Management for the Eldorado Mountain/Doudy Draw area

Comments by Friends of Boulder Open Space
July 12, 2008

New trails coming to the magnificent Eldorado Mountain/Doudy Draw area
Current concerns and focus for FOBOS are to ensure that appropriate weight is given to conservation of the extraordinary natural resources in the Eldorado Mountain/Doudy Draw (EM/DD) area in the face of the proliferation of new trails there. With the new trails, scheduled for opening in autumn 2008, there will be a total of 13.6 trail-miles for all uses in the Natural Area. The Habitat Conservation Area will have a remote 1.8-mile trail for foot-travel and equestrians and a 0.5-mile climbing access trail. All trails, both old and new, in the Natural Area will be used for mountain biking.

In routing the trails, the OSMP Department has mostly followed routes drawn up by the bike/equestrian/dog user groups, with inadequate consideration for conserving natural resources. The mandate for this conservation priority has been part of the charter for both Boulder Mountain Parks and for the Open Space program from their inceptions to today under the Visitor Master Plan. FOBOS, concerned that the Department was not fulfilling the Community’s responsibility to our children and grandchildren to pass these public lands on to them in a healthy, sustainable state, has been working since last year to influence trail routing and management of these areas.

FOBOS maintains that long segments of the new trails have been very poorly located. We have documented that some trail sections go through extraordinarily diverse native grasslands, one of which includes an unusual, relict plant community, and also through critical wildlife habitat. FOBOS further raised the issue that long segments of trails would traverse potentially unstable hillslopes of shale. Because of the efforts by citizens interested in conservation, planned trail routing through one sensitive area (lower Spring Brook) was avoided, and the Goshawk Ridge trail was slightly modified to avoid a wet meadow, a section close to the upper Spring Brooks drainage, and a mountain lion kill site. Otherwise, no changes to trail routing have resulted from these.

With many more trails in ecologically sensitive areas of the EM/DD area, FOBOS has communicated to OSMP the critical need for a detailed and effective management plan that will focus on conservation of the resources while allowing public access and include: (1) baseline monitoring of the existing plant communities and wildlife populations; (2) expectations for maintenance or restoration of specific, desirable ecosystem conditions; (3) specific descriptions of unacceptable impacts; (4) and ranges of possible management actions in response to observed ecological changes and interactions among users.

Trail Study Area Plan for Eldorado Mountain/Doudy Draw
The EM/DD plan, completed in December 2006, contained some promising commitments:

  • “A detailed long-term monitoring plan with sufficient funding will be developed to guide TSA plan implementation. As part of this monitoring plan, baseline information will be collected where needed and monitoring criteria to measure success in implementing plan goals will be developed.”
  • “To provide and maintain acceptable conditions for natural and cultural resources and for the visitor experience, OSMP will devote sufficient management resources to enforce regulations dealing with seasonal and permanent visitor access closures, use restrictions for specific recreational activities, and on-trail, on-leash, and no-dog requirements. Adjustment of enforcement activities will occur over time, as needs change and levels of visitor compliance evolve.”
  • “Monitoring will be used to determine the effectiveness of management strategies to improve conditions where necessary and maintain acceptable conditions elsewhere. Measuring the effectiveness of strategies involves several steps including identifying the range of acceptable conditions, selecting indicators that will be measured, developing protocols for measuring those indicators, and then implementing the monitoring on the ground. Effectiveness monitoring often requires the collection of baseline data to formally document existing conditions before a strategy is put into action. Monitoring provides the Open Space and Mountain Parks Department with information not only to assess how well the TSA plan strategies are working, but also to refine the nature, location, or extent of implementation.”
  • And many other specific promises on these topics.

Thus the EM/DD TSA plan and Visitor Master Plan call for management that will meaningfully conserve natural resources and will determine when recreational use is causing significant impacts. Reasonable implementation of the TSA plan requires that certain critical management actions be completed before the trails are opened.

Why the current concern? Shortcomings in TSA implementation

The flurry of planning for new trail construction this year has appropriately included detailed plans, contracting documents, and clear schedules for both trail building and physical trail specifications.

Unfortunately, the same attention to detail has not emerged in connection with much of the planning on monitoring, adaptive management, staffing, standards, or staff responsibilities with regard to natural resources, user compliance with expected behavior, possible user conflicts (e.g., bike-hiker-equestrian issues), management alternatives for dealing with problems, etc.

The trails that are planned in the EM/DD area will radically change the recreational use of the area and the impact on resources. This segment of OSMP lands has historically been one of the least used and most pristine in the system, with plant communities that are unique not just in the OSMP system, but in the world, and ecologically important wildlife refugia. The promises in the TSA plan to protect and manage these treasures are critical.

Inexplicably, the promised plans to ensure adequate resource management seem, at present, to be lagging far behind the planning for trail construction.

FOBOS Responses

FOBOS has met several times with OSMP staff to express concerns about planning in these areas, and the lack of transparency in the process.

In May, we presented a set of documents to OSMP staff and the Open Space Board of Trustees that reflected our concerns and that gave a detailed set of examples of how the appropriate monitoring, planning, and management alternatives for action could be organized. We used the Limits of Acceptable Change (LAC) model that has been widely adopted by land management agencies in the U.S. and around the world, and has even been used by OSMP to set forth options for a segment of the new Goshawk trail. This model was originally developed by the U.S. Forest Service in the 1980s, and it is now used by every Federal land-management agency, as well as many local and state ones. The documents FOBOS presented included a score of specific criteria and standards, every one taken directly from either the Visitor Master Plan or the EM/DD TSA Plan. In our examples we included a decision-tree matrix that showed management responses when objectives were not met, or measured changes were not within the specified acceptable limits. The reason for the widespread adoption of the LAC model by land managers is that it provides a method to objectively evaluate the issues, take appropriate action, and manage public expectations.

The answers received from the Department lacked substance. The LAC model was deemed too complex for implementation, but no alternatives were forthcoming.

In mid June, staff created a LAC-type format for dogs in the Spring Brook area. They have put forth a list of 13 things that will be monitored — and have agreed to publicly announce and discuss standards and indicators for assessing (a) compliance with regulations on trails in the Spring Brook area and (b) sustainability of equestrian use of the Goshawk Ridge Trail. They have not yet embraced a LAC-type format or similar process for defining acceptable impacts for wildlife/natural resources, indicating that to do so would be very difficult.

