Following are the full comments submitted by FAMB in favor of the Taylor Hellroaring Project.
Dear Project Leader Mackenzie,
Please accept these comments regarding the Taylor Hellroaring Project EA from Flathead Area Mountain Bikers (FAMB), a nonprofit based in the Flathead valley, dedicated to preserving and enhancing mountain bike opportunities in the area.
FAMB strongly supports the proposed action, Alternative 2. We feel that the trails proposed within Alternative 2 will provide a much needed addition to the recreational offerings in the valley. Despite the abundance of Forest Service land in the vicinity of the Flathead Valley, there are very few trailheads accessing that federal land that are easily accessible from the population centers of the valley. The trail network laid out in Alternative 2 will provide excellent front and middle country recreation opportunities that connect with other area trails and are easily accessible from existing trailheads.
The Forest Plan’s MA7 designation for the area is an acknowledgement that this area is appropriate for increased recreational use, and for good reason - the area is accessible, and its proximity to Whitefish Mountain Resort makes it a logical place for new trails. Furthermore, this trail network helps replace access that was lost to mountain bikers via recommended wilderness designations in the Forest Plan. Mountain bikers are one of the fastest growing user groups in the valley, yet they are the only user group that has lost substantial access in the last decade. This trail network will help correct a backwards policy of eliminating access for a popular non-motorized user group.
Given that trail use in the valley has grown dramatically in the last decade, this network will take some of the pressure off of other trails and trailheads and also accommodate future increases in users. We feel that the layout of the network as set forth in Alternative 2 does the best job of providing that resource in a way that will work well for the most users.
Without diminishing our strong support for Alternative 2 and the trails included therein, we feel that the EA is lacking in a few areas. First, we feel that there should be a clear statement indicating that the trails, as mapped, are for the most part not ground truthed. The final layout of the trails may deviate substantially from the trails as shown in the appendixes. The map of the trails accurately depicts the general concept and the connectivity that we envision, however the final layout will almost certainly change due to a wide variety of on the ground conditions.
Similarly, while we don’t take specific issue with any of the proposed actions with respect to logging, we feel that flexibility should be built into the trail proposals where the trails cross areas that will be logged. The EA notes that forest clearing in the proposed trail corridors would be reduced to the extent practical through careful trail design and layout, which is an excellent idea. But in areas where that is not practical, it would make sense to re-orient the trail where possible to minimize the amount of trail corridor that passes through the clear cut area. For example, Trail L5 crosses through significant areas that are proposed to be clear cut, but trails in clear cuts are less enjoyable for users, and they tend to be more difficult to maintain. Similarly, trails may need to be routed through these areas in a manner that utilizes anchor trees, or takes advantage of view points that might not have existed prior to the logging operations. While we don’t envision that these re-orientations would be major, it would be beneficial to include language in the EA that allows for adaptability in trail design to work around logging activities.
We would also like to see the trail class designations of trails L3, L4, L5, and L6 be changed to class 2/3 (i.e. leaving the option open to make those trails fit either class 2 or class 3). Those trails will likely see relatively high levels of traffic due to their proximity to the trailhead and Whitefish Mountain Resort, and they’re designed to create a set of “stacked loops.” The idea of the stacked loops is to create a mini-network that allows different users to go different distances without doing an “out and back.” The other benefit of the stacked loop arrangement is that the trails can be built to create a defacto direction of travel. For example, if L4 is built as a machine built trail with a 6% grade, and L3 is a more natural, hand built trail with a 10% grade, the flow of travel for the vast majority of higher speed bike traffic will be to ascend L4 and descend L3, which benefits all users by creating a predictable pattern. By showing the trail class for those trails as 2/3, it would leave the option open to tailor those loops as needed when laying out the trails on the ground. In other words, the EA should leave open the possibility for segments of trail that are steeper and/or rougher if ground truthing reveals that to be appropriate.
Similarly, a more natural, rougher trail will effectively slow mountain bikes down. While there are quite a few methods for reducing bike / wildlife conflicts, this is one method that is effective and can create more interesting, enjoyable trails for the riders. Additionally, short, steep pitches can actually have the effect of slowing riders down - riders perceive the change in pitch as an obstacle and approach it more hesitantly.
