Flathead National Forest
650 Wolfpack Way
Kalispell, MT 59901
Forest Supervisor Weber;
Please accept these comments from Flathead Fat Tires, Inc. on the Flathead National Forest (FNF) Draft Forest Plan & Environmental Impact Statement (DEIS). Flathead Fat Tires (FFT) is a mountain bike advocacy group based in the Flathead Valley, and affiliated with the International Mountain Bike Association (IMBA). FFT is concerned with preserving and expanding mountain bike access throughout the Flathead National Forest.
FFT, in a general sense, supports action Alternative B of the draft Plan as it provides a balanced use of the forest that, with some exceptions, supports non-motorized recreational interests. We do, however, feel that support for recreational uses can be preserved or expanded in certain areas without detrimental impact to the conservation of wildlife interests.
FFT’s comments regarding the draft Forest Plan are largely place based, and thus comments pertaining to specific geographic areas are set forth below. The following comments apply to the plan generally.
Non-conforming Uses. FFT strongly supports the alternative B inclusion of existing levels of non-conforming uses in recommended wilderness areas where appropriate and sustainable. Given that recommended wilderness areas frequently do not become designated Wilderness, it makes little sense to manage these areas as if they were congressionally designated.
The continuance of mountain bike use in these areas is supported by Chapter 74.1 of the Forest Service Land Management Planning Handbook. Perhaps more importantly, the continuance of these relatively low levels of mountain bike use is considered in the DEIS: “In heavily timbered landscapes such as the Flathead National Forest, there is no scientific evidence that dispersed mountain bike use, horse use, or hiking has any significant effect on wildlife populations.”
Bicycles are compatible with conservation values, and mountain bikes do not have any more impact than other non-motorized users. As such, absent a specific, compelling reason to ban bicycles, mountain bike should be allowed to continue to use areas that are designated recommended wilderness, MA1b.
Vegetation Management in MA7. The MA7 designation should include a desired condition and objective that vegetation management should be performed in a manner that is compatible and complementary to the recreational uses in the area. FFT believes that recreation and vegetation management are compatible, however in areas with a recreation focus, those management activities must be performed with care so as to not damage or diminish the recreational opportunities.
User Groups in MA7. Table 34 within the draft Plan lists the various MA7 focused recreation areas, and includes the “featured activities” in the area. For many of the areas where the featured activity is designated as providing summer motorized access, those areas are also popular with mountain bikes and other non-motorized users. For example, the Cedar Flats Off-Highway Vehicle Area offers motorized trail riding opportunities, but is also popular amongst mountain bikers, hikers, and other users (including winter recreationists). The same can be said for the Ingalls Mountain area, the Blacktail Wild Bill Trail System, and Krause Basin. We strongly support continued motorized access in these areas, however we would like mountain bike uses in these area to be recognized so future management of the area accommodates all users, including wheeled motorized and wheeled non-motorized.
Recreation Setting and Access. The Recreation Settings and Access section of the draft Plan, within Chapter 2, should include both Desired Conditions and Objectives aimed at increasing the quantity and accessibility of trails on the forest. Throughout the draft Plan and the DEIS, it is acknowledged that increased recreational use (of all types) is expected in the future. Crowding of trails will lead to a diminished user experience, and will likely also lead to increased user conflict. It should be a forestwide Desired Condition (FW-DC-Rec) to accommodate existing desire for greater numbers of trails, as well as to accommodate expected increases in the future.
We ask that the following Desired Condition be added: A variety of motorized and non-motorized trails are available and are designed to meet current demand, and are also designed to accommodate reasonably anticipated future increases in demand.
We also ask that the following Objective (FW-OBJ-Rec) be added: Add 3-4 trail networks.
Infrastructure. As mountain bikers, high quality trails are the lifeblood of our sport. Some trails are high quality because of their pristine remoteness, others are high quality due to their accessibility, while others are high quality due to the challenge they offer riders. But regardless of the type of trail, they all require maintenance (some more than others). Furthermore, throughout the draft Plan (and these comments), there are calls for increasing the number of trails.
FFT recognizes that both new construction and maintenance of existing trail infrastructure is time consuming and expensive. While FFT will continue to support legislation that provides funding for these tasks, we also feel that public / private partnerships are important for maintaining and improving the trails on the forest. For this reason, we suggest including the following desired condition (FW-DC-IFS):
Private partnerships for the construction and maintenance of trails will be facilitated and utilized where available and appropriate.
