access is already legal. The Proposed Action in the EA needs to be revised
to reflect the public status of the road and other similar roads, the fact that there is legal
access, and to delete references to trespass by OHV users. Similarly, the Proposed Action
cannot close these and other public road segments. 280, 296

Response: The Boulder Ranger District does not have information supporting the claim that the roads addressed in the Lefthand Off-Highway Vehicle area are public roads. According to information available to the Boulder Ranger District, all roads on National Forest System land addressed in this plan are under the jurisdiction and management of the Forest Service.
The Forest Service does not have jurisdiction or authority for roads across private property without some type of authorization. The United States holds one easement across property owned by City of Boulder from County Road 94 for first portion of Forest Service Road 286.1. There are no other known authorizations to the United States within the planning area.

Comment Topic 11: Law Enforcement
1) Law enforcement should be specifically included; all law enforcement required to assure
compliance should be funded from user fees charged to OHV users to ensure adequate
funding; Use should only be allowed in areas that can be adequately patrolled. We are also
open to exploring possible joint enforcement strategies, to supplement the limited
enforcement staffing available to the Forest Service. More supervision and penalties for those
that abuse this area would suffice. Establishing a delineated system is excellent.
Enforcement, especially initially, is essential. 4, 48, 50, 238, 280, 296

Response: The Boulder Ranger District appreciates local support and is open to ideas for fine
adjustment (collateral penalties) and creative funding necessary to provide effective law enforcement in the Lefthand OHV Area. Law enforcement gives users a sense of active, on-site management of the area and is essential for promoting regulatory compliance. Official regulatory compliance is handled by National Forest Law Enforcement Officers, National Forest Protection Officers, Colorado Division of Wildlife and assistance from Boulder County Sheriff’s Department. Since these personnel are also patrolling other local areas, they rely heavily on support from other National Forest employees and National Forest volunteers that provide education and agency presence, even in the most remote portions of the Lefthand OHV Area. A mix of appropriated funds, fees and alternative source funding will be used to support law enforcement related activities in the future.

2) We absolutely do not want significantly increased law enforcement, especially not paid for
by user fees. That is in effect charging us money in order to threaten us, control us, treat us
as if we were confined to a reservation and subject to arbitrary manipulation of our lives -- this is NOT freedom. There is some need for these characteristics of governing in order to prevent establishment of private territorial acquisition and defense on public lands, BUT very little need. A proper use of enforcement would be to put enforcement officers in the shooting areas at 3:00 am to catch the local residents dumping trash instead of paying to put it in the legal dump and then blaming shooters for the mess. 232

Response: Law enforcement is one of many tools used to effectively manage National Forests as mandated. Observations indicate that consistent agency presence and a proactive balance of education and enforcement effectively addresses management goals and objectives resulting in more effective regulatory compliance. Additional law enforcement will be considered as funding allows and as deemed necessary. Please refer to number 1 above.
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Comment Topic 12: Monitoring
1) Effectiveness of your actions, road closures and limiting OHV access must be documented
by a planned monitoring schedule as well as providing law enforcement. 60

Response: Effectiveness monitoring will be conducted to determine whether design criteria,
mitigation measures, and watershed conservation practices are effective in protecting soil, water, and aquatic resources. All actions pertaining to classified and inventoried unclassified roads/trails will be documented in the National Forest Roads Atlas (INFRA) upon implementation. Road/Trail Management Objectives will also be updated to ensure a quality standard of monitoring and maintenance continues as prescribed. While design criteria and key mitigation standards are to be incorporated into project design and implemented over time, most measures will be applied as necessary to address mitigation needs identified during effectiveness monitoring. For additional information please refer to the EA Mitigation and Monitoring Section 2.2, pages 12-15 and the Mitigation and Project Design and Monitoring Sections in the Decision. Please refer to Law Enforcement Section number 1 and 2 for response to request for additional law enforcement.

2) I also think some closures, like routes that are in creeks, are necessary and they need to be monitored. Monitoring is critical for enforcement and I think that it is the first thing that gets dropped when there is not enough budget. 64

Response: The District is optimistic that multiple program funding and the implementation of a fee program will support ongoing monitoring, critical implementation of mitigation measures and related law enforcement. For additional information please refer to number 1 above.

3) The use needs to be contained within the designated area. There needs to be adequate
monitoring to restrict the spread of this intensive use and to make sure that the goals and
objectives of the plan are adhered to. 54

Response: Roads and trails identified for motorized use in the decision will act as the transportation system within the Lefthand OHV Area. Motorized use off of these routes will be prohibited. Various design criteria and mitigation measures are identified in the decision that will be implemented to encourage legal use of the transportation system. Effectiveness monitoring and law enforcement will help achieve related goals and objectives identified in the EA/Decision.

Comment Topic 13: NEPA
1) Many letters received stated that there was too short of notice of the EA to provide
comments within the 30-day comment period. 74, 81, 82, 86, 95, 126, 131, 148, 151, 160, 162,
183, 184, 190, 195, 198, 200, 205, 213, 223, 224, 226, 232, 257, 260

Response: The EA was mailed out and made available in the Boulder Ranger District Office the day the legal notice was released in the Boulder Daily Camera announcing the 30-day comment period. NEPA requires that there be a 30-day comment period within the EA. Having received 282 comment letters within the 30-day comment period suggests there was adequate notice.

2) Some commenters said that the requests for additional time have been rejected citing 36
CFR215.5(b)(2)(iv). This rule is not consistent with the Council on Environmental Quality
(CEQ) rules, which provide that all comment period may be extended. Many letters requested
an extension of the comment period. 45, 75, 81, 122, 127, 142, 152, 156, 182, 204, 240, 261, 280, 296

Response: The request to extend the timeline was denied because the responsible official felt that the 282 comment letters received within the 30-day comment period was an adequate representative sample of letters on which to review the environmental document.

3) Several comments letters stated an objection to the short comment period. 72, 76, 77, 83,
84, 85, 87, 88, 91, 93, 96, 97, 98, 99, 100, 103, 105, 108, 110, 116, 117, 118, 121, 123, 129, 135, 137, 138, 139, 140, 147, 146, 149, 150, 151, 154, 158, 161, 164, 166, 175, 176, 178, 181, 185, 186, 189, 191, 192, 202, 203, 206, 207, 209, 215, 216, 217, 219, 222, 225, 235, 237, 245, 246, 251, 263, 265, 267, 270, 276, 279, 280, 282, 286, 288, 295, 296

Response: NEPA requires that there be a 30-day comment period within any EA. This comment
period took place from August 2 (date of legal notice publication in the Boulder Daily Camera) to September 1, 2005, and therefore meets this requirement.

4) Some commenters wrote that COHVCO (Colorado Off-Highway Vehicle Coalition) was
purposely left out of the process for this EA, or did not receive the materials necessary to
provide comments as stated in the comments below.
95% of the people who attended the 8/17/05 COHVCO meeting DID NOT receive their
EA. 44 There is a clear inference COHVCO members and other off-road vehicle advocates were
purged from the USFS mailing lists. 280, 296
COHVCO and its officers did not receive individual notice of the EA and learned of the
EA and the September 2, 2002 deadline in mid-August. This occurred even though
several COHVCO members have participated in coordination sessions with the USFS.
Those active individuals still were not informed of the EA's availability until August 15,
2005, more than two weeks into the 30-day comment period. 180, 280, 296

Response: The public involvement process for this project is described on pages 4 to 5 in the EA. To expand on that discussion, there were three mailings and two sets of public meetings before the EA was released for the 30-day comment period. These are as follows:
i) The first mailing and set of public meetings were to determine the issues surrounding the Lefthand Canyon OHV Area. The letter (handout at the public meetings) asked that if you wanted to be removed from the mailing list or if you knew someone who you thought would like to me added to the mailing list, to indicate so on the enclosed form and return it to the Boulder Ranger District.
ii) The second mailing and set of public meetings was to determine possible solutions to the issues. This letter (handout at the public meetings) stated that if you did not provide comments, you would be dropped from the mailing list. The enclosed form with the letter (handout at the meeting) had a box to check if you had no comments but wished to remain on the mailing list that could be mailed back to the Boulder Ranger District (form was already addressed and ready for mailing).
iii) The third mailing, no public meetings, was the scoping period for the Proposed Action. As with the second mailing, the third mailing stated that if you did not provide comments, you would be dropped from the mailing list. The enclosed form with the letter again had a box to check if you had no comments but wished to remain on the mailing list and was already addressed to the Boulder Range District for easy mailing.
iv) The fourth mailing was the EA when it was released for the 30-day comment period.
COHVCO was on the first, second, and third mailing lists, but not on the fourth (please see project record for mailing lists). This indicates that COHVCO did not provide comments to the Proposed Action, did not telephone with comments or ask to be kept on the mailing list, and did not return the form stating that they had no comments but wished to remain on the mailing list. As a result, COHVCO was dropped from the mailing list as explained in the letter. Therefore, the Forest Service did not intentionally exclude COHVCO from this project as they were on the first three mailing lists and dropped from the fourth at their own discretion.

5) Some commenters wrote statements regarding the public involvement and notice
requirements of NEPA. These are: The intent of closure must be presented clearly, concisely, and in an easy to understand format. The agency must inform the public by notices, contact to known user groups, and one year comment period with regional input carrying double weight
to out of region comment. 170 Individual notice is also required by the USFS Handbook on NEPA procedures, FSH 1909.15. 280, 296
Public notice is posting in regional papers with the chance for input is required. 170
Although the stated comment deadline was August 31, this does not comply with the
legally required 30-day period from the date of publication in the Boulder Daily Camera,
which was August 2nd, 2005. The correct deadline is September 1, 2005, and all
comments received by close of business on September 1, such as this one, must be
accepted. 260

Response: The public involvement process used for this environmental assessment is in compliance with NEPA regulations. Please see Public Involvement beginning on page 4 of the EA for a description of this process. Also, see the response to number 5 above for a brief description of the mailings. The 30-day comment period for the EA took place from August 2 (date of legal notice publication in the Boulder Daily Camera, the official newspaper of record for projects on the Boulder Ranger District) to September 1, 2005. All comments received on the EA are included in the project record. All mailings, mailing lists, responses received from the mailings, and the notes from the public meetings are also available in the project record. Motorized groups are included in the mailing lists as well as other groups and individuals.
In addition, the Forest Service does believe that the intent of closure was presented clearly concisely in an easy to understand format as demonstrated on the spreadsheet in Appendix B (page Appendix B-5 to Appendix B-11) of the EA, and that the public was informed by notices and that contacts were made to known users groups. Please see the Public Involvement section of the EA (EA page) and the project record for actual notices, public meeting details, and specific mailing lists. There are no regulations requiring the agency to provide a one year comment period with regional input carrying double weight. The regulations require a 30 day comment period and do not favor any area over others concerning input to projects.

6) Many commenters said that the Forest Service deliberately did not involve the motorized
community or failed to inform the motorized community. The specific comments were:
The Boulder RD failed to inform most of the interested motorized users of the release of
this EA. We feel that the failure to inform and the refusal to extend are deliberate and
intended to dilute our efforts to participate in this, which contravenes the NEPA . 232
Even though I had provided comments on the scoping document, which should have
assured I would be on the EA mailing list. I did not receive my copy of the EA until I
called the Boulder RD on August 19th and received the mailed copy of the EA on the
23rd. 240
A considerable number of MOTORIZED people, who had provided scoping comments did not receive their copy until they made a phone call to the Boulder RD. This, to me, seems an underhanded way to skew the comments of the EA away from the motorized community. 240
Most of the trails are going to be closed and you didn't even send out the notice as you
should have to the motorized community. 285 It seems like the Forest Service was trying to get the decision passed without the proper input form the users of the area. 271

Response: The public involvement process is described on pages 4-5 in the EA. Please also see the response to comment number 4 above in this section for a description of the mailing procedures used. Every effort was made not to exclude anyone who had provided comments on the proposed action to this project. With specific reference to letter 240, a copy of the EA was mailed to the address provided on the comment letter, however the respondent failed to notify the Forest Service that they needed the EA to be mailed to different address other than the one provided on the response. A copy of the EA was mailed immediately after the respondent phoned in with the new address. Again, every effort was made to include everyone on the mailing list who had provided comments during scoping of the proposed action for this project, including the motorized community. This can be demonstrated by comparing the comments letters received on the proposed action to the mailing list used for the EA (all available in the project record). This can also be demonstrated by the comments received. There was no skewing of the comments away from the motorized community as over 90% of the comments received supported motorized use.
Several efforts were made to ensure that the motorized community was involved in this project at the onset. A record of clubs was created from past contacts and used in the first mailing list in addition to an informational flyer on the project that was handed out at the Lefthand Canyon OHV Area for several weeks before pubic involvement began. This informational flyer also had a place to sign-up for the mailing list that could be returned to the Boulder Ranger District. In addition, local papers also provided coverage on the project, some articles also included contact information for persons wanting to be involved (please see project file for articles). The motorized community also shared information within itself on a local Colorado 4X4 bulletin board on the internet (examples in project record). Given the request for input to the project via public letters, public mailings, and the outreach described in the paragraph above, the Forest Service believes that every effort was made to provide the users of
the Lefthand Canyon OHV Area a chance to provide input to the project. Therefore, the Forest
Service disagrees with the statement that the agency is trying to get a decision passed without proper input from the users.

7) Several commenters said that the EA was not mailed out in a timely manner to interested
parties in order to provide input to the project and that this way have been purposely done to
limit public involvement by the user groups. These specific comments are as follows:
I have looked at the documents under the EA, although it appears that they were not
mailed to all interested parties in a timely manner. 298
I understand that the USFS left until the last minute to inform the off-road vehicle
community about changes to this riding area. I find that unacceptable and probably
illegal. 136
It appears you may have not followed required notice time or the timely sending of
material to those who have the interest and right in making comments. It appears you
may have inadvertently ignored the motorized users who are interested in making
comments on this issue/action. 196
We would like to state that there appears to have been an attempt by the USFS to limit
public input on this proposal by delaying notification of interested parties and groups.
Overlooking or delaying notification to well-known organizations that represent OHV
users on a proposal that primarily and directly affects their members is unacceptable.
260
The USFS provided inadequate notice by publicizing the EA but failing to mail the EA to
interested parties. The first COHVCO member to receive a copy got his on August 15,
2005 and the COHVCO board received a copy on August 17, 2005, less than 2 weeks
before the comments were due. 252, 259, 275, 281, 292, 293, 297, 300

Response: Please see the response to comments number 1 and 4 above in this section.

8) Communication from the Boulder side is almost non existent. 42

Response: Communication with the pubic was given priority throughout the process of developing this Environmental Assessment (EA). The public was invited to help develop the issues, solutions, and provide input to the EA as described in the Public Involvement section of the EA (Chapter 1 page 4). This was accomplished through public mailings and meetings held as the project progressed. Meeting announcements, mailing lists, and the notes from these mailings and meetings can also be found in the Public Involvement section available in the project record.

9) The EA appears to have no addresses listed, US mail or email, to which the public may send
their comments on this EA. I believe this may be a violation of NEPA and it is certainly an
obfuscatory omission. 232

Response: Please notice that a contact name, address, phone number, and website address are
provided on the front cover page of the EA on the bottom right under “For Information Contact:”
Contact information was also provided in all public letters, handouts at public meetings, and in the legal notice posted in the Boulder Daily Camera on August 2, 2005.

10) A review on land like this should have been very public and shared with the recreationists
from day one, with a long and careful acquisition of comments from ALL users. 218

Response: Please see the response to comment number 8 in this section of comments. Additionally, input was solicited from recreationists, private landowners, environmentalists, and any parties interested in this project. Please see the Public Involvement section of the EA (EA pages ) for more details.