As a result, at the June Board of Trustees meeting, FOBOS presented a different critique of the planning, when we emphasized the lack of documentation or any publicly revealed specifics for land management. We stressed the importance of actual detailed planning, as promised in the TSA plan.

Throughout this process, we have emphasized the need for education, a public process, and the importance of transparency. Users need to know what is expected of them, what circumstances might result in access restrictions, and what will be measured.

Conclusions

Implementation of the EM/DD trails plan requires a detailed adaptive management plan made available to the public before trails are built. To protect the resources, as mandated by the City Charter and the Visitor Master Plan, actions may have to be taken that are based on the data gathered in monitoring and on prior knowledge. A range of possible management actions in response to observed change must be specified for everyone to understand so that later conflict may be avoided.

U.S. 36, Open Space and South Boulder Creek

June 6, 2008
Mayor Ruzzin and members of the Boulder City Council
Frank Bruno, Boulder City Manager

Re: U.S. 36, Open Space, and South Boulder Creek

Dear all:

south_boulder_view
Chris Brown Photography

As we move ahead with the U.S. 36 project, Boulder is faced with choices that bear not only on how we meet our transportation needs now and in the future but also how those transportation needs are integrated with other important community values and interests. Thus the City has chosen to support continuing the BRT lane beyond Cherryvale to Table Mesa and having a flyover connection to the Park and Ride. It has chosen to support having bike lanes along the U.S. 36 corridor between Table Mesa and Cherryvale. These choices were made to accomplish city transportation objectives.

One important effect of these decisions is to substantially increase the land area that will be lost to enable accomplishment of these transportation objectives. The actual number of acres (much of it open space land) that will be converted to transportation use varies according to the alternatives but will likely be in the range of 45, with roughly half of that open space.

Moreover, these lands (open space and other lands) include the South Boulder Creek corridor in an area rich with wetlands (perhaps 15 acres will be lost). They include designated critical habitat for the threatened Preble’s Meadow Jumping Mouse (about 15 acres will be lost) and the threatened Ute Ladies-Tresses (perhaps 40 acres will be lost). They include Burrowing Owl and Prairie Dog habitat. They include lands located within the State’s South Boulder Creek Natural Area and the Colorado Tallgrass Prairie Natural Area. The US 36 crossing already chokes off the South Boulder Creek corridor, directly blocking much of its floodplain and severely narrowing the area through which the creek may pass.

OSMP staff successfully demonstrated to the Federal Highway Administration that City of Boulder open space lands qualify as so-called “4(f)” lands (the first time FHWA has recognized city open space lands as coming within that status). By federal law, 4(f) lands may only be used for a federally-funded transportation project if there is no reasonable alternative and if harm to the lands is minimized.

Friends of Boulder Open Space strongly supports the city’s proposal for a comprehensive mitigation strategy that would actually enhance the South Boulder Creek corridor as it passes through city open space. We propose development of a watershed restoration process with all interested parties involved that would return the creek and its floodplain to a healthier, more functional state. We cannot replace what will be lost by building on these high value, 4(f) open space lands, but we can offset these losses through significant improvements to the creek and its adjacent lands.

We will be following up this letter with discussions with you and with other interested parties.

Sincerely,

Larry MacDonnell

south_boulder_creek_hwy_36
Chris Brown Photography

Why Caution Is Needed

by Sharon K. Collinge

Chris Brown Photography
Chris Brown Photography

A recent letter to the editor in the Daily Camera criticized the use of the precautionary principle in management of Boulder’s Open Space by stating that “This ‘precaution’ overrides science and data in favor of policies critical of all possible human impacts.”

Put simply, the precautionary principle is an approach that seeks to avoid unintended consequences of particular actions. Rather than ‘overriding’ science and data, this principle explicitly acknowledges the centrality of scientific data to decision-making. Most importantly, it suggests a guiding strategy for managers faced with the uncertainties and knowledge gaps that will always exist in our understanding of a situation.

We will manage Boulder’s Open Space most effectively with a similar approach. Although we do not know everything there is to know about human impacts on native grasslands, forests, and streams, there is ample scientific evidence showing that increased human activities lead to environmental degradation. This warrants a cautious approach to management of our local public lands.
To avoid unintended consequences we must clearly state our intended consequences by asking, “What do we want Open Space lands to look like in the future—say 5, 10, 20, 50 years from now?” “What condition of the natural environment is acceptable?” “How do we ensure that our actions are sustainable?” If we want the status of our Open Space to be the same as it is or even better 20 years from now, then we must avoid actions that fragment, degrade, and destroy the land and its species. That’s exactly why the precautionary principle is vital in managing our valuable Open Space.

Professor Collinge is a member of the Science Advisory Group and teaches at the University of Colorado

FOBOS comments on Eldorado Mtn/Doudy Draw Trails

Submitted July 27, 2007. (All GPS coordinates (N latitude/W longitude) reported in WGS84)

INTRODUCTION
The Visitor Master Plan provided for the creation of “Natural Areas” and established as two of the goals for such areas:

  1. “Accommodate low-impact visitor activities where adequate trails exist or can be built, and resource impacts can be minimized.”
  2. “Protect the quality of natural…resources (especially where high-value resources exist).”

Thus, new trails in designated Natural Areas should be designed and constructed in a manner that minimizes their impact on the area’s natural values.

The proposed trails will introduce intensive recreation (mountain biking), along with hikers, dogs, and equestrians into a biologically rich part of Boulder City open space in which no designated trails currently exist. As an area of relatively high-elevation grasslands and forests, with extraordinarily important ecotones, along with densely vegetated drainages, the Eldorado Mountain-Doudy Draw (EMDD) Natural Area supports substantial populations of bear, elk, wild turkey, deer, small mammals and as many as 30 breeding bird species, and it constitutes recognized hunting grounds for mountain lions. Because much of the Natural Area has been without trails and off limits to dogs, wildlife populations thrive in this Natural Area, as do important native plant communities. The OSMP Inventory Report (2/24/06) points out that:

  • the xeric tallgrass communities in this and adjacent areas are unmatched in our region in terms of size, quality, and composition. “Noxious weed species pose a major threat.” (p.18);
  • the shrublands “support the highest breeding bird densities of any OSMP ecosystems…and provide habitat for bears, deer, mountain lion, and small mammals…that utilize them for food, cover, and movement across the landscape.” This area holds part of the second largest deciduous shrubland in the OSMP system, and these shrublands are “a relatively rare habitat type” along the northern Front Range and on the OSMP system and “a rare and threatened community statewide” (p.19);
  • the riparian communities “provide habitat for many animals, including bears, mountain lions, songbirds, raptors, deer, elk, small mammals, herptiles” and “undeveloped riparian corridors are becoming increasingly scarce along the Front Range and particularly in the Denver-Boulder metropolitan area” and are threatened by “infestations by non-native species” (p.20);
  • mature Ponderosa forests, another “rare habitat type along the Northern Front Range and in the OSMP system,” see regular use by Abert’s squirrels, bobcats, mountain lions, wild turkey, bear, and a wide variety of bird species (p. 21);
  • Needle and Thread grassland communities, on the rocky mesas, are another “rare and threatened community statewide.” Dalmatian toadflax and other high priority noxious weeds (like jointed goatgrass and sulfur cinquefoil) “pose a significant potential threat.” (p. 22);
  • additional invasive species (e.g., chicory, diffuse knapweed, cheatgrass, myrtle and leafy spurge) are also called out as threats because they spread along recreational trails and threaten the quality of adjacent native plant communities and wildlife in this area (p.26);
  • recreational activity along trails, especially when accompanied by dogs, displaces and decreases reproductive success of wildlife species that depend on this habitat (p.30-31);
  • species that seem to have thrived in this area, like the elk and wild turkey, “require grasslands and forests in juxtaposition, are known to only a few areas on OSMP lands, and are shy to human presence” (p.31 &33).

For these reasons, quantification of pre-trail occurrence and use of the area by these species is essential if we are to be able to assess the trails’ impacts on the natural resources and make wise management decisions as promised in the VMP (VMP p. 62-63).

It should be noted again that this Natural Area was originally and appropriately designated as a Habitat Conservation Area because of its extraordinary natural values—critical habitats and large habitat blocks not penetrated by trails. FOBOS regrets that political decisions have intervened to downgrade the area to “Natural Area”, thereby opening the door to inappropriate intensive recreation and a rapid proliferation of visitors without adequate prior study to provide a baseline for comparison with the inevitable and deleterious impacts to the natural resources that will come with the increased use, the variety of ecosystems that will be fragmented, and the native species that will be affected.

The challenge for the community and the City is to provide for reasonable and well managed visitor access while allowing the native flora and fauna to sustain themselves and to protect the area’s priceless natural values. Alignment decisions should be based on selecting alternatives that achieve some reasonable degree of resource conservation. We present here several alternatives that have not yet been considered and that would lessen ecological damage compared to options presented by the OSMP documents dated July 3, 2007 while still providing a good visitor experience.

FOBOS regrets OSMP’s plan to build trails before staff has established baseline information with respect to the existing condition of the habitat and the resident plant and animal communities, as promised in the Dec.8, 2006 TSA Plan. We strongly urge OSMP to follow that Plan and sound land-management practices and, prior to trail building, to establish monitoring programs that will develop this information and will describe remedial management actions that will be utilized should impacts exceed levels defined as acceptable. We also recommend that this monitoring be used to track impacts of the increased visitation associated with the trails and that management actions be taken, as needed, based on the definitions of acceptability.

SUMMARY OF RECOMMENDATIONS

  • Do not construct a trail in Spring Brook Meadow. Several alternative routes for Trail 13 and connecting stems are described below.
  • Delay construction of trails in the northern section (the 13s–upper, lower, stem). These trails are deeply flawed, as described below. More time is needed to determine their impacts and to consider alternative routes, some of which are proposed below.
  • Minimize placement of trails along the forest/grassland ecotones. These areas are well documented as uniquely important habitat for many animal species. The proposed trail alignments for both 13 and 14 tend to follow the ecotones for much of their length.
  • Consider a modified version of upper 14. Both upper and lower 14 would cut through an important and highly valuable forest/grassland ecotone as well as interior forest and consequently are highly disturbing. Upper 14 appears to have fewer deficiencies, and we recommend a modified version of it (described below) over any version of lower 14.
  • Avoid trail placement along side slopes with unstable soils. The proposed alignments include substantial segments that would traverse hillsides with considerable slope and with highly fragile soil types. There are significant construction issues as well as user safety issues associated with such segments.
  • Begin monitoring immediately. Our preference is that construction of a modified version of upper 14 proceed after sufficient monitoring is completed, and be connected to Doudy Draw with an alternate alignment that we propose. See Alternative route for Stem Trail proposed below. The use of Trail 14 would be observed for a sufficient length of time to assess its effects on wildlife, trail sustainability, and compliance. Such observations should inform decisions about the possibility of other trails in the subarea.

FOBOS again requests a monitoring plan that

  • will provide critical baseline information on the alignments of any possible trails, and
  • will be carried out for at least one year before construction begins.

FOBOS requests that, before trails are built, the OSMP Department provide detailed documentation about procedures for monitoring user impacts and how/when impacts would be used to trigger management decisions, including temporary or permanent trail closure, based on the definitions of acceptability (see VMP p. 62-63). The public should be involved in the formulation of these definitions, as promised in the TSA Plan.

  • Minimize trails in riparian areas. Very few generally undisturbed riparian areas remain in OSMP lands and the negative impacts of trails in riparian areas are well documented. Consequently all routes that must cross riparian drainages should be routed perpendicular to the drainage and, where desirable, include a bridge that directs visitor travel and prevents riparian access.
  • Given the extent of invasive weed cover in Doudy Draw, weed control must occur prior to any Doudy Draw Re-Route and prior to the start of trail building up “Trail 13 – Stem” or our “Alternative route for Stem Trail” and on through this area. The potential for weed invasion – both during construction and through visitor use – also underscores the need for pre-construction monitoring so that the kind of measures promised in the VMP (e.g., see p. 63) and TSA Plan can be fulfilled.

FOBOS’s current understanding of the initial controlled experiments on jointed goatgrass at the mouth/lowest segment of Doudy Draw is that full scale control application of the tested herbicide could begin this fall. OSMP would then have information on whether these efforts were successful in spring of 2008, well before any construction should begin on the reroute of the Doudy Draw Trail. If our understanding is correct, these results would provide reasonable data on control of at least one of the invasives that are particularly problematic in the TSA and should be applied to additional segments of Doudy Draw and to social trails with high priority invasives prior to construction of new trails.

