Dennis Dailey
Wilderness Services
daileys@camasnet.com
Summary of comments regarding
the proposed Forest Service Trail Classification System
Background: In 2004, Backcountry Horsemen of America became aware of efforts within the Forest Service to revise the trail classification system and change trail standards that had evolved and been time tested for nearly a hundred years. The proposed system paralleled the recreation opportunity spectrum introducing a trail class at the primitive end of the spectrum (which would include a large portion of designated wilderness und lightly used backcountry) that would not be managed to accommodate either pack or saddle stock. It also introduced two additional classes that were of a lesser development scale than secondary (more difficult) and mainline (easiest) that could be used in more heavily used backcountry areas and wilderness, and two additional trails of a higher standard that would be appropriate outside wilderness in the more developed portions of the recreation spectrum. If implemented the proposed system would seriously affect access by recreational pack and saddle stock users.
BCHA called, wrote and traveled to
Summary of Comments: The comments were numbered, in pen, from 1 to 127. One hundred and two expressed concerns about the effects of the TCS on equestrians (numbers 26 through 127). There were several duplicates of the BCHA comments -- presumably these were mailed by state or local organizations or individuals without a cover letter. The majority of equestrian responses were from Back Country Horsemen (BCHA, BCH state and local organizations and individual BCHers). Comments were received from the American Horse Council (representing 185 unnamed equine organizations and several hundred thousand individual horse owners); from the Idaho Outfitter and Guide Association; the Kansas Horse Council; The Shawnee Trail Conservancy; and from a number of horse users who did not identify a specific affiliation.
Conspicuously absent were comments from commercial outfitters/packers, and hunters -- who are dependent upon stock for access to wilderness and backcountry. It is likely that these interests were uninformed of the agency's proposal and the potential impacts to their specific activity. Also silent or under-represented were state horse councils and breed associations. Although one could conclude that these were reflected in the American Horse Councils comment, it would have been more effective if they had commented individually or at least be referenced by name in the American Horse Council's letter.
Comment numbers 1 through 25 were assigned to other interests (numbers 3 and 4 were omitted from the package). Four were from IMBA or biking interests and were generally supportive of the proposal; and one from Blue Ribbon Coalition recommending more liberal parameters for motorized trails. Eight were from trail runners, 'quiet use' interests, and unaffiliated hikers/backpackers -- these generally favored a primitive environment, low standard trails, and expressed a concern that trails and closed roads might be opened to 'motorized use.' Although several of these expressed a preference for low standard trails, they also referred to the trails as hiking and horseback trails. It is significant that 'none' called for 'hiker only' opportunities.
Seven comments were from trails, environmental, and wilderness organizations. Two of these are significant from the standpoint of backcountry horsemen:
1. A comment was provided by "Wildlands CPR" on behalf of 56 listed environmental or wilderness organizations. Relief sought was a 'programmatic EIS.' Specifically this comment reflected concerns over:
-- impact of the "overly rigorous nature of the proposed Design Parameters" on budgets.
-- inadequacy of the statement of "need for sweeping changes to a system that has served recreationists well for many years."
-- "racetrack-like Motorcycle Design Parameters ... displacing hikers, walkers, and bicyclists."
-- "conversion of ... closed roads ... to trails open to motorcycle use."
The comment by Wildlands CPR further recommended "A different set of standards should be developed for trails within the National Wilderness Preservation System. Trails outside wilderness are often designed for a variety of purposes and uses. Trails and related structures within wilderness are subject to a specific, narrower standard -- the minimum required to protect the wilderness." They further state as their "chief concern" the "practical application of the proposed FSM/FSH direction ... that mixed use single track trails could end up looking and feeling like highly developed motorcycle racetracks;" and go on to state that "[m]any motorized and non-motorized users value primitive trails and remote backcountry experiences."
Although, as the authors state, this comment represents "thousands of non-motorized and muscle powered recreationists," it is significant that it does not call for providing "stock free" or "hiker only" trails. It appears that the authors carefully avoided any discussion of pack and saddle stock standards in their reference to "the minimum required to protect the wilderness."
2. A comment was provided by: Conservation Northwest, Washington Trails Association, and the Washington Wilderness Coalition (Washington Wilderness Coalition was also listed in the Wildlands CPR comment). This comment expressed a concern about the "Mischaracterization and Unjustified Exclusion of Historic Wilderness Users." The comment specifically recognized the "Omission of Pack & Saddle Design Requirement for Trail Class 1" and stated that "the characterization of equestrian use as not typically a managed use in wilderness has no legal basis and is inconsistent with the historical meaning of the Wilderness Act."
This comment from the 'wilderness' constituency supporting BCHA's position on the TCS is particularly significant.
Geographical origin
of the comments from equestrians:
National 2
(BCHA & AHC)
Unknown* 4
* envelopes with return addresses were not provided, so in some cases a guess had to be made regarding the state of origin. When sufficient data wasn't provided to guess, the origin was listed as unknown.
Compared to comments from other sectors of the recreating public, the number from equestrians appears impressive. Considering the potential affects of the Trail Classification System on pack and saddle stock opportunities, however, the turn-out is disappointing. Less than ½ of 1 percent of our membership provided comment! That is really not a very impressive showing. We would probably find similar results on other major issues affecting horsemen at a national level -- such as Right to Ride.
The number of comments from mid-west and eastern states was
surprising. Members in two states with BCH
organizations did not comment --
Comments varied from many pages in length to a few
sentences. Many of the more lengthy
comments were a verbatim repeat of BCHA's comment. The shorter ones were simply a request to
preserve opportunities for stock on trails.
My guess is that the most effective ones were those that took the
information from BCHA's comments and personalized it for their local
situation. All who took the time to
comment should be commended.
Summary:
1. The preponderance of comment was from Back Country Horsemen, and other equine interests, expressing concern over the impact of the TCS on historical pack and saddle stock access.
2. Environmental, wilderness, and unaffiliated hikers and quiet use interests favor primitive and minimum standards necessary to protect wilderness, but not one comment called for 'hiker only' trails.
3. Wilderness and
trail interests in
4. The greatest concern of environmental, wilderness and unaffiliated hiker and quiet use interests relates to motorized use of trails and closed roads.
5. Both comments from environmental and wilderness interests reflect the same concern that BCHA has expressed about the inadequate statement of need to change a trail classification process that has served recreationists well for the last 100 years.
6. Hunters and Outfitters/Packers (with the exception of IOGA) were silent on the proposed classification system.
Recommendations:
1. Establish communication with key wilderness organizations mentioned in Wildlands CPR comment and discuss implications of TCS to pack and saddle stock users, and the necessity of providing suitable access trails if back country horsemen are going to support future wilderness proposals.
2. Remind the managing agencies and wilderness organizations that the Wilderness Act, subsequent wilderness legislation and the Congressional Record do not support reducing the standard of trails from that which existed at the time of designation. HR 95-540, in fact discusses improving trails to provide a quality wilderness experience.
3. Establish communication with key hunter organizations and state and national outfitter/packers organizations and discuss implications of TCS to pack and saddle stock users.
4. Schedule time at the next board meeting to explore ways of getting better involvement from BCH state and local organizations and individual members on issues of importance to pack and saddle stock users.