11) If a region is not clearly and publicly notified of proposed closures with a minimum of 180
days it is criminal on the part of the custodial agency and lawsuits should be filed. 170

Response: On a project level EA such as the Lefthand Canyon OHV Area Travel Management EA,
the National Environmental Policy Act required that notification of the EA be published in the
newspaper of record and that the project have a 30-day comment period. Both of these requirements were met. The notification of the EA as posted in the legal notices of the Boulder Daily Camera (the official newspaper of record for projects on the Boulder Ranger District) on August 2, 2005 making the 30-day comment period August 2 to September 1, 2005. This is in addition to public involvement throughout the process as described in comment number 8 above.

12) This EA regards many of the comments made in scoping to be irrelevant, when in fact
some of them are quite relevant. Number 4 non-significant comment states that Carnage
Canyon should be managed, not closed. The EA response is that keeping Carnage Canyon
open would violate certain laws and the Forest Plan. This issue is NOT insignificant and this EA fails to uphold the purpose of an EA by failing to attend to this issue. Number 55 nonsignificant comment states that Castle Gulch entry points to the system should be left open
for emergency access. The EA responds that regardless of designation, "emergency access is
granted to all emergency response units". This fails to account for the need of users to extract themselves from the system in case of sickness, injury, damaged vehicle or an emergency
outside of the area requiring their immediate presence; AND user vehicles are not emergency
response units. Number 63 non-significant issue states that USFS routes continuing across
private land should not be closed because of possible trespass. The response is that use
across private land is allowed where the USFS can legally grant access. This may be moot
since most of the routes that cross mining claims may be found to be public ways under
RS2477, and be open to the public at all times. Numbers 65, 70 and 72 also raise significant
issues. 232

Response: The following addresses the issues raised above:
a) Number 4, Carnage should be managed not closed: This is a non-significant issue because
keeping Carnage (286.1A) open would not meet compliance standards as outlined in the Forest Plan and the Clean Water Act, therefore, regulations dictate the closure of this route. In addition, keeping Carnage open would not meet the Purpose and Need of this project (EA page 3) because it is an unsustainable route and could not be included in a sustainable road and trail system, and keeping the route open does not protect natural resources. In addition, it also states that all routes within creeks will be closed under Action Items Common to All Action Alternatives (B, C, D) in the EA (page 11), and Carnage is located in a creek. The closure of Carnage (286.1A) was also considered in Alternative A, the No Action Alternative.
b) Castle Gulch entry points to the system should be left open for emergency access: Please see the response to comment number 3 under the Road and Trail section of this document.
c) USFS routes continuing across private land should not be closed because of possible trespass: This may be moot since most of the routes that cross mining claims may be found to be public ways under RS2477, and be open to the public at all times: Please see the response to comments under the RS2477 section of this document.
d) Number 65, Route closures should only happen only after all other options have been exhausted: This was considered non-significant because it is a statement of opinion. In addition, this does not meet the Purpose and Need of this project (EA page 3) because some routes must be closed in order to provide a sustainable road and trail system, and protect natural resources.
e) Number 70, Create a system using counters and cameras to manage use: This suggestion does
meet the purpose and need of the project though it can be used as a monitoring tool. As stated in Appendix A (page A-6), this was a suggestion that would be analyzed further for adaptive
management of the area. This will be kept open as a consideration as we monitor the Lefthand
Canyon OHV Area. Use of counters has been problematic in the past as the ones installed have
been stolen. The Boulder Ranger District does have plans to install under-ground counters in the near future. The use of cameras raises legal issues that may prohibit their use.
f) Number 72, There is a concern about gaining access through private in Castle Gulch, as County Road 94 will not allow motorized use linking the Lefthand Canyon OHV Area to James Canyon: This remains a non-significant issue because the EA does not provide access to James Canyon even if access through Castle Gulch is obtained. The alternative to provide motorized connectors to other areas outside of the Lefthand Canyon OHV Area was dropped from study because it does not meet the Purpose and Need (EA page 15).
13) Our objection to the other alternatives include, but are not limited to inadequate notice of publication of the EA, the reduction of OHV opportunity in all other alternatives, jurisdictional issues on established routes, and we are opposed to user fees on public land that is currently being managed with the help of money collected from OHV users. 266
Response: For:
a) Inadequate notice of publication of the EA: Please see the response to comment number 1 in this section (NEPA)
b) Reduction of OHV opportunity in all other alternatives: Please see the response to comment
number 4 under the Recreation section of this document.
c) Jurisdictional issues on established routes: Please see the response to comment number 5 (c)
under the Impacts section of this document.
d) User fees on public land currently being managed with the help of money collected from OHV
users: Please see the response to comment number 1 under the Fees section of this document.

14) Some commenters stated that they strongly oppose the preferred alternative and
requested that the Forest Service withdraw the Draft EA, revise the Proposed Action to retain
roads and trails identified as necessary to meet recreation demand with mitigation, and to put
it out again for public comment with procedures in place to ensure that interested members of
the public are informed of the document and the comment deadline. Other letters requested
that the EA be restarted and that all existing roads and trails which are available for use by
motorized recreationists be adequately identified as the baseline alternative, or cancel the EA
and start over with less restrictive options and more public input. One commenter also noted
that the conversion of half of it to "backcountry or non-motorized recreation is a significant
change in recreation outputs. Thus, the EA should fully disclose the fact that it is revising the RMP and limiting future recreation opportunities.” Other letters said to abandon the EA and
start over with an EIS. 111, 247, 274, 280, 296
The EA should be withdrawn and revised to include a preferred alternative that retains
the entire planning area for OHV use, adopts a number of mitigation projects to address
identified erosion issues, and keeps a sufficient number of single track routes open to
reduce or minimize possible congestion and conflicts between motorcycles and 4-
wheel users. 280, 296

Response: Withdrawing the EA, starting over and revising the preferred alternative to retain roads and trails is not needed due to public involvement, the analysis, and the No Action Alternative. The Proposed (preferred) Alternative and all action alternatives proposed in this plan do meet the Purpose and Need and were developed through input from the public (See Public Involvement on page 4 of the EA). The Proposed Alternative keeps the greatest amount of mileage open to motorized recreationists while providing a sustainable road and trail network and protecting natural resources as outlined in the Purpose and Objects on page 3 of the EA. Retaining any more roads or trails would not meet these objectives. In addition, Mitigation is identified in the Plan (page 12, Mitigation and Monitoring Common to all Action Alternatives), and identified for critical routes to maintain the congruency of the road and trail system (the north end of 287.1 for example). The EA is not changing designations within the project area to “backcountry or non-motorized recreation”, therefore the project is not revising the Forest Plan as suggested above. In addition, Alternative A was analyzed and could have been selected, retaining all of the routes in the Lefthand Canyon OHV Area without a new analysis. This alternative was not selected however because it does not meet the purpose and need of the project (please see the Decision Notice and Finding of No Significant Impact page 9).

15) One comment letter said that the EA needs to be fair to all of those involved and not biased toward a select few who think that their way of seeing and enjoying the land is the only way. In addition a commenter also stated that it is in the worst interests of everyone for the USFS to believe that it should dictate what is in the best interests of Americans. 232, 258

Response: This project has been developed largely through public involvement and specialist team input as the project progressed. The initial stage of the project began with scoping and public meetings and Interdisciplinary Team (a resource specialist team) meetings to determine the issues concerning the Lefthand Canyon OHV Area. Once those were established, the process was repeated to identify possible solutions to the issues. That was used to develop the Proposed Action that was mailed out for a 30-day public comment period. The alternatives were developed using the input received on the Proposed Action from the public and specialist team (Please see the EA page 4-5 and the project record for a more detailed view of this process). This illustrates how the public was involved in developing the issues, possible solutions, the Proposed Action, and the alternatives. This process gave all parties a chance to participate and is not biased for or against the motorized community, environmental groups, private landowners or the public as they all had equal opportunity to participate in the process and to represent their interests throughout.

16) One person or group of people should not be allowed to make this ruling. You need more
than just Forest Service employees making a ruling like this when it effects so many people.
The comments are great, but we all know just how far they go when someone has already
made up their mind. Do not close this area down. 194

Response: Activities on National Forest public system lands are decided by a responsible official of the Forest Service. Public involvement is mandated by NEPA to involve the public in the decision making process. Please refer to the Pubic Involvement section of the EA (EA page 4) for a detailed description of the public involvement process for this project.

17) Alternative B would be ok with me if it had a few changes made: I would not want to see a
fee charged to access my public land. I would think that there could be a way to access the
Fairview peaks area via both motorcycle and 4x4 vehicles if new routes could be developed. I
would like to see both of the proposed rock crawling areas come to fruition and all the
proposed motorcycle routes developed. Wildlife in the area is no more affected by OHV folks
than by the current homeowners in the area, as well as by the presence of county road 87J.
Consider your charge to manage the area in the interests of the public as opposed to local
landowners. 27

Response: Please see the Fees section, Fairview Peak section, Rock Crawl section, and Wildlife
section in this Response to Comments document for a detailed discussion of the points made here.

18) Basically in order to address our concerns the project evaluation must address:
i) The Majority of visitors to the project area do so to enjoy multiple-use opportunities
including motorized access and motorized recreation opportunities.
ii) Why are motorized recreationists the only ones to lose ground in every action.
iii) Where does the public go to replace the motorized access and motorized recreation that
will be closed?
iv) What is the cumulative effect on the public of this motorized access and motorized
recreation closure combined with all other motorized access and motorized recreation
closures in the state?
v) The development of a plan to mitigate the significant impacts on the public from the loss of
motorized access and motorized recreational opportunities from the Proposed Action and the
combined cumulative effect of all other actions in the state.
vi) There are no compelling reasons to close as many motorized access and motorized
recreational opportunities as proposed. It is simply contrary to the public need in the area and the way that the public uses the area.
vii) There are compelling reasons to maintain and enhance the existing level of motorized
access and motorized recreation in the project area. 217

Response: The Lefthand Canyon OHV Area is not losing its motorized emphasis, nor is it being
closed to motorized use. The EA emphasizes motorized recreation and plans for a sustainable road and trail system that is manageable by the Forest Service and will also protect the natural resources while providing quality recreational experiences (EA page 3). The route closures identified in this plan are proposed so that the above condition can be met. This will enable the Forest Service to provide an area that can be maintained long-term for motorized recreation. The routes that will remain open under this proposal can accommodate the traffic from the closure of the un-authorized routes as identified in Appendix B. Other routes have been added as well. Therefore, this plan does enhance the motorized recreation opportunities within the Lefthand Canyon OHV Area that are sustainable and can be maintained into the future.
Please also note that the motorized community is not loosing a significant number of miles under this project as the majority of closures are illegal routes that are not open for legal travel. Please see Table on page in Chapter 2, the Recreation section in Chapter 3 starting on page and the spreadsheet on Page in Appendix B for of the EA for more discussion.
The cumulative effect on the public from this proposed action combined with motorized closures
across the state and the development of a plan to mitigate these effects is outside the scope of this project as this would require a larger scale study than that of this project. This project however does provide motorized opportunities that can be maintained, rather than closing the area to motorized access.

Comment Topic 14: Recreation
1) There are many times more miles of trails open only to foot traffic compared to trails for off road vehicles. Why do you want to take even more away from the public? 141

Response: The Lefthand Canyon OHV Area Travel Management Plan EA emphasizes motorized
recreation, not foot traffic in the OHV Area. The 1997 Forest Plan determined that motorized use would be featured in the Lefthand OHV Area. While non-motorized use is not strictly prohibited in the area by the Forest Plan, it suggests consideration of various actions that promote a safe balance of multiple use of the area. This project level EA recognizes this management direction, by emphasizing motorized use opportunities while addressing related issues and ensuring adequate protection of natural resources. Please refer to the EA for detailed information on Purpose and Need, Alternatives, Affected Environment and Environmental Consequences.

2) Several letters received commented on the dusk to dawn closure and restrictions on
campfires as proposed in the preferred alternative (B). These comments are:
COHVCO objects to the ban on night riding, camping and fires as largely unsupported.
These are uses that should be allowed unless there is actual evidence of harm to public
health and safety. 280, 296
This EA destroys overnight camping, most multi-day visits, and night time trail
riding/jeeping by disallowing night use. It is absolutely wrong to deny overnight use of
the Left Hand area to all or most users because of the excessive behaviors of a
relatively few undisciplined ones. 232
No campfires is excessive. Banning fires altogether or at night is oppressive. 232
Fires should not be allowed. 4
Dawn to dusk policy will keep drunk drivers off the road and limit trash and some
obnoxious behavior: Dusk to dawn closure is a good idea, it will hamper problems of
drinking, shooting, and vandalism. 17, 60
We support limiting the site to day use only. Many of the problems appear to flow from
overnight uses. 238
I don't see a reason to have the area open to overnight camping in that it is a
moderately sized area which can be explored in a day. Overnight camping would
multiply the chances of another fire in the area. 212

Response: Dispersed camping and related campfires are allowed recreation opportunities on
National Forest, as long as they are done safely and natural resources are adequately protected.
Within the Lefthand OHV Area, these opportunities have resulted in a poor track record and
unacceptable impacts. Some of these issues include but are not limited to: an elevated potential for catastrophic wildfire from escaped campfires, problems with sanitation, vandalism, perceived threat to safety and ongoing nuisance for adjacent private landowners, unnecessary resource degradation and other concerns that result from unruly, defiant behaviors during evening hours. The EA identifies a reasonable range of alternatives that address these and a variety of other important related issues. The dusk to dawn closure identified in the action alternatives allows for more effective management while ensuring public health and safety. Any evening use or access during this closure would require authorization under special use permit. Day use dispersed camping would remain available in sites designated for this use.
The Boulder Ranger District recognizes the value of dispersed camping and how motorized access
plays a role in facilitating this recreation opportunity. In addition, it understands how dispersed camping improves recreation experiences for both motorized and non-motorized users.
Consideration of these opportunities and related issues beyond the scope of this EA is expected to occur as the District initiates future travel management planning efforts. This process is expected to better define dispersed camping/campfire regulations and resolve related issues while identifying new and improved recreation opportunities in a more comprehensive basis.
Please refer to Road and Trail and Fire sections for additional related information.

3) One comment letter submitted that the project does not consider multiple-use and must
analyze for multiple-use. This letters comments include:
The evaluation and decision-making must take into account that the total area of the
Arapaho-Roosevelt National Forest equals 1,587,000 acres and out of that total 379,000
acres or 23.9% is designated wilderness and the remaining 1,208,000 acres or 76.1% are
intended for multiple-uses and every multiple-use acre must remain available for
multiple-uses in order to meet the needs of 97.45% of the public and maintain a
reasonable balance of opportunities. 217
The proposed Lefthand Canyon plan must be based on the true needs of the public. We
request that the proposed plan be redone and that the allocation of multiple-use and
motorized recreational resources be based on the fact that 95% of the visitors needs
those opportunities and would use them. Wilderness visits are not growing nearly as
fast as multiple-use visits. Therefore, we also request that the proposed plan provide
for a growth rate of motorized recreational opportunities that matches the growing
popularity. 217
Specific NVUM data for the Arapaho-Roosevelt National Forest shows that there were
8,183,000 total site visits to the forest and only 311,900 wilderness visits. Therefore
wilderness visits in the A-RNF are only 3.8% of the total visits yet the alternative
proposed by the Forest Service provides both a disproportionately large and increased
number of recreation opportunities for wilderness visitors and at the expense of the
multiple-use and motorized visitors.