GENERAL COMMENTS THAT APPLY TO ALL TRAILS AND THE PLANNING PROCESS

Enormous ecological value and function will be lost from development of trails in the Doudy Draw/Spring Brook sub-area. A summary of some ecological damage and losses is presented below for proposed trail sections. The Trail Suitability Analyses give short shrift to this, not even using the information contained in the Inventory Report for the TSA.

The currently proposed main trail alignments (upper and lower 13 and 14) track long sections of the ecotone along the top/edge of pediment terraces, cutting off habitat upon which wild turkey, deer, elk, and other wildlife depend. These routes can be expected to affect turkey, deer, and elk populations, but much-needed pre- and post-monitoring is required to quantify the effects. Effects on forest nesting birds, particularly forest raptors also need to be monitored.

The proposed trail alignments repeatedly cross riparian areas and shrub communities. This configuration will draw visitors into these areas, which now provide important habitat for diverse species, as highlighted in the OSMP Inventory Report (see page 1 of these comments). The impact will be significant, since these trails are being planned as multiple-use trails: hikers, mountain bikers, equestrians, and dogs (on Trail 13), many of which can be expected to be off-leash, based on compliance data gathered so far by OSMP.

The trail alignment process has been rushed, and this rapid pace is unfortunately leading to poor choices. Some important alternative routes have not been considered in the haste to build trails during 2007 that will have permanent, detrimental impacts and bring additional visitors into the area. OSMP staff and the public should not be forced by political considerations to choose among inadequately studied, poorly conceived routes.

There is a lack of sufficiently detailed knowledge of natural resources along trail alignments and at the scale of impending impacts. (Prior to public comment on alignments, baseline monitoring plots have been established and data collection has begun along alignments which may not be the final/best routes.) This shortcoming stems from two factors: (1) Lack of specific monitoring. (2) Absence of detailed maps to guide decisions. The excellent Inventory Report did not consider resources at the trail scale—the scale of impacts caused by trails, ecotone disruption, and visitor behavior.

Sound planning would use newly developed maps that include the full range of resources that are typically considered in siting trails (e.g., wildlife presence and needs, ecotones, and invasive plants, soils, and geology [including scarps and slumps from landslides], as well as plant communities and areas of rare plants that are already mapped) all at the appropriate scale for planning routes and making decisions.

Some trails will funnel visitors (including a predictable proportion of off-leash dogs) into pristine areas of special, irreplaceable ecological values (e.g., Spring Brook area—mature forests, ecotones, and rare and relict terrace grasslands on the ancient pediment surface).

The proposed trail plan would promote increased off-trail travel into these pristine areas. As examples:

  • the trail through the southern part of Spring Brook meadow (brown on OSMP map) will feed an off-trail “desire line” down the meadow to Fowler Trail East and up the meadow to link with the Goshawk Ridge Trail bridge;
  • the proposed brown “ramp” from upper/lower 13 into Spring Brook area that parallels and is close to the stream bottom will invite visitation into the bottomlands, especially along the many gently sloping deer trails (widened by recent horse travel);
  • many short-cuts to link more directly to trail segments; those shortcuts will be used to avoid long, gentle, looping stretches of trails;
  • many tempting pathways into native grasslands, mature forests and riparian areas from upper 13.

FOBOS is concerned about safety issues and user conflicts — mountain bikes, dogs, hikers, and horses on very narrow trails, long parts of which will be cut into and run along very steep side-hills that make it difficult at best to step off the trail to give way for visitors that have the right-of-way. As another safety issue, it should be noted that this area is used by lions for deer hunting, always in-season.

Soils and substrates for most of the area have not been taken into account. This problem bears on suitability and sustainability of long sections of trails (much of upper 13 and upper 14, as well as all of lower 13 and lower 14 below the flat terrace surfaces).

The design of trail routes has been strongly controlled by topography and by limited criteria for construction standards. Routing along gentle grades results in unnecessarily long stretches of trails through important wildlife habitat and grasslands that are highly sensitive and vulnerable to plant invasion including spread of noxious weeds. In addition, the attempts to create ‘sustainable’ trails by limiting climbing grade and possible ponding of water are negated by the choice of routes that cut for long distances across very unstable side-hill slopes of Pierre Shale—the very opposite of sustainable.

COMMENTS ON OSMP PROPOSED TRAIL ALIGNMENTS
Spring Brook area We recommend no trail in the Spring Brook area (such as “Trail 13- Spring Brook”) for the following reasons:

Exceptional habitat for deer and elk; possible presence of Preble’s Jumping mouse; lion hunting grounds; vulnerability to weed invasion, as demonstrated by high-priority weeds (such as Dalmatian toadflax and Sulfur cinquefoil) along the social trail.

Funneling visitors into Spring Brook will inevitably promote off-trail travel throughout the area, including the length of the meadow along the desire-line northward.

FOBOS requests that, if a trail is constructed in the Spring Brook area south of the meadow (as shown in brown), OSMP make and articulate detailed plans about (1) how it intends to control human, dog, and horse travel in this area; and (2) the conditions that would trigger trail closure if compliance is lacking.

“Ramp” Trail (shown on the OSMP map in brown) from Lower & Upper 13 into Spring Brook
A major problem with this alignment is the long “ramp” (about 1000-feet long, from top of terrace [pediment] surface gradually down into drainage) that traverses the steep wall. Most of this track generally parallels and is very close to the bottomland and offers continuous opportunities and temptations to drop off the trail down into the riparian area. Maintaining on-trail travel through here is merely wishful thinking. The route is also on unstable substrate of Pierre Shale.

The 13s
Lower and Upper Trail 13 have many failings (only some of which are adequately described in the Trail Suitability Analysis) and are unsuitable because they would:

  • result in excessive ecosystem degradation (incursions into several high-quality native grassland assemblages that are rare in the OSMP system and that could be avoided) and would unnecessarily fragment habitat;
  • provide pathways for invasion by weed species unless major control efforts are initiated prior to construction;
  • be built on unsuitable substrate that could be avoided, leading to an unsustainable trail (especially most of lower 13);
  • unnecessarily promote off-trail travel.

More details and documentation follow: Lower 13 cuts through large areas of otherwise uncommon and extraordinary grassland that includes at least 8 species of native grass and a native sedge (listed in appendix A).