Soils. In the soils section (Chapter 2 of the draft Plan), recreational trails should be included as a desired condition insofar as a trail would be considered contrary to the first desired condition – that long term soil and site productivity be conserved. While trails impair site productivity within the tread, the impact is minimal and is desirable for many other reasons. Similarly, “single track” trails should be exempted from the standards and guidelines (FW-STD-SOIL, and (FW-GDL-SOIL) as the draft standards and guidelines appear to be focused on vegetation management activities and road building / decommissioning. This conclusion is supported by the EIS; recreation and trails are not mentioned anywhere in the section 3.2.6 “Soil environmental consequences.” Presumably this is because the impacts of trail based recreation on soil are extremely limited.
The following comments pertain to specific geographic areas:
FFT supports continued mountain bike access access on the Alpine 7 trail, and the various spurs that are currently open to mountain bikes. These trails, along with portions of the Alpine 7 trail in the Swan and South Fork (discussed below), are extremely popular rides and one of the few places in the region where mountain bikes have access to high quality, pristine alpine terrain. Because mountain bikes are already banned from the vast majority of alpine trails throughout the Flathead National Forest, is of utmost importance that these trails remain open. For this reason, we would like the following Desired Condition (GA-HH-DC) to be included:
Portions of the Alpine 7 trail outside of the Jewel Basin Hiking Area, as well as various trails accessing Alpine 7 (including Six Mile, Hall Lake, and Bond Creek to the south, and Jimmie Ridge, Doris Creek, and Columbia Mtn. to the north) provide high quality mountain bike opportunities not found elsewhere in the Flathead National Forest.
Additionally, the boundaries of the Jewel Basin recommended wilderness area should be adjusted slightly to allow uninterrupted mountain bike access on the Broken Leg and portions of the Alpine 7 trails near Tom Tom Lake and Crater Mountain. In the alternative, non-conforming uses could be allowed on these short stretches of trail.
The 1986 / current management of the area allows mountain bike access on these trails, and these trails see significant use. We recognize that the Jewel Basin has historically not allowed mountain bike access, however expansion of the boundaries of Jewel basin has effectively cut off bicycle access on these trails. These are key north / south trail corridors that are regularly used by mountain bikes. Given that the trails necessary to maintain north-south connectivity only venture into the recommended wilderness areas for short stretches, it is reasonable to either adjust the boundaries and keep these trails in an MA5b or 5c designation (which is preferred), or allow non-conforming uses on those stretches of trail.
FFT, as a signatory to the Whitefish Range Partnership, endorses the proposal put forth by that group, along with the comments submitted in support thereof. In particular, FFT would like to see realized the WRP’s recommendations with respect to front country recreation at the southern end of the Whitefish Range.
The WRP’s idea of a front country designation is separate and distinct from the high intensity commercial recreation opportunities on the forest, but it is also more specific than the generalized recreational framework laid out by the ROS. The partnership would like to see the MA 7 designations broken into subcategories, similar to those included in the MA6 designation (e.g. MA 7a Focused Recreation Area – Higher Intensity and MA 7b Focused Recreation Area – Lower Intensity).
The purpose of this would be to determine appropriate recreational activities near communities that would allow for non-commercial recreational opportunities and connecting community based trail systems (like the Whitefish Trail) to the forest trail system.
FFT, in conjunction with the WRP, recommends the following additional Objectives:
Cedar Flats, Crystal-Cedar, Big Mountain, Werner-Nicola & MA 7 Management Direction:
Cedar Flats – Designate as MA 7a. The WRP supports the designation of the Cedar Flats Off-Highway Vehicle Area and agrees with GA-NF-MA7-Cedar Flats OHV-DC. This area should be increased in size, by including the area of the Crystal-Cedar MA7 that coincides with the map included as part of the Wheeled Summer-Motorized recommendations of the WRP (see Appendix A: Summer-Motorized page 2). We would also suggest the addition of GA-NF-MA7-Cedar Flats OHV-OBJ 01: Assess opportunities for establishing additional single-track motorized routes and loops in this area.
Crystal-Cedar – Designate as MA 7b. The WRP supports the description of the Crystal-Cedar Area, though we would like to see the area changed (as mentioned in Cedar Flats description) to greater reflect the desire of the WRP to allow for a study of potential additional motorized trails in the area east & south of Crystal Creek. We would also like to see the addition of GA-NF-MA7-Crystal-Cedar-OBJ 01: Complete NEPA on increased opportunities for non-motorized multiple use trails (As proposed by the Whitefish Face Working Group, see Appendix B)
Big Mountain – Designate as MA 7a. The WRP supports the description of the Big Mtn Area, and would suggest the addition of GA-SM-MA7-Big Mtn-OBJ 01: Complete NEPA on proposed trail system linking Whitefish Legacy Trails to NFS lands in Haskill Basin area, summit of Big Mountain and the Whitefish Divide.