Response: The area’s close proximity to one of country’s largest metropolitan areas, fragmented land ownership, popularity of the area and landscape limitations makes it increasingly difficult to manage for a wide variety of multiple uses that result in quality recreation experiences. Given this dilemma, Forest Plan direction is increasingly important. Multiple use management was taken into consideration by the Forest Plan which balanced competing uses and identified effective recreation niche opportunities such as those in the Lefthand OHV Area. Based on this direction, the Lefthand OHV Area EA maximizes motorized use within the capability of the land yet still facilitates multiple use to the greatest extent possible. All applicable users were considered in the analysis. A mitigation/monitoring plan has been prepared to ensure implementation effectiveness (refer to EA pages 12-15).
In addition, this EA does not address or provide recreational opportunities for wilderness visitors. There are no Wilderness areas in the project area, and this plan has a motorized emphasis which is prohibited in Wilderness Areas.

4) Some commenters requested that the Lefthand Canyon OHV Area be expanded to include
more mileage for motorized recreation, or at the least, maintain the current existing
opportunities. It was also requested that the plan not reduce the opportunities to motorized
recreationists available at the OHV area. These comments are:
Continued access at present or greater levels to the OHV community should be
considered by the USFS and adopted. 162
It being one of the few areas (the only OHV area close to the plains) for OHV’s serving
this large and growing population, diminishing its size and future potential would be
contrary to future demands. It is small enough already, and the plans (b, c, d) all call for
shrinking it. Without opening up other close-in OHV areas to compensate for the loss,
shrinking this area will diminish the Denver/front range OHV opportunity. 167
All alternatives reduce motorized opportunities, what about an alternative that
enhances and/or expands opportunities? All alternatives are unacceptable, the EA
closes too much. Also, the EA specifies closure as the only option when many of the
routes can be rehabilitated and managed for use. We want to see an alternative that
takes this approach. Give us more.
80, 170, 226
Please do not close or reduce motorized opportunities in the Lefthand Canyon OHV
Area. The needs of the users be recognized first and to plan for the human component.
Motorized users are continually being singled out and are losing opportunities to
recreate in. Other letters suggested legal action to keep the opportunities available.
The trend of reduced motorized access and motorized recreational opportunities is not
necessary and is not consistent with multiple-use management of the area. The unique opportunities in the northern half, which cannot be compensated for in the southern
half, just disappear from our lives as if many of them had not been actively available to
users for over 100 years. 81, 89, 132, 148, 162, 164, 201, 202, 224, 232, 241, 247, 250, 261
Please expand motorized recreation opportunities in the Lefthand. Please know there
are many of us who are responsible motorized users of our public lands who live and
recreate here in Colorado. Please do not ignore us! We deserve and need more trails,
not fewer. The OHV motorcycle opportunity should be increased and enhanced at
LHC, in my opinion. 167, 196
Cutting back on areas as opposed to expanding them is counterproductive. This will
serve to create more problems as users ride illegally. 291
The proposed trail closures also annoy me. OHV sports have been quickly growing in
popularity in the past few years. As more people learn to enjoy this sport we will need
more trails, not less, to distribute use and prevent trail damage. 193
As the EA correctly notes, motorized recreation is increasing. MORE, NOT LESS road
and trail mileage is needed to meet the needs of the public. Alternatives B, C, and D
each decrease the motorized opportunity by at least 50%. This is not in keeping with
the needs of the motorized recreation community. It also is in conflict with the Forest
Service Handbook, which indicates that single track motorcycle trail systems are best
laid out in loops that provide longer mileage, typically 50 - 100 miles. The Alternatives
all fail to provide long sections of single track, but rather connect single track segments
to 4WD routes, and back to single track. 252, 259, 277, 281, 292, 293, 297, 300
The USFS should be increasing the mileage of motorized routes in the Left Hand area,
not decreasing it, both because of increased user needs and because the Forest Plan
calls for more motorized opportunity in this area. 232
Way too many trails and roads are to be closed in all Alternatives except A. 232
Add the single-track route to Fairview Peak proposed in Alternative C to the final
decision. The reduction of motorized trails by 50% is not acceptable in an area to be
managed for OHV use. 22, 53, 57
Cutting half of the trail mileage is unacceptable and unnecessary. I have been on the
trails and they are kept in good shape with minimal erosion, and local clubs have been
instrumental in keeping them that way at very low expense to the USFS. OHV
recreation is growing, and the participants have as much right to ride as others to also
share the trails. 136
The proposals that have been laid out to cut the areas use is by far too much. Many
different user groups us all the different types of trails located in Left Hand. By having
the vastly different trails eliminates many user conflicts. By reducing the trail system,
user conflicts with each other will increase. 258
We have enough areas closed to multi-use. Do not close any more trails. Find a way to
keep them open. You are discriminating against a large majority of the public when our
land is closed to multi-use. 277
The usage of this area should not be changed or limited. Roads that have been in use
for a period of history should not be closed or restricted. 149
These roads should be left open for off-road vehicle use. These roads offer the best
opportunity to enjoy the backcountry with our friends and family. Keep the trails open.
Don’t close anymore trails. Re-open closed trails. Please keep Lefthand Canyon open.
24. 38, 39, 40, 41
Keep open as many miles of the road and trail network as possible. Manage and reroute
roads and trails out of streambeds and harden crossing instead of closing them.
66
Do not close permanently any routes. Use temporary closures to manage the area and
then re-route to the temporarily closed roads and trails to mitigate resource damage. 66
To close down any of the trails or two track roads in this area is not an acceptable plan
of action. 256
I oppose the closing of any more trails. 278
Please provide for substantial OHV offerings in Lefthand Canyon. I motorcycled there
while visiting Boulder a few years ago. I enjoyed the rugged and scenic nature of these
routes. As one of the only opportunities for challenging OHV riding left in the Front
Range area north of Denver, Left hand is critical. With any fewer options, OHV users
will operate in an unmanaged fashion. Therefore, many miles of road and trail should
be designed and maintained for various motorized uses. Thanks for your
consideration. 143
Please count me as not in favor of closures and new permit restrictions in Lefthand
Canyon. 148
The demand is growing for OHV opportunities and the EA recognizes this trend.
Therefore the plan should either keeping or increase the motorized recreational
opportunities in the Lefthand Canyon OHV Area and not decrease them as proposed in
the preferred alternative. 95, 188, 203, 234, 274

Response: The Boulder Ranger District respects these concerns yet remains responsible for proper management of the Lefthand OHV Area.
Public involvement was crucial for ensuring identification of critical issues and the needs of the public were addressed in this project level EA. The Forest Plan clearly emphasizes motorized use in the Lefthand OHV Area. To adequately plan for this primary purpose, all known existing routes within Lefthand OHV Area were inventoried and analyzed using risk indicators in the Road Analysis Report (available in the project record), reflected in the No Action Alternative and considered in this EA. The EA analyzes actions for designating a road/trail system to meet this emphasis while protecting natural resources. A common issue raised by most commenters indicated that there are limited opportunities given various constraints. The EA identifies these constraints resulting in the Alternatives examined. The Boulder Ranger District understands the importance of road and trail connectivity and the demands for motorized recreation. However, the related motorized issues beyond the project boundary were considered but dropped from detailed study because it would not meet the Purpose
and Need as described on page 3 and 15 of the EA. Please refer to Road and Trail System and Impacts Section in response to comments for additional related response. For information related to monitoring/mitigation, please refer to the EA, Monitoring and Mitigation, Section 2.2, pages 12-15. Please also see the Impacts and Road and Trail System section responses in this document for further discussion.

5) The justifications for actions in this EA rely heavily on claims of a dire threat of vastly
increased OHV use and consequent impacts. However, increased sales and use on public
lands of OHVs are NOT exponential, as claimed. The tone of this EA sounds like scare tactics,
just as the USFS claim that OHVs are one of four threats to public lands sounds like scare
tactics. 232

Response: Please see the OHV study and report in the project file detailing the sales and use growth of Off-Highway-Vehicles.

6) pp37 - to help explain 3. You could compare % of single track available/closed (to describe
the impact/change to mountain bikers). 51

Response: The comparison is made in the table “Quick Guide Comparison of Mileages for the Action Alternatives” in Chapter 2 on page 8 of the EA.

7) Trash is not a motorized user problem. It is a local problem compounded by little attention
to prevention. 232

Response: The Boulder Ranger District agrees that trash is a problem within the Lefthand Canyon
OHV Area. Trash receptacles are proposed at the staging areas in all of the alternatives to help mitigate the trash issue (EA, Page 11, Road and Trail System Actions).

8) The management direction does not authorize a ban on night recreation use, camping or
fires. 280, 296

Response: The Forest Plan provides important guidance for managing the Lefthand OHV Area. This
guidance facilitates flexibility to make specific decisions and implement local actions that help manage the area. The actions referenced in this comment are found in each of the action alternatives and are intended to help the Boulder Ranger District manage the area more effectively while ensuring public health and safety. The agency has the authority to enact these actions through its national mandates to mange National Forest System public lands. The Boulder Ranger District will implement these actions and a variety of other supplemental regulations using CFR Subpart B authority (commonly known as Special Orders). Please refer to comment #2 above for a related comment response.

9) Several comment letters are strongly opposed to the closing of this area. Most letters did
not state reasons. Some letters did state that this is a great area and should not be tampered
with. Another letter claimed that equal access to trails for 4X4s in Colorado should be
considered with 31 million of us now in the United States. Yet another letter said that “we
would like it to remain rugged and challenging, but most importantly OPEN! The 4WD
recreational hobby has been handed one set-back after another since the mid 1970's and in
our opinion it's time to reverse this trend.” 29, 30, 36, 37, 44, 45, 47, 48, 62, 68, 82, 144, 159, 170, 180, 186, 233, 255, 262, 264, 268, 278

Response: Closing the area to motorized use is an alternative that was dropped from detailed study because it does not adequately meet the Purpose and Need. Please see page 15 of the EA for a more detailed discussion. None of the alternatives close the area.

10) We specifically request that there be no open fires or campfires at any time (Alternative C
and D). 113

Response: Based on analysis and public input, the decision imposes a dusk to dawn closure and
requires camp-fires to be in a designated fire-ring to address the concerns with fire. Please see the Fire section in this Response to Comments document for a more detailed discussion.

Shooting
11) Several comments state that shooting is not addressed in the EA. These comments also
state that there is a safety issue with having OHV use with shooting activities in the same general area. Trash left and damage done by shooters is also a concern. Some letters also
suggested closing the area to shooting completely. These comments include:
The EA does not address the issue of target shooters and the trash and destruction
done by them in the area, although it has an adverse impact on the quality and safety of
the motorized recreational experience in the area.
Shooting is not appropriate in an OHV Area; shooting should not be allowed in
Lefthand. 13, 23, 163, 167, 174, 243, 247, 252, 259, 275, 277, 281, 292, 293, 297, 300
The use of guns in Lefthand is the cause of most of the problems that need to be
addressed. Over the years I personally have hauled a couple of tons of shot up
garbage out of the area. The shooters trash up the place. The recreational motorists
constantly have to clean it up, with the hope of earning the privilege to continue to use
the area. 295

Response: The Boulder Ranger District does acknowledge that shooting is an issue in the OHV Area. The Boulder Ranger District also acknowledges that shooting is a much broader issue encompassing the entire District. For this reason, the District has decided to do a District wide analysis of this issue and is in the preliminary stages of beginning that study at the time of this decision. The shooting issue at the OHV area will be included in the overall District study. For the purposes of this project, it is outside the scope of this analysis for the reasons cited above.

12) The two shooting area mentioned have been problems over the years. These could be
converted to parking areas, but new shooting areas should be established and there location
pointed out at the parking areas: This will help assist in getting compliance with the change.
Boulder needs to establish an area for target practice, this could eliminate the inherent danger of shooting where large concentrations exist in a mixed usage area, and it will also provide an area where unwanted household items will not be used as targets: Shooting areas where users can plink and blast away and shoot freely, as they do now in the Left Hand area, are very valuable. Any questions regarding problems with the shooting areas must be addressed by better management of those areas, management which does not interfere with the freedom of
use of those areas. Another option would be to establish shooting areas outside of Lefthand.
23, 156, 212, 232, 243

Response: Please see the response to number 11 above.

Staging Areas
13) There is a need for more parking areas. I support converting the least used shooting area
into parking areas. However, it would not be fair to convert both shooting areas to parking.
105, 117

Response: Thank you for your support of adding staging areas at the Lefthand Canyon OHV Area.
Analyzing to keep one of the shooting areas versus putting in parking however is outside the scope of this project as shooting is not analyzed for the reasons in number 11 above.

14) Several of the comment letters received support converting the two shooting areas into
parking areas. These letters identified a need for parking at Lefthand. 14, 67, 68, 71, 75, 78, 79, 82, 83, 84, 85, 87, 88, 90, 91, 94, 96, 98, 99, 101, 103, 104, 110, 118, 120, 122, 123, 126, 129, 135, 137, 139, 142, 146, 150, 156, 158, 164, 166, 167, 176, 178, 179, 181, 184, 185, 190, 191, 192, 193, 195, 202, 204, 207, 209, 217, 219, 220, 224, 225, 228, 230, 231, 236, 237, 238, 239, 245, 246, 248, 251, 263, 265, 267, 276, 279, 282, 286, 287, 295

Response: Thank you for your support of adding staging areas to the Lefthand Canyon OHV Area.

15) Several letters supported the addition of toilets. 14, 67, 68, 71, 75, 76, 77, 78, 82, 84, 85, 87, 88, 90, 91, 96, 99, 100, 101, 103, 104, 108, 110, 118, 120, 121, 122, 123, 126, 129, 133, 135, 137, 139, 142, 146, 150, 152, 154, 156, 158, 160, 161, 164, 166, 170, 173, 176, 178, 179, 182, 185, 190, 191, 192, 193, 195, 198, 200, 202, 204, 206, 207, 209, 215, 217, 219, 220, 222, 224, 225, 228, 230, 231, 236, 237, 239, 245, 246, 251, 263, 265, 276, 279, 286, 287, 295, 301

Response: Thank you for your support of adding toilets at the Lefthand Canyon OHV Area.

16) Some letters supported the addition of parking and toilets, but not at the expense of the
shooting areas. Others did not support the addition of these facilities if it meant the loss of
the shooting areas. Other letters did not support concerting the two shooting areas into
parking areas though did not list reasons why. 81, 108, 140, 173
R
esponse: Please see the response to numbers 13 and number 11 above.

17) The facilities developed at the two staging areas should not eliminate access to Lefthand if future funding of the facilities is not available. 22, 53, 57

Response: The facilities at Lefthand are not meant to dictate access to the road and trail system, but to enhance the opportunities available at the OHV area.

18) The parking area could perhaps be expanded to allow for more cars. 117

Response: The capacity of the parking area will be a design parameter based on the ability of the landscape to provide a certain number of spaces.

19) I have serious doubts about the wisdom of putting a parking area that far off the main
highway in a place that was previously used for target practice due to security considerations.
239

Response: The proposed parking areas are the only flat areas that can accommodate parking and
staging for the OHV area. The parking on the highway occurs in the Boulder County’s right of way, meaning that the Forest Service does not have jurisdiction to provide parking along the main highway.

20) I would recommend the USFS to add an additional restroom and trash facility at the Five
Point area because of the sanitation problems there. A garbage and toilet area should not be
out of the question as it is a pertinent issue in the area. A toilet area at "5 points", as per one of the alternatives, would be a good spot for such facilities. There should also be garbage
areas at both the main entrance off of Lefthand Canyon Road and at 5 points. 49, 56, 212, 287

Response: The deciding officer for this EA has added a restroom and trash facility at 5-Points in the decision based on public input.