As it is currently written, the EA emphasizes clearing vegetation to increase sight distances in order to reduce wildlife conflicts. And while clearing vegetation and increasing sight distances is certainly useful in reducing wildlife conflicts, long sight distances also often allow bikers to achieve higher rates of speed, which may not be desirable due to wildlife and user conflict concerns. Building an arbitrarily tight, turny trail can reduce that issue, but it comes at the cost of making the trail significantly less enjoyable to ride. The BLM’s Guidelines for a Quality Trail Experience (attached) does an excellent job of discussing this dynamic and laying out the design criteria that make for an enjoyable trail that riders will want to use repeatedly.
We feel that the trail class matrix is somewhat outdated when it comes to adequately describing trail characteristics for mountain bikes, and it does not capture the nuances involved in making a good trail that is interesting and fun to ride on a mountain bike while also being enjoyable for other users and also constraining use in a way that reduces wildlife conflicts. But even though the trail class matrix is deficient in that regard, it does not mean that such a trail can’t be built.
Ultimately, the important point is to ensure that the trail class designations for the trails are not restricting the trail builders’ ability to create the best trail possible given the goals of the network and on the ground conditions. More specifically, the trail class designations should not serve as an impediment to speed controls via technical features (i.e. roots and rocks within the trail tread and changes in trail pitch). Trail class 3 states that “Obstacles may be common, but not substantial or intended to provide challenge,“ which will often mean that the trail class does not allow for sufficiently difficult obstacles to slow riders down. Thus our recommendation to allow for a Trail class 2 where appropriate, which states that “Obstacles may be common, substantial, and intended to provide increased challenge.“ As noted above, particularly on trails that are built with descending in mind, a trail class 2 designation will leave more options open to the trail builders to include design elements that will reduce riders’ speeds, and given the wildlife concerns in the area, keeping as many options available as possible seems appropriate.
Notwithstanding the foregoing, and without diminishing FAMB’s strong support for Alternative 2, we feel that Alternative 3 could be laid out in a manner to better serve the recreating public and the goals of the project.
First, and most importantly, we feel Alternative 3 should retain Trail 2. Trail 2 is an alternative access point into the network if access through private land cannot be obtained. This situation is the same in both Alternative 2 and 3; if access through private land cannot be obtained, the primary access into the network will necessarily be on Trail 2. Thus, if Alternative 3 is adopted as proposed without including Trail 2, and access through private land cannot be obtained, the network is effectively isolated with no reasonable point of access from the south. This would obviously be detrimental, and would substantially reduce the use and benefit of many of the trails.
One of the stated concerns about Trail 2 is “multiple switchbacks,” however the EA does not actually explain why a trail with multiple switchbacks is problematic. Regardless, the trail could be re-oriented to reduce the number of switchbacks while still accomplishing the requisite connectivity. The other concern with this trail appears to be negative wildlife interactions, and specifically, grizzly bears. While we recognize that negative interactions with bears are a concern, as noted in the EA on page 3-178, Herrero and Higgins “found that incidents involving grizzly bears were more likely to occur in back country locations as compared to front country locations.” Given that Trail 2 is in close proximity to Whitefish Mountain Resort and is relatively close to houses in the Elk Highlands area, it would seem that it is located in the most “front country” location of all of the trails proposed. Thus, while negative bear interactions are certainly still a concern, based on the studies on the topic, it appears that the location of Trail 2 would indicate that it is less likely to be problematic. Given the importance of Trail 2 for connectivity in the event that a connection through private property is not possible, the trail should be kept in Alternative 3 as an alternative access point.
Second, Alternative 3 removes trail L5, but keeps L7 and L8. We feel that this tradeoff is not ideal – L5, in conjunction with L3 and L6, creates a series of stacked loops that stretch from Hellroaring Creek to the ridgeline. We anticipate that these will be the most popular trails in the network, and they’ll receive the most use. Removing the upper portion of L5 negatively impacts this configuration because 1) it means L6 is the only connector to the ridgeline in the area, which means that all traffic will be routed on that trail corridor, effectively creating a choke point; 2) it removes any possibility of establishing (whether by rule or by defacto use) preferred directions of travel, since all traffic directions will necessarily use L6, and 3) we feel that creating a denser network in that area makes more sense in terms of wildlife impacts – it concentrates much of the use in one area, allowing wildlife to adapt and avoid that particular area. If trails are going to be removed from Alternative 2, we feel a better configuration is to keep L5 and remove L8. In this context, L8 refers to the northern trail labelled as L8 on the Alternative 3 map (there are two trails on the map labelled as L8).