Werner-Nicola – Designate as MA 7b. The WRP supports the description of the Werner-Nicola area, including maintaining the mix of recreational uses that occur in the area, both in summer and winter. We would suggest the addition of GA-NF-MA7-Werner-Nicola-OBJ 01: Complete NEPA on vegetation management and increased non-motorized multiple use trails (as proposed by the Whitefish Face Working Group, see Appendix B) and GA-NF-MA7-Werner-Nicola-OBJ 02: Work with Montana DNRC to resolve human sanitation problems at Olney trailhead and parking issues at the Upper Whitefish Lake Road during winter motorized season.
Also, as recommended by the WRP, the Pacific Northwest Trail (Trail #26) from the Huntsberger area (near Whale Creek) northward to the intersection with Kootenai National Forest Trail #372 (south of Mt. Locke) should be kept in a Backcountry Non-Motorized designation. The MA1b boundary should be placed immediately to the north / east of the trail for that segment. This relatively short adjustment to the boundary of the 1b designation will not substantially impact the wilderness character in the area, but it will keep an important portion of a designated national recreation trail open to non-motorized user groups.
FFT supports the expansion of motorized and non-motorized access with the Salish GA. In conjunction with the recommendations of the Whitefish Range Partnership, we strongly support Objective 2 (GA-SM-OBJ) – the construction of a non-motorized trail that connects the Whitefish Trails to NFS Lands. Furthermore, we support the expansion of this objection to include trails – the intent of the WRP was to provide a compelling recreational experience, which is better accomplished via a network of looping trails. Particularly in the area immediately to the west of Whitefish Mountain Resort, a trail network is appropriate and worthwhile to provide a connection from the Whitefish Trails to existing NFS trails such as the Whitefish Divide trail.
As set forth in the North Fork section above, we support the inclusion of the Werner-Nicola MA7 focused recreation area. Please refer to our comments in that section regarding this MA7 area.
In the Blacktail Wild Bill Trail System (GA-SM-MA7-BlacktailOHV), we fully support the continued existence of this area as well as the motorized uses therein. As stated in the text describing the area, mountain biking as well as horseback riding and hiking occurs in this area in addition to the motorized uses. While we support motorized use as the primary use for the area, we would like the Desired Conditions to reflect the uses in the area beyond wheeled motorized.
FFT supports the boundaries set forth in alternative B in the South Fork GA. The South Fork contains portions of the Alpine 7 trail which is a popular route for mountain bikers. In particular, accessing the Alpine 7 trail at Napa Point is extremely popular and is used frequently by mountain bikers. The trail and road along Bunker Creek is also an access point used by mountain bikers on longer rides who access the trail from the east.
For this reason, we would like the following Desired Condition (GA-SF-DC) to be included:
Portions of the Alpine 7 trail, as well as trails accessing Alpine 7 (including Middle Fork Bunker Creek, Bunker Creek, Chipmunk Peak, and Bruce Creek) provide high quality mountain bike opportunities not found elsewhere in the Flathead National Forest.
As with the Hungry Horse and South Fork GA’s, the Swan Valley GA contains portions of the Alpine 7 trail that provide an exceptional mountain biking experience which is not replicated anywhere else in the Flathead National Forest.
For this reason, we would like the following Desired Condition (GA-SF-DC) to be included:
Portions of the Alpine 7 trail, as well as trails accessing Alpine 7 (including Napa Lookout, Wire, Bond Creek, Hall Lake, Six Mile, Peterson, Echo-Broken Leg, Strawberry, and Peter Ridge) provide high quality mountain bike opportunities not found elsewhere in the Flathead National Forest.
In the discussion of Crane Mountain, FFT supports the MA7 designation for the area. In the objectives (GA-SV-MA7-Crane-OBJ), the objective should be to construct a mountain bike trail network, which would be the implementation of the desired condition for a “system of trails.” The objective currently reads as though a singular trail is the goal, however an array of trails to provide options for users of varying ability levels is what is needed. Particularly for trail areas that are close to population centers, such as Crane Mountain, a variety of trails is needed to accommodate the diverse and growing numbers of the recreating public.