Trails Bikes
21) Support restricting trail event to designated rock crawl routes since this might keep the
dirt bikes from going off-trail. However, if trails bikes continue to go off-route trials events should be banned permanently; we recommend that you additionally consider either banning
motorcycle trials events, or restricting them to the designated rock crawl areas to try to
eliminate off trail activities; Keeping trials events on designated rock crawl routes is a good
idea (p. 11) since it has the potential to provide the off-trail experience required by the activity while keeping it on trail. However, because of the spatially promiscuous nature of trials bike technology, issuing trials events permits should be approached cautiously. The burden of enforcement should be on the sponsors, not on overburdened Forest Service, and, most
important, trial events should be discontinued immediately if any infractions occur. 14, 49, 56, 239, 278

Response: All trails bikes will be required to remain on designated routes as are all motorized
vehicles in the Lefthand Canyon OHV Area. The restriction requiring motorized vehicles to remain on designated or authorized routes is a National and Forest policy.
Two-Tiered Permit System

22) I strongly object to the part of the proposal that limits the area to day-use only "without a special permit". This sets up a two-tiered permit system, one for day use and one for overnight use. Complicated permit systems are difficult for the public to comply with. 70, 71, 77, 79, 81, 82, 83, 84, 85, 87, 88, 90, 93, 94, 96, 98, 99, 100, 101, 102, 103, 104, 105, 106, 108, 110, 115, 116, 117, 118, 119, 120, 122, 123, 125, 127, 129, 131, 133, 135, 137, 138, 139, 140, 142, 147, 150, 151, 152, 154, 158, 160, 161, 164, 166, 172, 173, 176, 178, 179, 181, 182, 184, 185, 190, 192, 193, 194, 195, 198, 200, 202, 204, 206, 207, 208, 209, 213, 215, 216, 217, 218, 219, 220, 222, 225, 227, 228, 230, 236, 237, 239, 245, 246, 248, 251, 263, 265, 267, 276, 279, 286, 288, 295, 299, 301

Response: The proposal does not require a special permit during the day. The area is proposed to be closed at night, with permitted night events. Therefore, a permit would be required to be in the OHV area at night, but no permit is required to be in the OHV area during the day when it would be normally open.

23) I support the proposed two tiered permit system. It makes sense to distinguish between
day use versus overnight use. Overnight use poses greater potential impacts and the need for
more services: I actually support issuance of permits for overnight use as differentiated from
day use. This makes enforcement of illegal 'drinking parties' much simpler. 75, 197

Response: Please see the response to number 22 above.

User Conflicts
24) The EA fails to address use conflicts between single and 4-wheel recreationists by closing
single trail routes. 280, 296

Response: The EA does acknowledge that there are safety and user conflict issues with the
proposed system of roads and trails by having two-way traffic and different modes of travel (e.g. 4- wheel recreationists and single-track trail riders) on one route (EA page 5). In the Actions Items Common to All action alternatives (B, C, and D) section (page 11 of the EA), this issue addressed as follows:
• Decrease user conflict and increase user safety by:
o Establishing a right of way (who has the right-of-way)
o Establishing One-Way routes (those rated as extreme) and providing pull-outs where
needed on the other routes.
o Provide trail ratings

Comment Topic 15: Road and Trail Network
1) Some commenters stated that the northern portion of Castle Gulch should be re-routed so
that it can remain in the system due to the importance of this route linking castle Gulch to the eastern part of the system. Another commenter also supported keeping Castle Gulch within
the designated fee area. These specific comments are below: Reroute the northern portion of Castle Gulch (287.1) to maintain a connection from Castle Gulch to Lefthand Canyon in the final decision. With the lack of access from the southern part of Castle Gulch this connection is critical. Rerouting of the northern portion of Castle Gulch Route 288.1 would benefit soil and water resources and would help heal the damage to this road. "Currently, this section of road is steep, deeply entrenched and eroded to bedrock in some places. The road is actively degrading due to vehicular use and accelerated runoff. The road is a major source of sediment for Castle Gulch Creek and Lefthand Creek, adversely impacting fish and aquatic
macroinvertibrates." Rerouting of this road should be accompanied by rehabilitation
efforts to heal the damage that has already occurred on the existing route. 22, 53, 134
Castle Gulch should remain as is. The area is seeing more visitors all the time. Lets
get some new roads built and then lets get some man power and some equipment that
can be used to change up the obstacles so that the folks coming to the area have new
and exciting challenges to look forward to from time to time. 67
We support including Castle Gulch within the designated fee area. 238

Response: The northern portion of Castle Gulch (287.1) will be re-routed to avoid soil and water impacts depending on if the Forest Service can obtain a public easement allowing motorized access to this portion of Castle Gulch.

2) Several commenters requested that the definition of a “user-created route” be reexamined
and the roads reanalyzed based on their origin. Other comments requested that routes not be
closed on the basis that they are user-created routes. One comment questions how the Forest
Service will effectively close user-created routes. The comments are as follows:
How will the USFS ensure that user created routes created after the implementation of
this project are immediately and effectively closed? How will the critical habitat of
Fairview Peak be effectively closed from all access points? The EA does not address
the details of several of these stated action goals. With the maintenance backlog the
USFS has been experiencing for some time now, concrete standards should be agreed
upon. 269
The Forest Service has identified many routes that have been in use for years as "new
user-created routes" when they are, in fact, very well established routes that have
existed for a very long time. That analysis is flawed! Many of the roads and trails in the
area have existed for many years. I recommend the USFS perform an extensive data
search to identify the origin of every route before identifying as "new user-created
routes". 53, 71, 76, 79, 81, 82, 83, 84, 85, 87, 88, 90, 91, 93, 94, 96, 98, 99, 100, 101, 102,
103, 104, 105, 110, 111, 112, 114, 115, 117, 118, 120, 121, 122, 123, 125, 127, 128, 129,
135, 137, 138, 139, 142, 147, 150, 151, 152, 153, 158, 160, 161, 165, 166, 173, 175, 176, ,
178, 179, 181, 182, 184, 185, 190, 192, 193, 194, 195, 198, 200, 204, 206, 207, 209, 215,
216, 217, 219, 220, 222, 225, 228, 230, 231, 236, 237, 239, 245, 246, 248, 251, 263, 265,
267, 276, 279, 286, 288, 295, 299, 301
This EA relies heavily on condemning user-created routes, presuming they are bad,
claiming they are illegal. The vast majority were created before restrictions on crosscountry
travel and so are legal routes. The USFS was not providing routes for
motorized users, maybe just hoping we would go away. The USFS should not close
trails because they were user-created. User-created routes are good. Even if some of
them are not of the finest design, they pretty much go where users want to go. And all
routes are needed. They are legal routes and should be adopted as system routes and
kept open for use wherever possible, with all due effort made to mitigate wear and tear
and to classify them as system routes. 232
Specific user created routes to close: (see letter #232, p. 14) 232
Specific user created routes to adopt as system routes and keep open:
(see letter #232, p. 14) 232
EA repeatedly decries the formation of 'user created trails' in the area, and utilizes this
as a reason for closure. 1902 USGS map shows that many of these routes existed over
100 years ago, and while they were probably created by miners, who were arguably
users, they were created legally and prior to the existence of the USFS. The area was
managed until recently as 'Open to OHV Travel', commonly referred to as a 'light green'
area on the USFS maps. This can be shown by the 1980 USFS Travel Map that is
available on COHVCO's website. During the decades when the USFS managed the
forest under this prescription, user created trails were legal and actually encouraged. I defy the USFS to show that any trail in the area that was created by the USFS, and
therefore isn't user created. 252, 259, 277, 281, 292, 293, 297, 300
The EA repeatedly decries the formation of "user created trails" in the area and utilizes this as a reason for closure. The area was managed until recently as "open to OHV travel", commonly referred to as a "light green" area on USFS maps. During the decades when the USFS managed the forest under this prescription, user created trails were legal and actually encouraged. 247, 275
I also believe that many of the "new user-created routes" are, in fact, very well established routes that have existed for a very long time. While this does not preclude their evaluation for closure, calling them "new user-created routes" also does not make them automatic candidates for closure. The proliferation of routes over time, while problematic from an environmental point of view, also points to strong demand for more challenging routes and variety of challenge. While much work in the plan has been done to accommodate this demand, some of the "user-created routes" could be
used to also accommodate the desire of the public for challenge and variety. Please perform an extensive data search to identify the origin of every route before identifying t as "new user-created routes". Don't take shortcuts and hurry this part of the plan. 75 "new user-created routes", if they are indeed, should not be allowed to remain. The designation of a "new user-created route" should be thoroughly researched to ensure that it is just that. 146
I don’t support closure of so called “new user-created routes”. These routes should be left open, as part of the network the area offers. 156
Your deeply flawed analysis of the area has erroneously identified many four wheel drive roads as "new" and "user created" when in fact they have been in existence for many years. Many are clearly documented on maps and in popular guide books of the area. I find this closure to be an indication of either an intentional bias against our activities or a deeply flawed knowledge of the area itself. Either way, it forms a fundamental reason to reject your plan. 164, 202

Response: The EA analyzes two types of routes in the project area. These are classified routes and unclassified routes. The following definitions were used for both roads and trails in the EA (see also EA Appendix C – glossary):
Classified Road – Roads wholly or partially within or adjacent to National Forest System land that are determined to be needed for long term motor vehicle access, including state roads, county roads, privately owned roads, National Forest System roads, and other roads authorized by the Forest Service.
Unclassified Road – Roads on National Forest System public lands that are not managed as part of the forest transportation system, such as unplanned roads, abandoned travel ways, and off-road vehicle tracks that have not been designated and managed as a trail: and those roads that were once under permit or other authorization and were not decommission upon the termination of the authorization (36 CFR 212.1).
The classified roads and trails in the project area have route numbers as identified in the Forest’s road and trail database, and the unclassified routes have letters preceded by a “U-“ for “unclassified” (please see the maps and spreadsheet in Appendix B for specific routes). The majority of routes in the project area are considered user-created unclassified routes because they are included in the above definition of unclassified roads. They can be included in this definition because these routes have off-road vehicle tracks that have not been designated and managed as a trail. These are evidenced in the Lefthand Canyon OHV Area by vehicles beingdriven off route thereby creating routes not classified in the system. The EA also does not identify every unclassified route as usercreated (please see spreadsheet in Appendix B).
Despite the time of origin, definition, or method of creation (origin); if a route is not classified as a Forest Service route with a Forest Service number in the Forest’s roads database, it is an unclassified route. The EA identifies a route as classified or unclassified and analyzes them the same. No preference was given between the two designations in the analysis. For example, some classified routes were identified for closure while some unclassified routes were identified for addition to the legal system of roads and trails (see EA Appendix B spreadsheet fro specific routes). Therefore, it would not be productive to re-examine the EA because a change in semantics or road origin would not change the analysis.
The Forest Service will ensure that user created routes created after the implementation of this project are immediately and effectively closed. Critical habitat of Fairview Peak will be effectively closed from all access points through monitoring within available Forest Service resources.

3) Many commenters rejected the idea of having only one entrance based largely on safety
reasons. They requested that the entrances at Castle Gulch remain open. These comments
are as follows:
I strongly object to the part of the proposal that would close all entry points except the
main one. The two entrances at Castle Gulch should be open to the public. This is a
major safety issue. 70, 71, 75, 77, 81, 82, 83, 84, 85, 87, 88, 90, 93, 94, 96, 98, 99, 100,
101, 103, 104, 105, 106, 108, 110, 112, 115, 116, 117, 118, 120, 121, 122, 123, 125, 127,
129, 131, 133, 135, 137, 138, 139, 140, 142, 146, 147, 150, 151, 152, 156, 158, 160, 161,
164, 165, 173, 176, 178, 179, 181, 182, 184, 185, 190, 192, 193, 195, 200, 202, 204, 206,
207, 208, 209, 217, 219, 220, 222, 224, 225, 227, 228, 230, 231, 236, 237, 239, 245, 246,
248, 251, 263, 265, 267, 276, 279, 286, 288, 295, 299, 301
I also take issue with the consolidation of access points. With the massive spread of
beetle kill in CO, areas will soon be susceptible to fire. Having only one way in and out
is a safety hazard in my opinion. I'd rather pay a slightly higher fee to have the Castle
Gulch entrances remain open. 119
One route entrance makes an area a hazard in case of natural disasters. Non-motorized
entrance makes our western regions a search and rescue nightmare issue. 170
A single access point is the dumbest thing ever heard of. That would mean that all
traffic would enter and leave at the same spot. What better way to cause road
problems. If there are multiple locations, then this breaks up that amount of traffic
which in turn causes more damage. Leave all entrances open. 194
The first time emergency services need in, or there is an access or evacuation need,
that will be one decision regretted. A single access point is also USUALLY not
environmentally sound as heavy traffic at one access point is far worse than light traffic
spread over two or more. 218
Closing those connections could also result in some serious harms occurring -- when
someone gets hurt and cant get to medical care in time because they had to spend an
extra hour getting to an "authorized" access point. 232
Castle Gulch should remain open at the highway end. In case of a vehicle breakdown or
even a health emergency, on lower part of the trail, users need a way to easily get down
to highway. In this situation, users would be forced to trespass or create their own
route. 244

Response: Closing the two entrances at Castle Gulch off of Lefthand Canyon Drive (CR94) resolves two issues. First, it stops trespass onto private land, and second, it increases safety by eliminating access points that encourage the use of non-street legal vehicles on a county highway (CR94), which is also illegal. Closing these two entry points does not restrict the entrance for the Lefthand Canyon OHV Area or Castle Gulch to one access point. Two access points are proposed in all of the action alternatives. One at the current main entrance area near the terminus of 286.1A, and the second approximately ¾ of a mile north of the current main entrance off of Lefthand Canyon Drive (CR94)(See maps for Alternative B-D in Appendix B of the EA). The latter will provide access to the Castle Gulch portion of the system without requiring off-highway-vehicles to travel on Lefthand Canyon Drive (CR94). Castle Gulch can also be accessed using the entrance at 286.1A and traveling north and then west over to Castle Gulch (see maps for Alternatives B-D in Appendix B of the EA). In addition, in the case of an emergency, or if someone gets hurt, emergency response vehicles can enter the area via the best routes available to them despite route status. This means that they can use the closed entrances off Lefthand Canyon Drive (CR94) to Castle Gulch not hindering their response time. Vehicle breakdowns do not constitute an emergency. The Forest Service would also suggest that you have a safety action plan in place before recreating that includes how you would handle an emergency. The issue that more than one entry is needed and not to make Castle Gulch entry points administrative use only because these entry points are needed for emergency purposes was
considered a non-key issue when raised during scoping because emergency access is granted to all emergency response units, no matter the designation of the route (EA page Appendix A-5).