Both upper 13 and lower 13 traverse across the old pediment and cut the relict native grassland that includes mountain muhly, a relict species in an extremely rare setting. This small area of less than about 10 acres should be protected. Trails can and should avoid passing through (as in several earlier plans) or even close to this habitat. Lower 13 also would pass by a prairie dog colony on the pediment that is expanding south.

Both upper and lower 13 will cut through an important and highly valuable forest/grassland ecotone as well as interior forest and consequently are highly disturbing.

Lower 13 is mostly on very step side-hill, with unstable shale substrate, that includes shrubland and native grassland communities (as described on page 1 of these comments).

Upper 13 offers many temptations to drop off the trail into riparian areas. The long track of lower 13 up the drainage will promote short-cutting across the drainage.

Trail 13 – Stem would be highly damaging to native grassland and to the riparian area, through which it cuts. There is the important question about the wetlands permit that is stated in the Suitability Analyses. Since this is one of very few drainages in the OSMP system that do not have trails in them, any crossings, if permitted, must take the least invasive route.

Nearly all of 13 Stem is unnecessary if lower 13 is not selected (see Alternative route for Stem Trail below.)

The 14s

Both trails would fragment habitat. Both upper and lower 14, as proposed, will cut through an important and highly valuable forest/grassland ecotone as well as interior forest and consequently are highly disturbing.

Lower 14 is mostly on a very step side-hill, with shale substrate, that includes shrubland and native grassland in places. In addition, as the OSMP Suitability Analysis points out, it may entice visitors into the Lindsay Pond and Bull Gulch areas.

Upper 14 cuts along the forest edge and wipes out a huge part of deer bedding ground in the area.

Of the two 14 alignments, Upper 14 is preferable – if only because its location will not allow visitors to look down on and be enticed to go to Lindsey Pond. As mentioned it will eliminate a substantial part of the ecotone – and wildlife’s access to it.

FOBOS TRAIL ALIGNMENT ALTERNATIVES
**Our first preference, as noted on p. 3 above, is to build Upper 14 and an Alternative Stem Trail once Doudy Draw high priority weeds are under control and baseline monitoring has been completed; to intensively monitor the impact of visitor use on these trail segments and use the results to inform decisions regarding the other ecotonal areas to the north and west; and to continue to explore options for Trail 13 alignments.

**Our Preferred Alternative route for Stem Trail (shown on Map 2)— from Doudy Draw to trails 13/14:

Connect with “Trail13 – Stem” at a point (39.92380/105.26014 [Map 2, STEM1]) close to the saddle (where it breaks from “potential Doudy Draw Re-Route”), continue in a route southwest and west to intersect with the junction of Trail 13 – Stem and Lower 14 at (39.92170/105.26331 [Map 2, STEM6]). Intermediate locations, connected by looping “as needed”, are:

  • 39.92319/105.26174 [STEM2], crosses first minor gulley to the west;
  • 39.92334/105.26226 [STEM 3], on ridge between the two drainages in the vicinity;
  • 39.92257/105.26208 [STEM 4], crosses railroad grade;
  • 39.92182/105.26229 [STEM5], on upper part of ridge.

A route similar to this will likely become a social trail anyway to move visitors directly to a 14 trail from the saddle.

**Our Preferred Alternative for Trail 13 is 13A (not shown on map) – Route 13A uses the existing, abandoned railroad (RR) grade to go northward from our “Alternative route for Stem Trail” around the terrace/mesa. We have investigated this option and found no conservation easements or legal constraints to prevent it. Staff has stated that there is a concern with a “spring”. A fence now separates the spring (which we believe to be the Spring of Concern) from the railroad grade where the two are in proximity. Bridges would be needed over the creek crossings, but use of the existing roadbed would avoid problems with the Pierre Shale. In addition, this route offers spectacular views, and many opportunities for interpretation – e.g. landscape level ecology and possibilities for highlighting different biological community types, geological formations, geomorphic features, watersheds, human history and land-use patterns. In addition it offers a trailbed that is: wide enough for the proposed multiple uses allowing safe passage; an existing human-constructed substrate so that new construction can focus on providing a durable trail surface, adequate drainage, bridges to connect segments of roadbed; and a route without major rare, sensitive, imperiled habitats, biological communities, or species of concern. Our proposed route goes from the RR grade to the west through the trees north of Spring Brook and crosses the brook at a place without dense shrub communities. We propose a bridge over the brook at this point with appropriate fencing/structures to both direct visitors to the connection with the “Fowler Trail East” roadbed (at a spot a short distance north of the hairpin turn and the start of the existing social trail) and to keep visitors from going down into the creekbed.

Advantages of Route 13A: This alignment would avoid the rare and threatened grassland communities on the mesa top, leave the Spring Brook meadow and the large block of mature Ponderosa forest and grasslands-forest ecotone unfragmented, minimize impacts to riparian crossings, and address the threat of the intrusion of invasive species into this rare habitat. In our view this is the only “13” route that will lead to fulfillment of the TSA Plan’s promise that “trails will not be built that would critically fragment large habitat blocks or create impacts to highly sensitive areas.”

Alternatives to OSMP Trail Alignments IF OSMP Proposed Trails must be built:
Route “Trail 13 – Springbrook” southward, staying east of Spring Brook and above it. Connect with Water Board Road east of Spring Brook. The part of the trail north of the current fence (currently grazed area) should be designated as “on-trail” only.

If “Trail 13 – Springbrook” must be routed across Spring Brook, a trail could easily have a more direct ingress into Spring Brook from the east, requiring steeper trail, perhaps with one or two switchbacks. Points on the terrace at which Upper 13 could drop off the terrace and join the “ramp” on a gentle grade (N lat/W long) are:

  • 39.92226/105.26909
  • 39.92245/105.26902 (connecting to the ramp at 39.92244/105.26922)

These points are shown as R1, R2, and R3 on Map 1, attached.
Alternative route for “Trail 13 – Upper” if that route must be built – (see red dotted line on Map 3, below) – if this alignment is chosen we prefer that it be placed further south than currently flagged to avoid rich, native grassland on the old pediment. (GPS points are given in Appendix B that could define this route [shown on Map 1 as 13ALT1 and 13ALT2]). This trail should also stay on the east side of Spring Brook and proceed south to the Denver Water Road.