Third, Alternative 3 retains two trails at the northern end of the project (both labelled as L8 on the Alternative 3 map), but it removes Trail L9. We feel that L9 is ultimately more important to the network than the northern L8 trail. Trail L9 provides better access into the network from the northern end of the project area, and would better allow some users to access the trails from the north end of Taylor Creek Road. While we don’t anticipate that this will be a major access point for the network, it is nevertheless preferential over the Alternative 3 configuration where L8 is the northernmost access point along Taylor Creek Road. Thus, while we still support the inclusion of all trails as set forth in Alternative 2, we feel that the northern L8 trail could be removed, and Trail L9 should be kept.
Fourth, Alternative 3 removes all trails to the west (downhill) of Taylor Creek Road in the area of trails L7 and L8. We feel this minor reduction in mileage comes at a high cost, as it will force all traffic in that area onto the Taylor Creek Road. While both Alternative 2 and Alternative 3 utilize Taylor Creek Road to create connections where necessary, Alternative 3 will put considerably more traffic on the road for much longer stretches. We’re concerned that configuration will not only create a less enjoyable experience for the trail users, but also will create potential conflicts with cars and other motorized traffic on the road. Furthermore, deleting these trails makes potential connections to areas to the west of the project area (e.g. future connections across private or DNRC lands) considerably more difficult. Given that the segments of trail to the west of Taylor Creek Road are relatively short, this attempt to reduce overall trail mileage of the project has a high cost with seemingly little benefit.
Fifth, we feel that Alternative 3 falls short by removing both C3 and C4, on the north side of the ridgeline. While together, those trails create a good loop opportunity, a significant benefit of those trails is creating access to 316 Road, and thus access to the Smokey Range NRT. Absent those trails on the north side of the ridge, there is no practical way to access the Smokey Range trail, and given its designation as a National Recreation Trail and the fact that the Purpose and Need statement for this project specifically mentions connectivity to that trail, omitting C3 and/or C4 is particularly detrimental to that goal. By keeping C3 (but, perhaps, omitting C4, or vice-versa), the goal of providing accessibility to the Smokey Range NRT could be accomplished, albeit without the shorter loop potential offered by retaining both of those trails.
With respect to Trails C3 and C4, the EA raises concerns about facilitating access to the Smokey Range Trail because easier access could mean the trail becomes a high-use trail in the future. While this concern seems somewhat at odds with the trail’s designation as a National Recreation Trail and the project’s stated Purpose and Need, it also seems unlikely that levels of use will increase to high levels. Even with the access that would be afforded by Trails C3 and C4, reaching the Smokey Range trail and travelling across it is still a significant and difficult journey that only a relatively small number of people will be able to undertake. From the trailhead, it’s still 14-15 miles with significant elevation gain just to get to the start of the Smokey Range Trail. In other words, even with the addition of Trails C3 and/or C4, the Smokey Range Trail is still a large and difficult adventure that will be beyond the abilities of most recreationists.
Regardless of the alternative chosen or the specific trails approved, FAMB also has concerns about the suggested Implementation Actions and Timelines set forth in table 3-34. Given that many of the trails pass through areas where substantial logging activities will be occurring, we feel that the timelines need to better acknowledge the delays that may be associated with those harvests, as it makes little sense to construct a trail that would, shortly thereafter, potentially be damaged by logging operations. Furthermore, those same logging activities may create difficulties in flagging and laying out the precise locations of the trails. We feel these potential difficulties should be acknowledged at the outset, and a goal for implementation of the project should be the close coordination of logging activities and trail planning and construction. It also means that trails that are unaffected or minimally affected by logging activities may be the most appropriate segments to work on to begin with.
We also feel that the implementation timeline doesn’t envision a more rapid build-out of the trail network if funding and resources become available. While it is to be seen if funding can be found for the construction of the trails, if funding is forthcoming and the construction of the initial trails goes smoothly, the implementation plan should accommodate a more rapid construction of the remainder of the network.
Thank you for your work on this project and your time in considering these comments. FAMB looks forward to working with the Forest Service both through the approval and implementation stages of this project. The recreation opportunities that this proposal provides will be a tremendous asset to the community.
/s/ Erin Bodman
Flathead Area Mountain Bikers President
FAMB is recognized as a nonprofit organization under IRS Code 501(c)(3)
Flathead Area Mountain Bikers, a 501(c)(3) nonprofit, is working to promote mountain biking and improve trail access in the Flathead Valley.