4) Some comment letters specified routes to add to the system as part of the decision. These
are as follows:
Add the single-track route using 837.1, Ubx and a new connection between them to the
final decision. This will help disperse motorized trail use into an area specifically set up
for their use in the Lefthand area. 22, 53
Add the single-track route using 845.1, 286.1b Uav, Uaw, Uay and Ubc proposed in
Alternative C to the final decision to improve the total mileage available for single track
motorized recreation. 22, 53
There needs to be more mileage in the Lefthand Canyon OHV Area. The population of
Colorado is predicted to increase from 4.3 million people in 2000 to 5.3 million people in
2020. This increased population will greatly increase the usage by OHV enthusiasts.
Yet ALL of the alternative plans except A have cut the mileage by at least 50%.
Suggestions for additional mileage are: A) re-route the northern portion of 287.1 to
maintain a connection between Castle Gulch to Lefthand Canyon. B) A rock crawl route
below 286.1B should be developed. C) The Rock Crawl route on 286.1D as proposed in
Alternative C should be developed. D) The single track route to Fairview Peak
proposed in Alternative C should be included. E) Add a single track loop on Fairview
Peak using 285.1A, Uch, Ucc, Uca, and 848.1. F) Add a single track route using 845.1,
286.1B, Uav, Uaw, Uay, and Ubc proposed in Alternative C. G) Add a single track route
using 837.1, Ubx and a new connection between them. 65

Response: With regard to the following routes:
i) Add 837.1, U-bx and a new connection between them: 837.1 is proposed for removal from the road and trail system because the route is no longer used and has re-vegetated in. Re-opening the route would not meet the Purpose and Need of this project (please see the response to comment number 7 below for more discussion). In addition, these routes would provide access to Fairview Peak, which is proposed for closure under the Proposed Action. Please see the response to comments in the Fairview Peak section of this document for further discussion.
ii) Add the single-track route using 845.1, 286.1b Uav, Uaw, Uay and Ubc proposed in Alternative C to the final decision: The responsible official has added these routes to the decision based on public input.
iii) A) re-route the northern portion of 287.1 to maintain a connection between Castle Gulch to
Lefthand Canyon: This is proposed in action alternatives C and D. Please see the response to
comment number 1 in this section of the Response to Comments.
B) A rock crawl route below 286.1B should be developed: Please see the responses in the Rock
Crawl section of this document.
C) The Rock Crawl route on 286.1D as proposed in Alternative C should be developed: Please see
the responses in the Rock Crawl section of this document.
D) The single track route to Fairview Peak proposed in Alternative C should be included: Please seethe responses in the Fairview Peak section of this document.
E) Add a single track loop on Fairview Peak using 285.1A, Uch, Ucc, Uca, and 848.1: Please see the responses in the Fairview Peak section of this document.
F) Add a single track route using 845.1, 286.1B, Uav, Uaw, Uay, and Ubc proposed in Alternative C:
Please see the response to i above.
G) Add a single track route using 837.1, Ubx and a new connection between them: Please see the response to i above.
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Old 06-24-2006, 02:40 PM
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5) Several comment letters are against the closure of 286.1A (Carnage Canyon.), while others
supported its closure. The comments for both are as follows:
Carnage Canyon, route 286.1a -- There is NO need to close this road. It is NOT ruined.
It has simply been used. The key issue concerning its use is creation of sedimentation
and secondarily, braiding. The proper solution for this issue is to build one or two
sediment traps, composed of large stones and boulders (six inches to 36 inches
diameter). 232
Carnage Canyon: Disputing the amount of resource degradation in this area is
pointless. This area has experienced an enormous amount of use with absolutely zero
active management. The only action that has taken place in this canyon is record
keeping of displays of environmental abuse rather than any effort to control, minimize
or stop resource damage. Apply active resources in controlling use and allowing the
USFS and the more than willing public to enforce strict management. This area can be
rehabilitated and controlled to drastically minimize environmental impacts and create a
sustainable trail. 163
Don't close Carnage: the sediment issue can be initiated simply be defining where the
road is. By diverting water off of the road and in the same areas the use of something
like shot create for stabilization. 67
In regards to the potential closure of the 'Carnage' (286A) trail, I believe that it should be
kept open if at all possible. This trail has become a staple to not only the surrounding
community but to a large part of the Colorado eastern slope. 212
I no longer support the closure of what has become known as "Carnage Canyon" route.
The fact that it had become as popular as it is testifies to the fact that there is a need
that should be filled in some way. If this is closed and taken away from the available
routes, that need is just going to be expressed somewhere else in more user-created
routes being blazed into virgin area. 239
I also believe, however, that it is important to remember that these are century old
mining roads that have provided public access to public lands for decades. The
Fairview Peaks and Carnage Canyon sections are two of the most important
destinations at Lefthand Canyon and should remain open. 61
I respectively disagree with the proposed solution for trails in the Lefthand Proposed
Action. Members of the Mile Hi Jeep Club have contributed substantial amounts of time
and effort to educate users and revegetate the area in order to keep these trails open.
The Proposed Action should be rewritten to retain at least the Carnage system that
allows for a more serious off highway experience. 43
I disagree with closing Carnage Canyon. You have not shown that it cannot be
managed in an environmentally sound matter. All you have shown is what happens
when it is not managed at all. 244
The two issues I do not agree with are the closing of Fairview peak and Carnage
Canyon. I believe access to both of these areas can be environmentally friendly and
acceptable to private land owners through proper management. 20
I really think that the closure of this area (Carnage Canyon) is a mistake. 48
We also support the Carnage Canyon closure. The situation there is untenable and
places the district in a compromised position with regards to its own planning
regulations. 28

Response: Keeping Carnage (286.1A) open would not meet compliance standards as outlined in the
Forest Plan and the Clean Water Act, therefore, regulations dictate the closure of this route. In addition, keeping Carnage open would not meet the Purpose and Need of this project (EA page
3) because it is an un-sustainable route located in a creek that has resource impacts on watershed and soil resources. Therefore, this route could not be included in a sustainable road and trail system. In addition, retaining this route does not protect natural resources as stated in the Purpose and Objectives on page 3 of the EA. The EA also states that all routes within creeks will be closed under Action Items Common to All Action Alternatives (B, C, D) in the EA (page 11), and Carnage is located in a creek. Alternatives B (the proposed alternative) and D both provide rock crawl opportunities to replace the lost opportunity in Carnage Canyon. Both are included in the decision.

6) Several of the comments received focused on the need for more single-track, or requested
that the plan not reduce single-track opportunities within the Lefthand Canyon OHV Area.
These comments are:
I am in favor of keeping access to the trail system as it is presently for motorcycle use.
210
Several single track routes should be added to the Proposed Action. If they are unable
to be immediately developed, they should be included as part of the system to be
developed when a club is willing to adopt it and grant funds or other funds are
available. (see letter for list) 57
Single Track Trails: Please consider keeping more of these routes as single track
routes. Please consider taking some of the proposed routes and making them one way
routes to limit resource damage due to uphill versus downhill use. Use and
management for one way sections can be a great alternative for managing use,
minimizing user conflicts and environmental impacts.163
The Forest Service Handbook indicates that single track motorcycle trail systems are
best laid out in loops that provide longer mileage, typically 50-100 miles. The
alternatives all fail to provide long sections of single track, but rather connect single
track segments to 4WD routes, and back to single track. 275
Alternatives B, C, and D each decrease the motorized opportunity by at least 50% and
significantly degrade the quality and quantity of single track trails that are suitable for
motorcycles. If a person is only able to ride 4 - 6 miles of trail, the area will not be
attractive to users. 281
Plans B, C, D: "too much [trail] is being closed". Five miles of single track (motorcycle
trail) is not very much at all. Putting bikes and trucks on the same roads is not a good
choice, especially for the bikes. With increased usage, riding a bike at such an area will
not be considered a very enjoyable experience. 167
A disproportionately large percentage of single track trails are proposed for closure in
this EA -- therefore, the suggestions below relating to adopting and keeping open user
created routes will more frequently focus on single track routes. 232
This EA comes very short on single track trail mileage. A lot of single track is proposed
for closure and very little is proposed for addition of conversion from road. The Left
Hand area needs an increase of single track trail for usage now and especially in the
future. The area around Fairview Peak would make a good start on development of
more single track trail, and Alternative C does have the grace to propose a start. The
Fairview Peak area is particularly good for single track trail because it gives that
opportunity far away from the southern area of Left Hand which is heavily traveled by
full sized OHV. This would make a nice environment for motorcyclists and would also
increase safety. 232
The trails in the area were great for a short workout and more are needed. Frankly, 3.5
miles of trail (as provided in the preferred alternative) isn't adequate for my trail running
outings, much less my mountain bike rides. There's no way it's enough for motorcycle
use. Please provide more single-track trails in the area. 226
I do not support the Alternative B as the best choice. It limits recreation opportunities,
particularly the availability of single-track trails. Restricting single-track users this
heavily will lead to a greater number of user created routes as individuals continue to
seek this experience. 52

Response: Alternatives C and D add a single-track loop opportunity in the southern portion of the OHV Area. The responsible official has added these routes to the decision for this project based on pubic input. The unclassified and classified single-track trails proposed for closure were identified for closure because they are either unsustainable, causing resource damage, or had re-vegetated in from little to no use (please see the spreadsheet in Appendix B for trail specifics). Keeping these trails open would not meet the Purpose and Need of this project (EA page 3). Despite these closures, the EA does not close all of the single-track opportunities in the OHV Area and still offers single-track loop opportunities. In addition, the motorcyclist is not restricted to trails, but has access to the entire road and trail network unlike full size vehicles and ATV’s who are restricted to roads (please see Action tems Common to All Action Alternatives, EA page 11). The EA proposes to establish rights-of-ways to help decrease user-conflicts with multiple vehicle types on the same routes (please reference Action Items Common to All Action Alternatives, EA page 11). The project area is not large enough to accommodate long trail systems. Trail connectors to outside the project area is not possible without
encouraging trespass onto private land, which violates the Purpose and Need of the project.

7) There is a need for ALL the routes, in all parts of the Left Hand area, including those that
have revegetated. The revegetated routes will provide an experience to users that approaches
the experience of traveling a route for the first time, when it is becoming a route -- an exciting and fulfilling experience and an opportunity that cannot be had from traveling well-used routes. Routes that have been little used and overgrown must not be closed, and never
removed from the catalog. We can come back to these routes and use them again and again
and when we stop forever, for instance, after the global nuclear war, then the routes will grow
in again and stay that way. The trail is there and has been there and has been approved to be
there and we do not throw the opportunity away no matter how many plants have taken their
opportunity to grow in during our absence. Closing an overgrown trail is a hostile act. 232

Response: Four routes are proposed for removal from the road and trail system because of low level of use (please see the maps and spreadsheet in Appendix B page B-6 for the specific routes indicated as re-vegetated in). These routes are in a heavily used motorized recreation area but receive little to no use. This has allowed the routes to re-vegetate in, indicating a low or no demand for these routes. One of the Purpose and Need objectives is to protect natural resources while providing quality recreational experiences within the Lefthand Canyon OHV Area (EA page 3). Therefore it meets the Purpose and Need to close these routes rather than to create new environmental impacts that would be required to reopen routes that do not contribute to a quality recreation experience as demonstrated by the low demand for them.

8) Some comment letters request better signage along the routes in the OHV Area. These
comments are:
Clearly the trails need to be marked, signs posted (that target practice will not destroy)
with rules. Trails need to be posted with levels of difficulty. Access to be closed /
restricted for travel and reclamation areas need to be marked and natural barriers with
steel structures for stability. 23
I think the main entrance direly needs better signage. It is needed most for better
outlining of open and closed trails and of proper ethics whilst in the NF. 212

Response: The objectives described within the Purpose and Need found on page 3 of the EA
provides for increased and improved signage within the project area. This action is also included in all of the action alternatives (EA page 11).

9) Some letters supported minimizing mileage and closing routes in the project area. These
comments include:
Minimize mileage. Close Castle Gulch. 25
I especially support designated road closures, particularly user created routes that
were never designed into the system. 1
Castle Gulch should be used for administrative use only. 11

Response: This project closes the mileage necessary to meet the Purpose and Need of the EA (page 3). Castle Gulch remains open in all action alternatives because of the recreational opportunities and connection it provides to the east portion of the OHV area. Options discussed in the EA are to reroute this road or close it if the jurisdictional issues along this route cannot be resolved.

10) One of the major issues should be the basis for the recommendations of the roads
analysis plan prepared for the Lefthand Canyon area. It is not incorporated by reference in the
EA (as required in NEPA) but the road closure decisions are based on that analysis. 280, 296

Response: A Roads Analysis Report (RAP) was completed for the Lefthand Canyon OHV Area that
focused on the existing and future transportation system within OHV Area project boundary. This
analysis followed a six-step process identified in national and guidance document Roads Analysis: Informing Decisions About Managing the National Forest Transportation System (USDA Forest Service, August 1999, Misc. Report FS-643). In addition to this six-step process, the Boulder Ranger District also prepared a supplement to provide a more detailed analysis and recommendations for route by route decisions in the EA. This supplement was included as part of the RAP and both can be found in the project record. The spreadsheet in EA Appendix B (pages B5-11) is the result of the supplemental analysis. A reference was added to the spreadsheet as addressed in this comment.

11) Some commenters requested connecters or access to outside road and trail networks from
the Lefthand Canyon OHV road and trail system. One letter made a suggestion that the EA
clarify how a connecting trail system would be counter to the management direction of the
area. These comments are as follows:
Two comment letters received addressed the Proposed Action’s lack of connecting
routes to an outside trail system. One letter does not approve of off-road vehicle trail
connections to outside trails, and the other letter states that if the Forest Services
closes any trails from the outside providing access, off road vehicle use will be forced
to remain within the OHV area. 7, 58
pp15 - 2.3.2 - HVR connection. You could add that a connection would be counter to
our management direction for that area. 51

Response: The proposed road and trail network in all of the action alternatives does provide various loops throughout the network (please see the maps in appendix B). The alternative to have connecting routes outside of the system was considered but dropped from detail study. It does not meet the Purpose and Need of the Plan because it does not decrease trespass onto private land (please see page 15 of the EA for the complete discussion).

12) Some commenters recommended that routes to be developed in the future should be
included in the EA to avoid having to complete NEPA for an expansion of routes at a later date.
These comments include the following:
Roads and trails that are to be added in the future would be established in the planning
document as dotted line routes, though existing as part of the decision document they
would not be open on the ground until development criteria were met. This would avoid
further NEPA to add mileage to the Lefthand OHV area as put forth in the Forest Plan.
22, 57, 193
Any of these routes that can not be developed at this time should be included in the
final decision and added to the network when club are willing to adopt them and funds
are made available. Roads and trails that are to be added in the future would be
established in the planning document as dotted line routes, though existing as part of
the decision document they would not be open on the ground until development criteria
were met. This would avoid further NEPA to add mileage to the Lefthand OHV area as
put forth in the Forest Plan. 53, 65

Response: The EA does not identify routes for future development because the analysis includes all of the routes to be included in the authorized system of roads and trails; no routes were excluded to be developed at a later date.

13) Relocating the Northern Portion of U-aw: this would benefit soil, water and aquatic
resources, would relocate the road on a more stable landform and further from the stream
channel. 134

Response: U-aw is included in decision. This route will be re-routed as described in Appendix B
page B-7.

14) We specifically request the following actions be considered: All illegal user created routes not to be turned into legal routes. Providing a rock crawling area only if this activity will not cause resource damage and non-point source pollution to James or Lefthand Creek.
Eliminating all sources of erosion and sedimentation that can affect James and Lefthand
Creeks. Developing and maintaining a sustainable and manageable road and trail system.
113, 242

Response: The EA uses the routes necessary to create a sustainable and manageable road and trail system as required in the Purpose and Need. This may require converting some unauthorized routes to authorized routes in order to provide connectors and some reroutes to meet the Purpose and Need. Developing and maintaining a sustainable and manageable road and trail system is identified in the Purpose and Need and will address the concerns noted above regarding decreasing or eliminating erosion and sedimentation that can affect James and Lefthand Creeks.
Please see the Rock Crawl section of this document for a discussion of adding rock crawl routes in the OHV area.

15) The trail concentration in the south east part of the planning area needs to be corrected
and the adjustment and closure in the SE looks to be beneficial and well thought out. However
in the northern part of the planning area there is nothing but closure. You also have an
administrative route, 285.1 which show no reason for maintaining. Are there range ponds or
other unspecified reason for closing this trail to the public while remaining open for admin?
Why not use this rout to create an enjoyable motorized loop for all to use? Does not the route
already exist? 183

Response: 285.1 is identified for either administrative use or closure due to legal access issues and wildlife issues. It would become administrative access only if the Forest Service could acquire an easement across private land. This closure is one of the major routes to be closed in order to close the Fairview Peak area (the northern section described in the comment). Please see the Fairview Peak section of this document for further discussion on the closure of Fairview Peak.