MORE ABOUT SAFETY ISSUES:

  • Much of the proposed trail system will traverse steep hillsides (i.e., be cut into side-slopes of as much as 23 degrees). Unless trails are very wide, there will be little room to maneuver to avoid bikes, dogs, and horses that require wide passage. We note that staff has indicated trail width to be mostly about 30-inches wide, not enough room for other visitors to avoid horses.
  • Moving off-trail on the uphill side to avoid contact will be difficult for all but the most agile, and moving quickly off-trail on the downhill side would be treacherous for small children and those of limited mobility. For all visitors, agile or not, moving off trail will cause erosion on this loose slope.

SOILS AND GEOLOGY ISSUES:

Long stretches of the trail system are proposed for slopes in shale that are now unstable or that will likely become unstable and deeply eroded within a short period of time, unless engineered to stabilize at high cost and with significant impact. Overall, the costs of building and maintaining the trails would appear to be much higher than estimated.

  • Most of the proposed routes between Doudy Draw and the terrace surfaces to the west are in shale, and major segments of these tracks (lower 13 and lower14) are to be constructed with side cuts into steep slopes of shale.
  • Long, continuous sections of trails lower 13 and lower 14 would incise shale and slumped shale slopes between 18 and 23 degrees.
  • There is very high probability of undercutting slopes and initiating new slumps (unless uphill sides are anchored and buttressed). Staff indicated on the field trip (July 19, 2007) that upslope walls as much as 2-3 feet will result from trail building on these steep side hills.
  • Other long, continuous sections of trails 13 and 14 traverse the shoulders of terraces—the boulder-strewn, very steep hillsides (also on about 20-degree slopes) just below the terrace surfaces. Shale underlies these areas, as well. The cobbles and boulders are simply resting on the shale—they do not form a gravel surface as they do on the mesa top.

OTHER GENERAL COMMENTS

Trail routes are driven dominantly by three factors: (1) grade, (2) drainage, and (3) visitor experience, at the expense of natural values and resources.

The Suitability Analyses are very weak with respect to natural resources of wildlife and plant habitats, and the links between the two appear lacking.

Prevention of the spread of weeds and invasive plants is inadequate. Large sections of weeds on the paths into this area should be controlled before building these trails. Otherwise, there will be direct and immediate influx of weed seeds by many vectors (not just by trail construction, the only vector mentioned in the Suitability Analysis).

The planned trails will inevitably and unacceptably harm natural resources in the affected Natural Area. The trail layout will funnel visitors into highly sensitive and attractive landscapes, thereby directly promoting off-trail travel into these lands. There are alternatives that would be preferable environmentally and still provide an excellent visitor experience.

CONCLUSIONS

FOBOS believes that there is much room and opportunity for improvements to the trail alignments as currently flagged, and as presented on the public hike. FOBOS hopes that OSMP will consider closely our recommendations and alternative routings that would minimize ecological damage to the Natural Area and that may well cut trail-building and maintenance costs.

The current plan could be greatly improved by bringing together existing and new knowledge about valuable wildlife and plant resources to inform decisions. Moreover, a few important and viable options have not been considered.

FOBOS is deeply concerned about impacts of the proposed trails on wildlife and their habitats, as well as on native plant communities. Because of the lack of systematic monitoring of many critical ecological factors for at least a full year following route decisions and prior to the proposed 2007 trail construction, data are inadequate to assess with accuracy some of the impacts on species such as elk, bear, cougar, and turkey. In addition, the data are inadequate to determine acceptability levels and standards that will trigger future management decisions (see VMP). Further, the TSA Plan (Dec 8, 2006, p. 23) states that “more information will be needed where trails are proposed.” Without this, it will not be possible to “protect rare, imperiled, and highly-vulnerable resources,” “prevent the spread of invasive weeds,” “maintain viable habitats for the native plants and animals,” and “detect unintended impacts early…(to) ensure impacts to important resources are avoided, minimized and mitigated” as promised in the TSA (pp.8, 9, and 15).

Finally, FOBOS believes that this trail-building plan could be improved in many respects to bring trail alignments into compatibility and consistency with the stated importance and concern regarding conservation of valuable natural resources in the Natural Area. Many of the OSMP options on the table are unreasonably out-of-balance in favoring intensive recreation and the human visitor over the exceptional natural values in the Doudy Draw/Spring Brook subarea.

The plans for trails 13 and 14 are in many ways inconsistent with following stated guidelines and goals for Natural Areas in the Visitor Master Plan:

  • Accommodate low-impact visitor activities where adequate trails exist or can be built, and resource impacts can be minimized.
  • Protect the quality of natural …. resources (especially where high value resources exist).

High value resources do exist in the Doudy Draw/Spring Brook subarea, as documented in the Inventory Report and with subsequent observations by OSMP staff and volunteers.

The trail plan should be revised to provide for conservation of these priceless natural resources.

Appendices:
Appendix A

  • Native grasses and sedge in Lower 13 trail path
  • Big bluestem Tall dropseed (Eastern prairie [sporabalus])
  • Prairie dropseed (Eastern prairie [sporabalus])
  • Blue grama Mountain muhly (in relict, rare grassland on very old pediment surface)
  • Western wheatgrass
  • Sun sedge
  • June grass
  • Agassiz bluegrass

Appendix B

GPS points that define alternative routing of Trail upper 13 further south than currently flagged to avoid rich, native grassland on the old pediment. Points are east to west from current flagged route to the Water Board Rd.

  • 39.92136/105.26614 [Map 1 13ALT1], east end of alternative route at flagged tree
  • 39.92140/105.26824 [Map 1 13ALT2], west end of burned area (mostly open forest and healthy grassland) to Water Board Rd. north of bridge site.

This route achieves a loop trail. It also stays on the terrace surface more than about 30 m away from its edge above the Spring Brook area.

Goshawk and Mickey Mouse Trails

Concerns and questions submitted by Friends of Boulder Open Space (FOBOS) June 6, 2007. (All geographic coordinates in WGS84)

Summary
The Visitor Master Plan provided for the creation of “habitat conservation areas” (HCAs) and established as one of the goals for such areas: “Provide public access and passive recreational opportunities that foster appreciation and understanding of ecological systems and have minimal impacts on native plant communities and wildlife habitats or other resources.” Thus, new trails in designated HCAs should be designed and constructed in a manner that minimizes their impact on the area’s natural values.

The proposed Goshawk Trail will bring hikers and equestrians into one of the most biologically rich parts of Boulder open space. An area of relatively high elevation meadows and forests traversed by drainages coming off the foothills, the Eldorado Mountain-Doudy Draw (EMDD) HCA supports substantial populations of bear, elk, deer, and mountain lions and provides important habitat for a wide variety of birds including flammulated owls as well as northern goshawks. Because it has been relatively inaccessible, wildlife populations thrive in this HCA, as do important natural plant communities.

