​​The Taylor Hellroaring Project is a proposal to build a new network of trails on the Whitefish Face, to the north and west of Whitefish Mountain Resort. These trails would connect to the existing trails on Whitefish Mountain Resort and to the Whitefish Trail as well as to the network of trails to the north of the resort. FAMB has been instrumental in crafting this proposal and strongly supports this project. FAMB submitted comments in April, 2017. A summary of these comments appeared in a previous blog post on our website. 

This month, FAMB submitted comments on the project Environmental Assessment (EA), in support of Alternative 2, which adds the most trails - approximately 40 miles of new trail. You can learn more about the project here.
A map of Alternative 2, which FAMB supports, is here.
A map of Alternative 3, which has a reduced number of trails, is here.
Alternative 1 would be "no action" - no new trails built.

The full text of FAMB's comment appears below:

Dear Project Leader Bond,
 
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 recreational opportunities afforded by Alternative 2, as it provides excellent opportunities for accessible recreation, and it creates a broader network that will allow users to spread out and thus avoid conflicts that can arise on crowded trails. Furthermore, the additional mileage of trails in Alternative 2 (as opposed to Alternative 3) goes further towards replacing the access that was lost by mountain bikers through the adoption of recommended wilderness areas in the recent Forest Plan revision.
 
FAMB feels that, while there are undoubtedly impacts associated with trail networks and the use thereof, those impacts can largely be addressed via smart trail construction techniques. Those include (but certainly aren’t limited to) building proper sight lines, routing the trail so as to avoid sensitive areas, and promoting safe travel practices via education and signage.
 
Notwithstanding the foregoing, and without diminishing FAMB’s 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 3-40. 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.
 
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. For example, Trail L5 crosses through significant areas that are proposed to be clear cut.  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, because 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 consider the possibility of logging related changes to the trail configuration at this juncture.
 
While these are somewhat less significant concerns, we also feel the project could be improved with the following changes:
1)      We prefer the orientation of Trail 1 in Alternative 3, which avoids the wetland area. Alternative 2 should include that trail configuration.
2)      While we prefer Alternative 2, we do not take issue with the trails in the Holbrook area that were removed in Alternative 3 due to landowner concerns. Specifically, we don’t take issue with removal of Trails L1B and C1 from Alternative 2.
3)      The configuration of Trail L7 in Alternative 3 appears to be preferential to the configuration of L7 in Alternative 2. We suggest changing Alternative 2 with respect to that trail segment.
4)      There appears to be an inconsistency with respect to Trail L8.  There are two “L8’s” on the Alternative 3 map. The southern L8 segment is unlabeled on the Alternative 2 map.  The discussion of the segment in Table 2-8 appears to be referring to the southern segment. We support the inclusion of both segments, as depicted on the Alternative 2 map. However, as noted in these comments, we feel that L5 and L9 are more important segments than the northern L8 segment.
5)      Trail L9 could be slightly re-oriented to avoid the tributary to Taylor Creek (at the northernmost extent of the trail). By staying to the south of that creek, some concerns may be alleviated, and trail construction will be less complicated.
 
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.

FAMB has been hard at work advocating for mountain biking in Northwest Montana. One of the items we've been following closely has been the Flathead National Forest Plan Revision process. As we've indicated to you in our previous blog post, there is lots of be excited about in the proposed forest plan revision. However, FAMB has just submitted an objection to the Plan Revision's handling of recommended wilderness areas. The text of FAMB's objection appears in its entirety below:

Statement of issues and/or parts of the plan revision to which the objection applies:
Section MA1b-Suit(06) improperly states that “Mechanized transport … [is] not suitable in recommended wilderness areas.”  This section is in violation of Forest Planning Rules.
​
Concise statement explaining the objection and suggestion how the proposed plan should be improved:
In referencing the management of recommended wilderness (RW), the FSH 1909.12, gives discretion to Forest Service managers to determine how to manage recommended wilderness areas in their land use plans. However, despite that discretion, the Rule does not permit a categorical, forest wide approach with respect to existing uses.  Furthermore, the Rule lays out an obvious, if not defined, hierarchy or path of progression when it discusses the development of the plan components for RW.

Chapter 74.1 reads as follows:
When developing plan components for recommended wilderness areas, the Responsible Official has discretion to implement a range of management options. All plan components applicable to a recommended area must protect and maintain the social and ecological characteristics that provide the basis for wilderness recommendation. In addition, the plan may include one or more plan components for a recommended wilderness area that:
1.  Enhance the ecological and social characteristics that provide the basis for wilderness designations;
2.  Continue existing uses, only if such uses do not prevent the protection and maintenance of the social and ecological characteristics that provide the basis for wilderness designation;
3.  Alter existing uses, subject to valid existing rights; or
4.  Eliminate existing uses, except those uses subject to valid existing rights.
The Responsible Official should strive to maintain consistency with the provisions of 16 USC 1133(d) and the content of FSM 1923.03(3) when developing plan components for the management of recommended wilderness areas.
 
The Section MA1b-Suit of the 2017 Flathead National Forest Plan violates this Rule with regard to mechanical transport for several reasons.