16) Building any new route up to 5-points is not a good idea in my opinion, however. RC-A.
The terrain there is very steep and would cut through a section of virgin forest. None of the
proposed new rock crawling routes would even begin to replace the Carnage Canyon Route. I
am not in favor of creating ANY new routes if it means cutting across virgin territory. There
are already plenty enough routes there without having to create new ones. 239

Response: Please see the response to comment number 1 in the Rock Crawl section of this
document.

17) More trail maintenance is a must in this area. Cooperation with local off highway groups
and the USFS on mass trail cleanups and blocking of unauthorized trails would bring this area
back to a healthier ecosystem while still allowing use of the trail [Carnage, 286.1A] by the
public. 212

Response: Please see the response to number 5 above.

18) Reroute around mining claims where feasible. For example reroute 281.1 around the
mining claim to 849.1. Keep both these trails open. Do NOT close them or make them admin
use only. 232

Response: In the Action Items Common to All Action Alternatives section on page 11 of the EA it
states to:
• Pursue legal public access where needed to provide a sustainable road and trail network
where there is private land, and to also provide legal access for private landowners. Pursue
acquisition of isolated private in-holdings.
• Close or relocate roads traveling through private land if public use easements can not be
obtained for them. Since mining claims are private land, the above actions would apply. In the case of 281.1 and 849.1 however, 281.1’s closure is dependent upon access to Fairview Peak. Please see the response to comments in the Fairview Peak section of this document for a more detailed discussion. 849.1 is identified to be removed from the system because it is no longer being used and has re-vegetated (please see response to number 7 above).

19) Close only short spurs in heavily routed areas and hill climbs that go nowhere. 232

Response: Please refer to the Purpose and Need and Objectives found on page 3 of the EA. Short
spurs and hill climbs that go nowhere will be closed along with other routes identified in order to meet the purpose and need of this project. Please see Appendix B of the EA for specific route actions.

20) Some of the closures listed in the lower area are indeed a good idea, for some of these
trails are indeed relatively recently user-created ones. This does not include Ubc, or the
routes through Spruce Gulch 836.1-268.1 – Ubi. 836.1 should be signed as a one-way. These
particular single tracks are among some of the best riding opportunities in the area, and just in terms of linear distance, would be a great loss to the total trail system. 239

Response: With regard to the following routes:
U-bc is included in the decision based on public input. The route does provide more single-track opportunity, but will be difficult to maintain due to its proximity to steep slopes.
U-bi: is identified for closure because it is very steep and is causing resource damage. U-bi also encourages trespass onto private land (see Appendix maps and page B-6). For these reasons, it would not meet the Purpose and Need (EA page 3) to keep this route in the system.
836.1: is identified for closure in all of the action alternatives because it is unsustainable due to its location on very steeps slopes. For this reason, it would not meet the Purpose and Need of this project (EA page 3) to include this route in the system. 268.1: This route is identified in all of the action alternatives for closure. The route is no longer being
used and has re-vegetated. In addition, this route encourages trespass onto private land thereby not fulfilling the Purpose and Need of this project.

21) The EA omits any discussion of the roads and erroneously assumes that most of the roads
are user created. 280, 296

Response: The EA does include a discussion of the roads that can be found on page 54 of the EA.
In addition, all routes are mapped by alternative and a route-by-route recommendation is provided in Appendix B. Appendix B is also referenced in each alternative in Chapter 2 along with a table (Table 2, page 8) disclosing mileages by alternative. Many of the roads in the project area are user created and can be found in the Appendix referenced above. Please also see the response to number 2 above.

22) A couple of commenters noted that the routes in Lefthand are old and established and that
there is no evidence of user-created or new routes. One commenter said “Whatever "usercreated"
trails I've seen must have predated our first visit. The trail system is largely
unchanged and my experience with those of you who use it is one of good responsibility. I
despise trail breakers as much as anyone, but simply don't see evidence of it here.” The other
letter stated that many of these routes are well known and are published. I did not see a so
called new route that is not already published on a topographic map. 119, 140

Response: Please see the response to comment number 2 above.

23) These roads are historical public mining roads that have provided public access motorized
and non-motorized since the early 1900's they must remain open. 66

Response: Please see the discussion in the Heritage section on Page 100 of the EA. Only one road in the project area was identified as a historical road, the Castle Gulch Road, and it is not considered to be significant or eligible for the Register of Historic Places.

24) It is not necessary to sustain the exact condition of every route all the time. It is well within the parameters of multiple use/sustained yield to keep open routes that will change in
character and will need to be patched and repaired or rerouted now and again. 232

Response: Reasons for route closure in this plan are not based on the condition of the route itself, but on its impact to the natural resources and its sustainability. It is recognized that routes will need to be repaired and maintained over time and use.

Comment Topic 16: Rock Crawl
1) Many comment letters support the addition of the proposed rock crawl routes. These
comments are:
Creation of Alternate Rock Crawling Areas: This is a welcome proposal that should
create additional mileage. I support this proposal if it is used to add trail mileage and
not used to replace or substitute for other areas. 163
The EA does positively identify a need for both 4WD rock crawling areas and
motorcycle trail riding. These forms of recreation are subsets of the overall 4WD and
off highway motorcycling sports that deserve this attention. 252, 259, 275, 277, 292, 293,
297, 300
All rock crawl routes proposed should be included in the final decision. Due to 286.1b
being slated for closure, you will have to have an alternative to replace the closed route.
I would also like to have the rock crawl route on 286.1d, as proposed in Alt. D, included
in the final decision. It should be added to the system as a future development when
club support and funding through grants or other sources is obtained. 22, 53, 57, 244
We also support relocation of the rock crawl area out of the riparian area in Carnage
Canyon. Your plans for closures, restrictions, and restoration seem to be right on
target. 5, 7, 12, 14, 58, 60, 75, 239, 287
I do believe that dedicated rock crawling areas will go a long way to mitigate resource
damage due to people looking for more challenging routes. 14, 20, 287
I support the plans that propose more “ hardcore” rock crawling areas to be built in the
future. 193
The proposed rock crawling area is a step in the right direction. As others have
probably recommended to you, the area should be done in two steps in which the lower
section is done at one time and the upper at a later date. This would allow for input
from the users and to determine any possible environmental consequences from the
use of the crawling area. Building this trail would bring another way for the more “hardcore”
off-roaders to enjoy a trail near metropolitan area. 212

Response: All proposed rock crawl routes are included in the decision. They will be designed for use by four-wheel drive vehicles and trials bikes. These routes will allow the Forest Service to provide quality rock crawl opportunities. User created rock crawl areas, and designated routes that were not designed and signed on the ground have created significant damage to water quality, soil and aquatic resources and vegetation within Lefthand. They are unsustainable and unmanageable. Using good design principles, and learning from the experiences of other similar places would hopefully provide high quality recreation experiences. Design and development would be done so that these areas are manageable and ecologically sustainable.
The idea of staging development of the rock crawl areas will be considered in the Implementation Schedule for the Lefthand Area, which will be developed if any Alternative other than A is selected; the Implementation Schedule will prioritize and stage development for components of the final decision. Most likely all aspects of development will be staged because these improvements will be expensive and appropriated Federal funds are very limited. We will be counting on partnerships, volunteers, and grants to help with putting the decision on the ground. All action alternatives, B, C, and D include closure of 286.1A, known as Carnage Canyon, because of the extreme resource damage in the area and the alignment of the route in the creek bed at points on the route causing damage to the water, soil and aquatic resources and deterioration of water quality in Lefthand Creek. Please also see the response to number 5 in the Road and Trail System section of this document.

2) Some commenters are not in favor of rock crawl routes based on environmental impacts or
question if rock crawl activities should be permitted at all. These comments letters include:
I understand providing a rock crawl area may concentrate use, I question whether such
uses of public land should be permitted at all. 4
These resources belong to all Americans and allowing this activity is a violation of the
Multiple Use and Sustained Yield Act (16USCs531) which calls for management of NFs
"without impairment of their productivity." Rock crawling will seriously impair the
productivity of these lands and it should be eliminated. 54, 134

Response: Rock crawl routes are included in Alternatives A and C. This issue is also addressed in more detail in number 1, above.

3) Any extreme rock crawling routes must be well patrolled and easy to defend from abuse. 18

Response: Fees will be directed to staff presence on the ground as a high priority. This issue is also addressed in number 1, above.

4) There are some enhancements, primarily for the 4x4 community. I applaud that, but
question why the rock crawl areas seem to be provided at the expense of motorcyclists. 226

Response: Rock crawl routes, included in Alternatives B and D, would include use by trials bikes.

5) A major concern is that if a Trials Bike event takes over the rock crawl area, for a day or two, this may cause issue with Rock Crawlers who arrive and are unaware of the event. Having
both proposed Rock Crawl areas would alleviate this to some extent. 57, 22

Response: Special events such as a Trials Bike event would be posted in advance of the activity to inform other users.

6) We specifically request that rock crawl areas be provided only if this activity will not cause resource damage and non-point source pollution to James and Lefthand Creeks. 113

Response: Addressed in detail in number 1 above.


Comment Topic 17: RS2477
1) Several comments state that specific roads in the project area are RS2477 roads and should
not be closed. Two (280, 296) goes on to state that this is also supported by Colorado case
law. These comments are as follows:
Many of the roads slated for closure pre-date the USFS in this area (1908 Forest
Preserve), and are clearly shown in the 1902 USGS map of the area. Go to the link at
the COHVCO website to see this map. Because these roads pre-date the USFS, they are
by law public roads, and are not subject to USFS jurisdiction. Specific roads that
existed in 1902 and MUST remain open and therefore cannot be considered for closure
by the USFS are: The road around Fairview Peak, Golden Age Hill Road, Castle Gulch
(part of this road is now CR 87), Spruce Gulch (part of this road is now CR 87J). Other
roads or trails can be matched with roads shown on the 1904 USGS map, suggesting
that these also remain public roads, even if not part of the county maintenance system.
In several cases, county records identify these trails by name. For instance, FR 297.1B,
2986.1 and 286.1B are the Castle Gulch Road on the County Transportation map. Ex. 3.
U-bi, 268.1 and 837.1 are the Spring Gulch Road and FR 287.1 is the Golden Age Hill
Road.
232, 247, 252, 259, 275, 277, 280, 281, 292, 293, 296, 297, 300
The trails of Lefthand Canyon pre-date forest service travel policy and should be left to
the public to be used in many ways including motorized travel. 271
Another major issue is the jurisdiction or status of several of the roads. The
background of several roads and trails shows that they are actually the original roads
used in mining and development of this area. 280, 296

Response: Until the roads that predate the creation of the Forest are challenged through the legal system by a public road managing agency, such as a county, as required by law in order to change jurisdiction, these roads do fall under Forest Service jurisdiction. Therefore, they fall under Forest Service guidelines for management and can be closed during travel management projects such as the Lefthand Canyon OHV Area Travel Management Environmental Assessment.

2) In recent years, the USFS has taken the position that unless a county claims an RS2477
right-of-way, it need not recognize public access. This does not conform to national manual
guidance regarding RS2477. Nor do these comments require the USFS to recognize a claim
for a public road under RS2477. Instead, the point is that the EA must take into account
documentation showing that the roads in question predate establishment of the national
forest, were "constructed" as that term is defined in Colorado, and remain in public use today.
In these circumstances, USFS direction holds that it lacks the jurisdiction to actually close the roads and trails to public use. 280, 296

Response: The Forest Service agrees that unless a public road managing agency claims a RS2477
right-of-way, that road remains under Forest Service jurisdiction. This does not contradict policy. If a public road agency can provide documentation that the road predates the National Forest under RS2477 policy, and then jurisdiction will be converted to that public road managing agency. Should this be the case, when those roads revert from Forest Service jurisdiction to the jurisdiction of the public road managing agency, then the Forest Service lacks the jurisdiction to actually close the roads
and trails to public use.

3) The history of the roads is also relevant to the repeated statements in the EA that there is no legal access along portions of the roads and trails. The early USGS map and Boulder County
records indicate that these trails reflect original road beds established before this area became a National Forest (July 1, 1908). These are public roads and there is in fact "legal access." The EA incorrectly assumes that there is a trespass problem where recreationists cross
private land on the roads or trails are public and there is no lack of legal access. 280, 296

Response: This comment is regarding roads that predate the National Forest, these are RS2477
roads. To reiterate from response number 1 above, these are Forest Service roads until challenged by a public road managing agency. Until they are challenged they remain under Forest Service jurisdiction. Since these roads fall under Forest Service jurisdiction, the Forest service does not have the authority to provide public access across private land where an easement has not been granted from the private land owner.

4) Roads shown in 1902 follow the roadbed for CR 87 and CR87j. Since this is part of a county
road and is still a public road, closure for administrative use is inappropriate. If it is in fact a public a public road that predated the establishment of the National Forest, agency policy precludes its closure. The EA instead assumes that all of the roads are USFS roads where
they cross on federal land and that the same road is not a public road where it crosses private
land. These conclusions are incorrect. 280, 296

Response: The Lefthand Canyon OHV Area Travel Management Plan Environmental Assessment
does not propose to close CR87 or CR87J. Please refer to the Appendix B maps and the
accompanying spreadsheet beginning on page B-5. In addition, the Forest Service does not agree
that the conclusion above is incorrect regarding roads crossing private land. The Forest Service does not have the authority to provide public access across private land where an easement has not been granted from the private landowner.

Comment Topic 18: Scenery
1) I find it offensive that the USFS would spend more than a slight amount of money to phonyup
the appearance of an area so as to pretend that it is not being used. Those monies should
be spent on route development and maintenance. But more importantly, no trail or road
should ever be closed because it does not match some people's notions of scenic quality. 232

Response: The Forest Service has various visual requirements based on the setting of recreation
facilities or activities. The objective is not to make an area look unused, but to ensure that the facility or infrastructure fits into the landscape. Scenery, whether physically altered or natural, is integral in facilitating recreation experiences desired by forest users. The Lefthand OHV Area has been used and management has not kept pace with uncontrolled motorized recreation. Much of the scenic quality in the Lefthand OHV Area is inconsistent with Visual Quality Objectives (a.k.a. Scenery Management Objectives) identified in the Forest Plan. As discussed in the EA, Scenery, Section 3.2, pages 44-53; the existing scenic integrity is generally lower than prescribed. This project ensures that the Visual Quality Objectives for the area as established in the Forest Plan are adhered to and brought back to standard where applicable. Please see the Scenery section of Chapter 3 in the EA EA pages 44-53) for specific Visual Quality Objective Ratings established for the Lefthand Canyon
OHV Area in the Forest Plan.

2) Please consider visual aesthetics when "creating" a new rock crawl area; currently the area
is ugly. 3

Response: Construction and use of the new rock crawl area just north of the gated area adjacent
County Road 94 presents considerable design and funding challenges. National Forest engineers
and landscape architects will design the rock crawl area to have the least amount of visual impact as seen from County Road 94.

Comment Topic 19: Social and Economic
1) An independent economic statement on the region is a must. 170

Response: This is outside the scope of this document because this is a project level environmental assessment and does not analyze actions that are regional in scope.