The challenge is to provide for reasonable visitor access in a manner that is as compatible as possible with the area’s especially important natural values. Alignment decisions should be based specifically on choosing the most ecologically favorable alternative. Quality of the visitor experience, while important, should be secondary.

FOBOS regrets OSMP’s decision to build the trail before staff has established baseline information respecting the existing condition of the habitat and the resident plant and animal communities. We hope OSMP will follow through on its promise to establish monitoring programs that will eventually help to develop this information and will describe management actions that will be taken if impacts exceed levels defined as acceptable.

We also hope this monitoring will be used to track impacts of the increased visitation associated with the trail and that management actions will be taken, as needed, based on the definitions of acceptability.

Ecologic and conservation issues:
Wildlife issues:

Impacts on habitats for elk, mountain lion, bear, deer from increased visitations and fragmentation of habitat. Even available information does not appear to be considered in the assessment of trail suitability factors. Surprisingly, critical observations made in the Inventory Report for the EMDD TSA are not mentioned in the current Trail Alignment Suitability Analysis (5/18/07). As one example, the Trail Alignment Suitability Analysis ignores the importance of this HCA as “one of the only corridors for seasonal Elk migration in the County” (Inventory Report, p. 31). More information and better use of existing knowledge are needed to make informed decisions.

Birds. Northern goshawk and flammulated owl are among species that require habitat protection. In the TSA Inventory, flammulated owls are described as, “a species of special concern…[that]…have been observed in the Spring Brook drainage where they probably breed…”. This critical observation is not mentioned in the Trail Alignment Suitability Analysis. Similarly, knowledge about the northern goshawk is available, but such information does not seem to have been digested and applied by the responsible OSMP Managers. The HCA also harbors many other raptors and wild turkey. More information and better use of existing knowledge are needed to make informed decisions.

Rare plants— Assessment by OSMP is needed of the types, locations and extent of Rare and Sensitive plant communities along proposed routes. Critical information is missing in the Trail Suitability Analysis (for example the Big Bluestem communities in the upper meadows are not mentioned).

Biologic soil crust—more observations by OSMP or other experts are needed along proposed routes.

FOBOS recommends that OSMP’s Inventory Report be updated and supplemented with observations of local naturalists, OSMP volunteers, and visitors familiar with the area to identify mountain lion hunting grounds, raptor and bear foraging areas, nest sites, etc., so that these areas can not only be avoided but also accurately used in identifying suitable routes through this HCA.

Trail suitability issues
FOBOS supports trail option 2B as the least environmentally harmful option of the “twos”. The northerly sections of 2B provide outstanding views and a route through two ravines and varied vegetation around ridges. The other options would increase habitat fragmentation and impair unique open meadows. We favor track 2B on the basis of its distance from prime wildlife habitat that would be sliced by track 2C.

If trail 2B is constructed we recommend a short spur (just a few 10s of meters long) from the northernmost switchback to the top of the hogback ridge at N 39.9237 deg., W 105.2749 deg. to afford excellent views of Eldorado Mountain, South Boulder Peak and Bear Mountain to the northwest, and panoramic views eastward.

FOBOS is adamantly opposed to 2C, on the basis of, first, avoidable and unnecessarily long incursions into important habitat; this segment has been promoted by OSMP Management as offering a nice visitor experience with good views, and it “passes through a diverse variety of habitats” (Trail Alignment Suitability Analysis, p. 2). Furthermore, the curving and looping of the route “adds (sic) mystery” (ibid, p. 2). FOBOS believes that “adding mystery” is not adequate justification for creating more ecologic damage by lengthening trails.

Track 2C also maximizes environmental degradation by slicing this varied habitat, including mixed shrub and forest (foothills deciduous shrubland) on unusual and rough boulder-strewn substrate, with excellent water-retention capacity, over much of its length. The Trail Alignment Suitability Analysis fails to mention that “foothills deciduous shrubland is a rare and threatened plant community statewide” because it serves as “habitat for a rich diversity of birds and mammals” (Inventory Report for the EMDD TSA, p. 19). The Trail Alignment Suitability Analysis even fails to mention the presence of foothills deciduous shrubland.

Track 2C also fails on the basis that it is now nearly free of “priority” weeds; new trail construction would greatly increase the likelihood of noxious plant invasion to the area (Trail Alignment Suitability Analysis, p. 6).

FOBOS recognizes the challenge of routing around the “2A meadow” while providing realistic access to Mickey Mouse Wall in a track that would be used by climbers. We are concerned that many climbers will short-cut the long path to segment MM-1B by any access (2B or 2C). FOBOS urges close consideration of another option that would mitigate some of the unjustifiable damage of track 2C and allow more direct access to Mickey Mouse Wall:

Retain the existing social trail MM-1A from the 2A/2B/2C junction to the barbed–wire fence. This route is on a moderately gentle slope close to the ridge crest and is characterized by an easily navigable path on rocks and boulders of a range of sizes. These boulders provide excellent protection from erosion. The trail here has been used as climbing access for at least 30 years and is in excellent condition with little signs of wear. Make a short connector from the barbed-wire fence (N 39.92268 deg., W 105.27916 deg.) to proposed 2C (at approximately N 39.92260 deg., W 105.27947 deg.). Such a connector would require only about 20 meters of trail and is likewise on a gentle slope with well-set boulders and rocks that create a natural and excellent surface to buffer run-off and human traffic.

Please compare the costs of this alternative (20-meters length up gently sloping, stable ground) to the cost for the meandering section of 2C (more than 900-feet or about 280-meters long on mostly heavily vegetated, steep sided slopes) that could be eliminated by this alternative route.

This 2C detour would by-pass the steepest part of track MM-1A where it slices an exquisite stretch of the main meadow. At the point where this 2C detour gains elevation to intersect trail MM-1A, trail MM-1A would continue southward. At this point, trail MM-1A becomes gentler and could then remain the main climbing access route, perhaps with a few water bars, as needed. This continuation of MM-1A should be closed to horse travel to prevent erosion.

Having a suitable climbing access on the westerly side of the meadow (MM-1A) would then completely eliminate the need for trail MM-1B, thus sparing more cost and invasion of forest habitat.