First, the Rule dictates a discretionary approach to recommended wilderness areas on a case by case basis. The Rule discusses options related to a recommended wilderness area, not all recommended wilderness areas within the Plan’s purview. Contrary to this Rule, the Flathead Forest Plan categorically excludes mechanized transport in recommended wilderness areas, which goes above and beyond the case by case approach required by the planning rule. The Rule clearly contemplates the consideration and management of individual recommended wilderness areas, and by taking a forest wide approach to management, the Plan abdicates the responsibility of the Responsible Official to manage and exercise discretion over each recommended wilderness area.

Second, the path of plan components as set forth in Chapter 74.1 begins with the intent to first seek to manage the wilderness character (#1) and then to seek a continuation of uses (#2) with careful and active management to prevent degradation of the character by those continued uses. It then moves on to (#3) altering existing uses as a mitigation step where, logically, if the continuation of uses is not working an adaptive approach is taken to correct it. Finally, the last step (#4) is to eliminate uses if mitigation efforts fail.

The Rule effectively creates a hierarchy, and while the manager ultimately has discretion, the hierarchy established by the Planning Rule cannot simply be ignored. The Forest Plan effectively bypasses the adaptive management steps (#1-3) altogether and adopts the most restrictive option (#4) of elimination of uses that are considered non-conforming to wilderness. This approach has negative impacts on public access to established uses often coexisting with the identified wilderness character on those landscapes.

We contend that existing levels of bicycle use, and associated impacts that would otherwise violate the Wilderness Act should be permitted to occur in RW’s so long as that use does not prevent the protection and maintenance of the social and ecological characteristics that provide the basis for wilderness designation in the first place. Furthermore, we contend that existing levels of bicycle use do not prevent that basis for Wilderness designation, since that use has existed in the area for many years, and the fact that the area is designated as RW indicates that that mechanized use has not prevented wilderness characteristics from existing thus far. In other words, bicycle use hasn’t impaired the area, and there is no indication that existing levels of bicycle use will begin harming the area in the future.

Therefore, we urge the USFS to more thoroughly follow the steps laid out in the FSH and manage RW to allow the maximum range of existing public-use opportunities as a first step while managing the existing concurrent wilderness character. The key word here is “manage”. In managing the character with the existing uses, the experiences of the individual user should not be manipulated or controlled simply due to the recommended wilderness identification unless clear evidence demonstrates that the character is being permanently diminished and prior or concurrent mitigation efforts are proving unsuccessful. Through active and adaptive management, limitations and/or zoning of some uses may become necessary if conditions or resource concerns begin to deteriorate and mitigation efforts are not successful. Under such circumstances, a public planning process under NEPA should assess the need for change and determine a balanced plan solution that minimizes resource impacts and minimizes loss of diverse public access opportunities. Subtle and non-restrictive management techniques and mitigation efforts which reduce impact on the wilderness character should be employed before user restrictions which ration or control use are employed. Only after all other options are exhausted, and it is well demonstrated and documented that wilderness character will be irreparably damaged by continued non-conforming use, should the elimination of certain uses be administered. In such instances, user restrictions or eliminations, when necessary, should be administered trail by trail in a way which addresses the specific problems versus a broad brush approach of wholesale eviction and elimination.

The duty of Forest Service land managers is first and foremost to manage the resources. Adaptively managing resources must be the first step in the process of any action. Land managers must not manage RW as de-facto Wilderness by eliminating uses in an arbitrary and capricious manner. Only Congress has reserved the authority to make final decisions on Wilderness designation, therefore recommended wilderness should be managed consistent with the multi-use mandate that exists for general forest service lands until such time that the Congress acts to change the landscapes to a more restrictive and permanent designation. And it that framework of adaptive management that is precisely what is laid out in Chapter 74.1, which was brushed aside in the Plan’s forest wide exclusion of bikes from recommended wilderness areas.

Finally, the very use of the term “mechanized transport” is vague and poorly supported. While the use stems from the Wilderness Act, the original intent behind the term is highly debatable, and the Forest Service’s application of the term has been inconsistent.  In managing the use of non-motorized bicycles on the forest, the Forest Service should simply refer to them as what they are: bicycles. The continued use of “mechanized” simply confuses the issue since there are numerous forms of transport that are, to some degree or another, mechanized, and that do not appear to be contemplated by the Forest Service’s use of the term.

For these reasons, any categorical exclusion of non-motorized bicycles from recommended wilderness, including that set forth in Section MA1b-Suit, should be deleted from the plan. The use of bicycles in recommended wilderness must only be addressed on a case by case basis, and should follow the management hierarchy described in FSH 1909.12, Chapter 74.1.  
 
The reasons for this objection are:
The Forest Plan categorically excludes mechanized transport in recommended wilderness, which is contrary to the directives contained within the Forest Planning Rule.

Proposed solution:
Delete all categorical exclusions of mechanical transport in recommended wilderness, as that terms pertains to non-motorized bicycles, from the Forest Plan. Considerations of bicycle use in recommended wilderness should be undertaken on a case by case basis, and should follow the management hierarchy set forth in FSH 1909.12, Chapter 74.1.

Statement demonstrating the link between objection and prior formal comments:
Flathead Area Mountain Bikers submitted comments supporting Forest Plan alternative B, and specifically supporting the continued allowance of non-conforming uses in recommended wilderness areas. The Comments also noted that continued allowance of mountain bike use was supported by Chapter 74.1 of the Land Management Planning Handbook.