2) Several comment letters state the concern that closing the area will lead to a decrease in
tourism money spent in the State and local communities. An impartial economic impact
should be a requirement prior to any closures. 73, 80, 136, 169, 170, 266, 272, 273

Response: The Lefthand Canyon OHV Area Travel Management Plan does not close the area to
motorized use. This alternative was considered but dropped from detailed study because it does not meet the purpose and need of the EA (please see EA page 15). Instead, this EA enhances motorized recreation in the project area by providing a sustainable road and trail system, staging areas, better signage, a map of the area, and by the addition of either single-track trails or rock crawl routes. Other enhancements can be found throughout Chapter 2 of the EA. Thus, the improvements to motorized recreation proposed in this EA should not lead to a decrease in tourism money spent in the State or local communities. The improvements may even potentially lead to an increased economic benefit as a result of this travel management plan. Motorized recreationists may be drawn to the area for a more developed motorized experience with various challenge levels, or they may prefer to visit other authorized roads and trails throughout the District for a more dispersed motorized recreation experience. An economic analysis is not required and was not conducted for this project because economic concerns were not brought up during scoping by anyone externally or internally. Therefore, this is not
a key issue and did not drive alternative development.

3) Similarly the EA is devoid of data regarding user groups and the basis for the conclusion
that the proposed action meets existing and future demand for OHV use. The A-R LRMP FEIS
noted that OHV use had increased dramatically and was expected to continue that trend.
FIES3-446. The EA ignores this critical fact when adopting a preferred alternative for the
Lefthand Canyon OHV area, which is one of the few such areas on the National Forest. 280,
296

Response: The EA does analyze for the existing and future demand for OHV use in the Lefthand
Canyon OHV Area. This discussion can be found in Chapter 3 under cumulative impacts in the
Recreation discussion beginning on page 25 in the EA. The Forest Service believes that the action alternatives will meet the increased demand for use over time by requiring vehicles to stay on route, providing a sustainable road and trail system, and providing signage and vehicle barriers to keep riders on route where needed. This will provide motorized recreational opportunities while keeping impacts constrained to a sustainable designated road and trail system that can be adequately maintained to manage for the impacts from increased use over time.
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Comment Topic 20: Support
1) Actions common to all alternatives that we support: Dusk to dawn closure will eliminate a
large part of the problems associated with partying, shooting, vandalism, fire, etc., closing
roads in, or causing damage to, creeks and riparian areas; protecting private property owners
and reducing trespass onto private land by closing roads through private land; sediment and
pollution control for chemicals; keeping use from expanding northeast over ridge; the
provision that non-compliance will lead to closures or controls. This is a good concept to
include in the plan since it gives the land managers more control and helps reverse
uncontrollable aspect of use; monitoring effectiveness of closures; improving safety by traffic
barriers and pull outs around extreme sections; reducing vandalism of public and private land (p. 26); relocating a portion of 287.1 to reduce damage to wet areas; developing a set of "risk

factors" to evaluate which routes to keep open or close (p. 54) 278
Response: Public participation as area stewards will continue to be an important asset to ensure effectiveness of project implementation and compliance with regulations.

2) I am very pleased to see what looks like a well managed motorized route system. I support
the BRD action on this issue. I support that this plan will provide routes that they can use and also manage OHV use so that it protects private land, sensitive habitats, and keep new routes from being created. The plan creates a sustainable and managed route system and reduces congestion and most importantly environmental damage. I am concerned with protecting critical wildlife habitat. 1, 2, 3, 5, 9, 10, 11, 12, 14, 15, 16, 17, 18, 19, 21, 25, 28, 49, 56, 59, 60, 64, 66, 134, 157, 238, 239, 242, 269, 280, 287, 296

Response: Thank you for your support.

3) I support Alternative B, the Proposed Action, though would welcome a combination of
Alternatives B and D. The Proposed Action (B) and Alternative D are the better plans. 8, 54

Response: All of the alternatives have different components. The selected alternative may reflect modifications based on those components of the non-selected alternatives.

4) I support Alternative B of the plan for the Lefthand, Carnage Canyon area. I would request
that the rock crawl area be built before Carnage Canyon trail is closed. 187

Response: The Forest Service agrees with your position and if feasible, would like to develop a rock crawling area prior to closure of 286.1A (Carnage Canyon) so as to not displace the rock crawling opportunity from the Lefthand OHV Area without offering a new, legal opportunity for that activity. Please also see the response to number 1 in the Rock Crawl section for more discussion.

5) With this one exception and our recommendations for Five Point staging area and stronger
fire provisions, the undersigned groups strongly support the Proposed Action because it will
provide urgently needed, high quality motorized recreation opportunities in a well-managed,
ecologically sustainable system. 14, 278

Response: Thank you for your support.

6) We support the following general actions that the Environmental Assessment addresses:
Adherence to the management directives of the 1997 Revised Forest Plan for the
Arapaho and Roosevelt National Forests and Pawnee National Grassland (Forest Plan).
Development of trailheads with safe parking, area information, and sanitation.
Day use only for the entire area (7 am – 9pm).
Creating a road system that decreases trespassing onto private lands and allows the
crossing of private property only with legal access from the owners.
All designated system routes to be rerouted out of the riparian areas where possible.
Promoting responsible use through education.
Restoring impacts caused by motorized use and preventing further watershed damage.
Designing and building sediment control and pollution control measures.
Closing public access points to Castle Gulch from CR94.
113

Response: Thank you for your support. Many of the points listed above are issue driven forces
behind travel management planning efforts in the Lefthand OHV Area. This EA has been a
collaborative effort among the Forest Service, area users, nearby landowners, environmental groups and the public. The Forest Service appreciates the high level of public participation that has gone into developing and refining this EA.

7) We are pleased to note that the Proposed Action has the greater reduction in route density
of all the alternatives and the greatest increase in habitat effectiveness. Wildlife will benefit from the reduced densities and proposed closing and restoring of roads. 287

Response: Thank you for your comment.

8) The routes [around Fairview Peak] do not comply with the direction in the Core Habitat 1.41
prescription. The routes are unenforceable because of their remote location and the fact they
would need to be patrolled on foot since they are inaccessible via USFS patrol vehicles. The
routes threaten a critical wildlife habitat area and elk migration corridor linking the high
country with Heil Ranch Open Space. Reduces trespass across private land to reach the area,
thus reducing OHV/land owner conflict that has been quite intense in this area. 14

Response: Thank you for your support. Please also see the Fairview Peak section of this document for further discussion.

9) Several letters received supported the Proposed Action. Reasons include:
The decision saves the Forest Service the expense of trying to patrol a virtually
unpatrollable area.
The decision eliminates motorized incursion into the non-motorized core habitat
prescription 1.41. The decision eliminates user created route u-bc which would enter
effective habitat and conflict with Forest Plan Guideline 108 (EA p. 20)
The decision eliminates potential adverse impacts to two sensitive species, American
three-toed and Lewis Woodpeckers (EA p. 21)
Our examination of the Proposed Action reveals that the proposed system of routes
kept open, routes to be added, and routes kept closed, will be a manageable system---
and a system that will more robustly accommodate and enhance exploding Front Range
OHV use, than the current, unplanned, unmaintained, haphazard, and difficult-toenforce
route system. Exponential growth in use is expected and this system, as
designed, will likely be able to absorb at least some of this growth and reduce pressure
on more vulnerable areas.
While the differences in miles of routes being closed and opened are not significant
among the alternatives, the resulting reduction in impacts in the Proposed Action is
significant.
Limiting new trails being developed and maintaining boundaries for this type of activity
will ensure that all parties involved can enjoy the beauty of the area and sustain any
increased use that may occur. This is a good way to limit the amount of destruction by
vehicles and also allow for the riparian areas to vegetate.
I am in support of Alternative B. I feel that this is a good compromise between
environmental protection and OHV access. I support the Proposed Action.
4, 14, 17, 20, 287

Response: Thank you for your support.

10) I think the recent signage and cables installed at Left Hand Canyon to help keep a small
minority of riders from riding off the trails was a good thing. 278

Response: Thank you for your comment. The improved signage and post-and-cable barriers have
been highly instrumental in restoration of the meadow and surrounding area. Re-vegetation there
would likely have been impossible without installation of those traffic control devices.

Comment Topic 21: Watershed
1) The studies done on the creeks in the Left Hand area watershed are from the 1970's. There
is no current, scientifically created, hard data, which would include baselines and before/after comparisons, especially before/after the Overland fire, and plant/animal/mineral metrics produced onsite and source/movement/destination tracing, to define the condition of the
creeks and the sources of any materials that would better be left out of them. Without
rigorous study, the claims of watershed damage are riddled with conjecture and bias. The
evidence offered in this EA is that fish are doing fine, with healthy natural populations, and
that means the water bugs are, too, and also the water plants -- and therefore we may infer that sedimentation and minerals transported to the creeks from the Left Hand area and OHV usage
and mining claims cannot be bad. This EA overstates, frequently and in general terms, the
claims that motorized use must be decreased to accommodate watershed problems. Any
such problems, if they exist, are non-significant. 232

Response: The Forest Service has observational data and photos from field monitoring of the
Lefthand Canyon OHV Area showing the gully erosion, soil movement and stream sedimentation that
has occurred since the 1980’s. Photographic monitoring has occurred from the 1980’s through 2005. Some of these photos are attached below. There are before and after photos of the “meadow” or “playground” area which indicate the need for management and restoration. These photo points are legitimate methods of monitoring the use and impacts from OHV recreational activities and the watershed condition in the Lefthand Canyon Dispersed Recreation Area. This observational data from field monitoring of the Lefthand Canyon Dispersed Recreation Area indicates that thundershowers, snowmelt, and rain on snow events have caused erosion and soil displacement within the project area and sedimentation into Carnage Creek and Lefthand Canyon over many years. Accelerated erosion and sediment from snowmelt events has been most alarming because in most situations snowmelt does not cause hillslope erosion, and therefore; does not cause sedimentation in streams, except in highly disturbed areas. Additionally, analysis of potential erosion and sedimentation of streams was conducted by the Forest Soil Scientist and the South Zone Hydrologist utilizing the model known as Disturbed Water Erosion Predictive Project (WEPP). The results from this modeling analysis and a summary explanation are located within the Project File at the Boulder Ranger District. According to this analysis the estimated soil erosion from the existing condition (Alternative A – No Action) to the 3 action alternatives (Alternatives B, C, and D) was between a 47% and 56% reduction in estimated soil erosion as the amount of roads were reduced. Generally, this analysis indicated that there was a dramatic difference between the amounts of soil erosion occurring under current conditions, especially during high rainfall events, such as the summer thundershowers that occur in this area frequently. The WEPP analysis indicated that the existing condition creates 47% to 56% more erosion than the 3 action alternatives, which becomes available for sedimentation of the streams in the area and downstream of the area. It should be noted that the WEPP model shows the relative effect of roads and trails and not the actual tons/acre of soil erosion. It is a model that is useful in describing or showing the relative impacts to soil erosion and sediment produced when undisturbed conditions are compared to disturbed conditions under the same climate, rainstorm events, and slopes. The WEPP model calculations that are in the Project File utilized the 2.5 year precipitation amount to represent the typical rainfall or snowmelt event and the 50 year precipitation amount to represent the high intensity thunderstorms that are typical in this area during the summer and fall. In relative terms if the 88.5 acres that are currently disturbed with roads and trails in the Project Area were undisturbed with 85%
ground cover then there would be approximately 100% to 99.5% less soil erosion and sediment
produced from those acres under the same climate, rainstorm events, and slopes. Again, this is in relative terms and is a relative comparison. These results verify the observational monitoring that the Forest Service has conducted at Lefthand Canyon Dispersed Recreation Area since 1981. Areas that are highly disturbed create greater soil erosion and sediment than normal undisturbed conditions. Generally, the greater the amount of acreage of disturbance the greater the amount of erosion and sedimentation. The undisturbed condition assumes no roads or trails are present, and the disturbed condition assumes roads and trails are present. The WEPP model used skid trail as the treatment category with compacted soil to represent the roads and trails present. Additional assumptions are in the Project File in the document titled “Lefthand OHV WEPP Assumptions”. One of the factors limiting fisheries that were identified by the CDOW in their stream surveys was insufficient pools (see EA at page 62). Excessive sedimentation can contribute to pool loss because sediment is deposited into pools. Even in the absence of recent site-specific studies regarding the effects of sediment on the Left Hand Creek fisheries, the adverse impacts of high sediment loads on fish is well documented. For example, see Suttle et. al. (2004), Argent and Flebbe (1999), Bisson and Bilby (1982) have studied potential impacts of suspended sediment and sedimentation in general to salmonids. These research articles indicate impacts from suspended sediment and find sediment on riverbeds to juvenile salmonid survival for differing reasons. Numerous other laws and policy directs the Forest Service to control and minimize erosion and sedimentation. The National Forest Management Act directs that the agency should not allow significant or permanent impairment of land productivity and that management practices should not contribute to sediment deposits that seriously affect water conditions or fish habitat. The Clean Water Act directs that the agency must apply best management practices to control non-point source pollution. The Colorado Water Quality Control Division has listed Left Hand Creek as an impaired stream in the most recent 303(d) list (see EA at page 63). Even though the pollutants of concern are primarily metals, excessive sediment contributes to cumulative impacts of an already impaired stream. A good summary of the laws that direct Forest Service actions to protect water and watersheds can be found in the Rocky Mountain Region Watershed Conservation Practices Handbook (FSH 2509.25). Left Hand Creek is a source of public drinking water. If there are areas where non-point source pollution is entering domestic water supplies, then as the land managers of these public lands, and as good neighbors, the Forest Service has a responsibility to improve watershed conditions and therefore in the long-term improve water quality for the towns and water districts that use these waters.

2) Water/Riparian: Chapter 2, page 13 – “Item 17 - "Where possible" should be removed. It will
not be possible to protect riparian areas if trails are allowed. Chapter 2, page 13 – “Item 19
"would" should be changed to "will" to reflect the strength of the commitment to remove trails
from wetlands. 50

Response: For “Item 17 - All designated system routes in water (riparian areas) will be rerouted out of the riparian areas where possible” is a mitigation measure to minimize the impacts on the watershed and riparian areas as a whole within the project area. The overall direction of the Forest Plan and the Watershed Conservation Practices is to utilize best management practices to design and locate roads as best as possible for the topography of the area. In some locations, topography may limit the options to reroute roads and trails completely out of riparian areas. We recognize that if such situations are encountered, and portions of routes are left in riparian areas, that these areas will continue to have impacts to streams and aquatic ecosystems. However, reducing the length of routes within riparian areas to the degree feasible should substantially reduce impacts over existing levels. For “Item 19 – All designated system routes in wetlands would be rerouted out of the wetlands” the use of “would” is necessary in the Environmental Assessment because the decision on which alternative to implement has not be made yet and using “will” is deemed to indicate a decision has
already been made. The “strength” of the Forest Service commitment to remove trails and roads from wetlands is not necessarily reflected in the wording of this mitigation measure. If any of the Action Alternatives are chosen by the Deciding Official – Boulder District Ranger, the Decision Notice would state which of the mitigation measures are to be in place for the implementation of the alternative.
Once the Decision Notice is signed the mitigation measures would be in effect.

3) Sedimentation - heavy sediment in the South Platte River after the Hayman fire did NOT
wreck the river or the reservoirs or the fish or the bugs. Similarly, and with vastly less impacts at hand, the Left Hand area creeks will survive OHV use just fine. Motorized route closures are not needed to ensure water quality or protect water flora and fauna in the Left Hand area. 232

Response: Please see the response to Watershed Comment 1 regarding soil and water impacts to
the Left Hand Creek watershed and the Forest Service’s responsibility to control erosion and
sediment. The adverse impacts of erosion and sediment following the Hayman fire, as well as other wildfires, are well documented. Robichaud, et al. (2003) documented rehabilitation efforts that followed the Hayman fire and also disclosed some of the effects from previous wildfires that occurred in the South Platte River Basin. In fact, the Forest Service, Natural Resource Conservation Service, and Denver Water have spent millions of dollars in rehabilitation efforts to try to limit those impacts. Denver Water was in the process of dredging Strontia Springs Reservoir because of excess sedimentation from the Buffalo Creek, Hi Meadow, and Schoonover Fires. It is also true that the fire did not permanently destroy the streams or fisheries, and that they are beginning to recover. It is important to recognize
that there are differences in effects between pulse events like wildfires, which contribute very large amounts of sediment for a short period of time, and chronic sediment from road and trail systems, like those found in Left Hand, that contribute smaller amounts of sediment for much longer periods of time. Following a wildfire sediment pulse, the stream and aquatic ecosystem has the opportunity to recover as sedimentation returns to pre-pulse conditions. Chronic sedimentation sources, however, tend not to decline over time, so that the stream has no opportunity to recover.

4) We specifically request that eliminating all sources of erosion and sedimentation that can
affect James and Lefthand Creeks be considered. 113

Response: We considered an alternative that would have eliminated off highway vehicle use in the analysis area, but it was not carried through detailed analysis because it did not meet the purpose and need or the Forest Plan direction of motorized use in the project area.
Erosion and sedimentation is a natural process that occurs throughout a watershed that will occur to some extent across the watershed. The Forest Service is responsible for minimizing erosion and sedimentation caused by human uses of National Forest System lands. The Forest Service has considered and already reduced several sources of erosion and sediment caused by human uses within the James Creek and Lefthand Creek watersheds through cooperation with many volunteers and partners. The Forest Service will continue to look at the public lands under Forest Service jurisdiction to improve soil and water condition and reduce erosion and sediment sources caused by human impacts on Forest Service lands. There are many sources of erosion and sediment that are not within the jurisdiction of the Forest Service within the James Creek and Lefthand Creek watersheds, therefore; the Forest Service has no control of the impacts of these sources. Monitoring photos of soil erosion and sedimentation at the Lefthand Canyon Dispersed Recreation Area

Comment Topic 22: Weeds
1) We are unsure how one mitigating measure, regarding the spread of weed seeds, would be
implemented. Page 13 states that any selected action alternative would require that OHV's be
"free of soil, seeds, vegetative matter, or other debris that could contain or hold seeds." At the least this seems particularly difficult. 238

Response: Thank you for pointing out that mitigation measure number 25 on page 13 of the EA
needs clarification. It was meant to require that when equipment is used for project activities such as parking area construction, road widening, restoration, or other ground-disturbing work, that equipment would be inspected for presence of dirt, mud, or plant parts to prevent noxious weeds from being introduced during the work. Equipment may originate from areas with noxious weeds that are not yet present on National Forest System public lands. This measure was not intended to require that OHVs driven by forest visitors be free of weed seed sources.

2) Plants and Weeds: An effort should be made that leads eventually to requiring all vehicles
including recreational vehicles to be weed and seed free. Recreational vehicle tires are a
significant means of transporting noxious weeds. 50

Response: Recreational vehicle tires do transport noxious weeds. Requiring all vehicles entering the Lefthand OHV area to be weed and seed free was not considered under any of the Alternatives in the EA, but could be considered in the future. Currently the area is widely infested with many weed species. As resources permit, the Boulder Ranger district will work to treat and reduce weed infestations in the project area, increase awareness about noxious weeds among all Forest visitors and encourage voluntary removal of weed seed sources from shoes, animals, and motorized and nonmotorized vehicles when visitors enter National Forest System public lands.

3) Treat your user constituency well and you might very well be able to form a partnership with
some off-roaders to help eradicate invasive species of plants; and get a grant from the
National OHV Trail Fund to support it. 232

Response: The Boulder Ranger District works with several OHV groups on various projects. Future
projects could include invasive species – for example, weed pulling events, displaying weed
awareness information on kiosks, and/or encouraging voluntary cleaning of shoes, animals, and
motorized and non-motorized vehicles when visitors enter National Forest areas to recreate.

Comment Topic 23: Wildlife
1) Some commenters stated that there was a lack of quality data, or no data at all, pertaining
to the wildlife analysis of the EA. These comments are as follows:
Recent legislation requires federal agencies to document decisions using quality data.
The travel management plan falls short of this criteria with respect to the wildlife habitat
management discussion and nonpoint source erosion. The travel management plan
fails to ensure and maximize "the quality, objectivity, utility and integrity of information
(including statistical information)." Accordingly, the EA needs to be substantially
revised with respect to the "core wildlife habitat area" to either produce such data or
delete it. 280, 296
The EA provides no data showing what portions are "core wildlife habitat" or the effects
of OHV use on the habitat. The EA does not document the basis to assume that
additional portions of the planning area are now "core wildlife habitat." 280, 296
The EA covers all of the species and habitat that might be in the area but fails to
produce data showing that continued OHV use will have an adverse effect sufficient to
warrant closing the roads and trails that have been used for several decades. 280, 296

Response: The Forest Service used the best available scientific information for this analysis, in the EA and the supporting Biological Report – Wildlife and Terrestrial Habitats, which contains more detailed analysis than the summarized information displayed in the EA. Please refer to comment number 1 under Watershed for a discussion of non-point source erosion. The EA compares expected impacts of each alternative to the core habitat adjacent to the project area, based on the mapping from the 1997 Revision of the Land and resource Management Plan for the Arapaho and Roosevelt National Forests and Pawnee National Grassland (Forest Plan) and observed conditions on the ground. Maps included in Appendix B of the EA for each alternative show the Core Habitat area, designated as Management Area 1.41 by the Forest Plan. According to the Forest Plan, motorized use is prohibited in areas with this designation. The EA does not assume that additional portions of the planning area are now core wildlife habitat; rather, the EA and the supporting Biological Report – Wildlife and Terrestrial Habitats analyze and compare expected impacts of each alternative to the Core Habitat area which is north of and adjacent to the project area. As discussed in the EA on page 85, Alternatives A and C increase the potential for user-created motorized routes into Core Habitat due to the proximity of open motorized routes to the Core Habitat area. As stated under Fairview Peak comment number 1, restricting motorized access to the Fairview Peak area as in Alternatives B and D, and to 4-wheel drive vehicles in Alternative C, is being proposed more in response to changed circumstances than it is to protecting wildlife in the Core Habitat area to the north, though wildlife protection is a secondary consideration. Please refer to Fairview Peak comment number 1 for further discussion regarding the concern expressed by this comment.

2) Sometimes statements are made which indicate that the reason for closure is to protect
wildlife from undue stress. But the research and personal experience shows that wildlife is far
more stressed by over off-trail hikers and hikers with dogs than motorized users. 183

Response: Please refer to the discussion under Fairview Peak, comment number 1 regarding the
Purpose and Objectives for this project and reasons for proposing the Alternatives analyzed in the EA. As discussed on page 75 of the EA, wildlife responses to disturbance are shaped by several factors, and vary by type of animal. The Purpose and Need for this project relates to motorized recreation, which is the primary use of the area; therefore, nonmotorized use was not included in the alternatives analyzed.

3) Fairness of environmental impact should be expressed. Proclaiming an area as a species
being destroyed need to take into account current other factors such as rainfall. Many species
lay dormant in the west until the region is friendly to their needs. That does not mean public
usage has destroyed them. 170

Response: Potential impacts to Threatened, Endangered, Forest Service Sensitive, Management
Indicator Species, and other species or habitats pertinent to this project are analyzed for each Alternative in the EA under Section 3.5, Wildlife and 3.6 Botany. The analysis does not conclude that any species is destroyed. Discussions for some species and habitats include impacts from short and long term destruction of vegetation that occurs when roads and trails are created, and other direct and indirect impacts to wildlife and plant species and their habitats that would be expected under each alternative.

4) pp74 - B - paragraph 2 - ringtails! Who has ringtails? I'd be interested in a sighting. 51

Response: When analyzing for effects of projects on Threatened, Endangered, Forest Service
Sensitive, or Management Indicator species, the Forest Service assumes species are present if
suitable habitat occurs in the project area. Suitable habitat for ringtails occurs in the Lefthand Canyon OHV area. Ringtails are not often seen, and the Forest Service is not aware of sightings in the area.

5) We are pleased to note that the Proposed Action has the greater reduction in route density
of all the alternatives and the greatest increase in habitat effectiveness. Wildlife will benefit from the reduced densities and proposed closing and restoring of roads. 14

Response: Potential impacts to effective habitat, as well as wildlife species and habitats, are
summarized and compared for each Alternative in the EA, and more detailed analysis is provided in the Biological Report – Wildlife and Terrestrial Habitats.

6) Protect the elk habitat in Fairview Peak by closing motorcycle trails created by users. 7

Response: Potential impacts to elk and their habitats are summarized and compared for each
alternative in the EA, and more detailed analysis is provided in the Biological Report – Wildlife and Terrestrial Habitats. Also see the Fairview Peak section of comment responses.

Appendix C
Minor Corrections to the EA
Some minor typographical errors, data omissions, and need for clarifications were discovered in the Lefthand Canyon OHV Area Travel Management Plan Environmental Analysis document. These were
identified through public comments and/or Forest Service document review. The following is a list of those minor corrections. None of the following resulted in a change to the analysis for this Plan:
1) A reference to the Lefthand Canyon Off-Highway-Vehicle Area Roads Analysis Report (RAP) was
added to the spreadsheet in Appendix B

2) Clarification was added to the Preble’s meadow jumping mouse discussion on page 78 of the EA. The paragraph was replaced with: “Under Alternative A, ongoing and increasing negative impacts to potential habitat from off-highway vehicle use are expected to continue, especially along route 286.1 from the main entrance to the shooting area, and along route 286.1A in Carnage Canyon. Under Alternatives B, C, and D, potential adverse effects may occur to individuals, and permanent adverse effects are expected to potential habitat, in up to about 1800 square feet of area from widening of the road at the main entrance. Under Alternatives B, C, and D, long-term beneficial effects to habitat in multiple, larger areas, particularly
Carnage Canyon and Spruce Gulch, will be much larger in extent than the area to be affected by the road widening. The Determination of Effects for threatened and endangered species is based on the potential to impact individuals, regardless of whether net long-term effects to a species and its habitat from a project may to be beneficial. Under Alternatives B, C, and D, long-term benefits to Preble’s meadow jumping mouse and its habitat are expected to outweigh short-term adverse impacts to individuals and habitat”.

3) Mitigation and Monitoring measures were added for the Preble’s meadow jumping mouse in the
Mitigation and Monitoring Common to All Alternatives section of the EA (page 12) under the wildlife subsection as follows:
Mitigation:
• During construction, staging areas for equipment must be in areas that are permanently affected, offsite, or that are outside Preble’s potential habitat (300 feet from the 100-year floodplain or as determined by project biologist).
• Restore at least 0.9 miles of potential Preble’s habitat in Carnage Canyon. Along 0.9 miles, 2.2
acres of Preble’s habitat will be restored as native shrubs, grasses and sedges are planted within the riparian corridor (20-foot wide corridor along 0.9 miles will equal 2.2 acres of restored habitat.)
• Submit a report to USFWS describing the success of restoration efforts 3 years after the initial restoration of the 2.2 acres of habitat in Carnage Canyon. Pictures of the areas to be restored, both before and after restoration, will be included.
• In the unlikely event that a Preble’s mouse (dead, injured, or hibernating) is located during
construction, the Colorado Field Office of the Service (303) 275-2370 or the Service’s Law
Enforcement Office (303) 274-3560 shall be contacted immediately.

Monitoring:
• Monitor restored areas at least twice annually to ensure successful establishment of vegetation and assess drainage concerns. Take corrective action if needed. Corrective action will range from recontouring, erosion control, and revegetation. Monitoring will continue as long as the area is managed for OHV use. Monitor the extent of Preble’s habitat affected to ensure that it does not exceed the area authorized in the December 1, 2005 Biological Opinion from the USFWS (1,800 square feet).
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Old 06-25-2006, 05:42 AM
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It could have been much worse.

So it looks like I may get to do the shakedown run on my 40 in Lefthand afterall.
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Old 06-25-2006, 02:21 PM
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Ige, how did you get this? PDF? Word doc? Send it to Wes, and he can upload i and link it here, so people can simply print out this beast and read it on paper. My eyes is throbbin'.
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Old 06-26-2006, 07:51 AM
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It represents some amazing work on the part of Cat Luna and Brian Rasmussen. They also wanted to open Fairview Peak, but the Ranger, Christine, relented when faced with environmental concerns (in all fairness she has to consider that or get sued like none other). It represents a loss of trail/road miles, but IMHO I am surprised LeftHand hasn't been closed due to damage. It could have been - but isn't. That, and the addition of a rock crawl area, night closure (to stop the beer parties), and FS personnel on site more than justify the fee for entry IMHO.

Hammer Christine on Fairview Peak, it is not necessarily permanent. Be sure to mention sensitivity to environmental concerns and offer alternatives.
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Old 07-17-2006, 06:42 PM
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Quote:
Originally Posted by Hulk
Ige, how did you get this? PDF? Word doc? Send it to Wes, and he can upload i and link it here, so people can simply print out this beast and read it on paper. My eyes is throbbin'.
i got a disc.
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Old 07-25-2006, 06:37 AM
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Default Adam Mehlberg's take on the LH decision

You may want to consider these points in your comments:
Quote:
Subject: Lefthand Canyon Final Decision


This is what I have summarized from the Lefthand Decision. It is only
from a full size vehicle view point, and it may not include other
users concerns. I hope these viewpoints will help enhance any appeals
being done.

Road miles added in decision.
286.1B (old stage road) this was closed due to proximity to shooting
area off of the paved road.
U-az user route near shooting area.
RC-A new road from pavement to five points.
RC-B new road on top of ridge above Fireman Hill.
U-bj user route on top of ridge above Fireman Hill.
U-bp user route from upper five points to Castle Gulch.

Road miles removed in decision.
285.1 (Fairview Peak), 285.1A, 288.1 (part), 288.1A, 287.1A (part),
287.1 (part), 286.1A, 286.1F.

This comes to a net loss of approximately 1.18 miles of 4WD roads in
the Lefthand Area where the prescription is 4.3, Dispersed Recreation,
and the Travel Management Strategy table (pg 74 of Forest Plan) states
that for 4WD vehicles the existing system is adequate but swaps may
occur, conversion of ways to system routes is likely (a net increase),
new roads and trails are likely to be constructed (less than 5 miles),
and no obliteration's will be carried out (pg 46 and 47 Forest Plan).

The biggest problem is with the closure of Fairview Peak, 285.1, and
all the motorized access into the northern half of the 4.3 Dispersed
Recreation prescription that makes up the Lefthand Area. This is
creating a buffer zone around the 1.41 Fairview Core Habitat area out
of half of the largest of only three areas on the Boulder Ranger
District that allow road and motorized trail additional miles per the
Forest Plan.

Page 8 of the Lefthand Decision under "Rationale for the Decision"
states that for the Fairview Peak Core Area the goal is to minimize
recreational impacts to wildlife populations and ecosystems by
discouraging additional recreational use. It appears that the Boulder
District is eliminating all motorized recreational use instead.
The other reason for elimination of motorized and mechanized from
Fairview Peak is trespass and legal public access. Reroutes are not
proposed because of cost and impact. Can this be challenged? What
reroutes have been done on the District for a comparison? They seem to
enjoy a lot of maintenance through volunteer efforts, why not do the
reroutes through grants and volunteer efforts?

The Castle Gulch southern access issues are a tough problem due to the
private property access points. I am encouraged that a Castle Gulch
loop is being maintained, though it may not survive due to easement
issues.

Adam Mehlberg
Trailridge Runners 4WD Club
Secretary
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