If 2C is built, we propose moving this trail higher in elevation above its current east-west flagged route across the upper part of the “2A meadow”. Such relocation would serve two purposes: (1) avoiding a dense shrub community of snowberry and (2) moving visitors farther from the temptation of heading directly down the axis of the meadow below.

FOBOS is strongly opposed to segments 3A and 3B & 3C, on the basis of needless and preventable incursions into important meadow habitat that includes the presence of big bluestem community.

FOBOS supports route 3D as the least damaging of the “threes” on approach to Spring Brook.

FOBOS recommends close attention to proposals for routes that avoid any crossing of North and South Spring Brooks by making a trail around the southward nose of the prominent Dakota hogback ridge and staying north of Spring Brook. We acknowledge that such a route may parallel North Spring Brook drainage for several tens of meters. We recommend a detailed evaluation of vegetation in this stretch before accepting or rejecting these proposals.

If trails are built across Spring Brook, FOBOS favors the following options to minimize impacts:

  • 3D to 3C to 4C.
  • At 4C crossing, route the trail across South Spring Brook to go directly up and out from the bottomland, thereby eliminating the long 4C stretch along and near the creek bed.

FOBOS is adamantly opposed to segment from 3B to 4A across South Spring Brook because it would cross flammulated owl (and perhaps goshawk?) habitat and heavily used black bear habitat (based on recent observations of numerous bears in this spot by an OSMP volunteer and based on scats over a long period of time). We also oppose the 3B to 4B route that would require the 4B dogleg. FOBOS is strongly opposed to trail segment from 4B dogleg eastward along South Spring Brook, because this segment would traverse more riparian habitat than the 4C option.

Again, no matter where the trail crosses South Spring Brook (and the 4C crossing appears to be the least damaging), it should go directly up hill perpendicular to the drainage and not funnel visitors close and parallel to the bottomland as currently flagged. The same concerns about trails climbing quickly out of the North Spring Brook crossing at 3B should apply to any South Spring Brook crossing.

FOBOS proposes a new option in the “5” trails, here named 5D. Trail 5C is too close to the drainage area of South Spring Brook, and segment 5A is an ecologically unsound and unnecessarily long route that cuts prime deer and elk habitat as well as well-known lion hunting grounds. FOBOS proposes a route to the east of, and nearly parallel to, 5C to the water board road. This track (5D) should lie at least 50 m east of segment 5C and would approximately bisect tracks 5C and 5B. A route to any bridge from trail 5D (at the water-board canal) could be made by a track parallel to the canal. The presence of water adds value to the visitor experience, and this might be noted in the trail suitability analysis.

For each option adopted by OSMP, FOBOS requests written statements that document the OSMP choices as the ones that minimize impacts.

If OSMP does not choose options that clearly minimize ecologic impacts in this HCA, FOBOS requests written statements explaining why OSMP does not choose these least damaging alternatives. The options recommended by FOBOS are based on sound evidence as the least damaging alternatives (2B; 3D to 3C to 4C; direct in-and-out at the 4C crossing; 5D).

Monitoring
FOBOS has asked that OSMP develop a baseline of land and resource conditions prior to the construction of new trails so that evaluation can be made of the effects of trail uses. OSMP has decided not to do such pre-construction monitoring. We now make the following requests:

  1. An outline of ecologic impacts that OSMP will monitor and that are based on expected losses (including, but not limited to, loss of communities/occurrences of rare plants, loss of wildlife habitat, alteration of wildlife activity);
  2. Descriptions of the mechanisms for evaluation of monitoring results;
  3. Consequent management actions to minimize ecologic losses. Please describe in detail how monitoring results will drive adaptive management decisions. Please indicate what is known now (baseline information) and whether that information is, or is not, adequate for future comparison. For each monitoring topic or target (e.g., bear activity), please list criteria that require management response. Please list specific criteria that would trigger temporary or permanent trail closure.

Please describe enforcement plans to ensure on-trail travel.

Trail Uses
FOBOS supports the requirement of on-trail travel by horses at all times, on the basis that horse travel is a major cause of erosion and disturbs the land surface thereby promoting plant invasion.

FOBOS encourages restrictions on the use of this area’s trails at night. We further advocate public education and signage to inform visitors of the risks associated with mountain lion habitat. The safety hazards might also be noted in the trail suitability analysis.

FOBOS recommends that OSMP should give more attention to avoiding and conserving the stone structures in the area.

Costs
Costs are obviously an important issue to OSMP and the public. Yet it is essential to ensure that new trails are both sustainable on the basis of human use and in relation to the environment through which they pass.

FOBOS is apprehensive that cost issues may trump environmental values. Particularly in a HCA, the requirement of minimizing harm to the area may necessitate added expenses. Such expenses are fully warranted if they help ensure that human uses of the HCA are as environmentally compatible as possible.

What are the currently estimated or budgeted monetary costs to build and to maintain Goshawk and Mickey Mouse trails? Please complete the OSMP Trail Alignment Suitability Analysis (5/18/07) document by providing the public with costs of each trail segment.

What are the currently estimated or budgeted costs to conduct adequate baseline studies and monitoring of these trails?

Other questions relevant to disturbance and health of the ecosystem.

If trail base material must be imported, it will possibly contain weed seeds. Will all such material be tested for weeds before application? If not, why not?

Regarding trail construction, FOBOS strongly urges extreme care in the construction of trails to eliminate any related possibility of consequent plant invasion, with special attention to (1) timely and thorough treatment for rehabilitation of disturbed areas; (2) disposal of overburden that might be moved or removed in the process of trail construction; and (3) lessons have been learned from recent trail construction on Marshall Mesa that damaged plant communities. FOBOS recommends tight oversight of volunteers to ensure that approved alignments are followed.

Status of crossing of Denver Water canal
At present, OSMP does not have an agreement with Denver Water allowing crossing of the canal. Denver has opposed authorizing crossing at the existing bridge and has not authorized construction of another crossing. We believe it would be irresponsible for OSMP to construct a trail to the canal unless and until it has obtained legal permission from Denver Water for a crossing.

Conclusions
FOBOS believes that there is much room and opportunity for improvements to the trail alignments as currently flagged. FOBOS hopes that OSMP will consider closely our recommendations and alternative routings that would minimize ecologic damage to the HCA.

The current plan could be greatly improved by bringing together existing and new knowledge about valuable wildlife and plant resources to inform decisions. Moreover, a few important and viable options have not been considered.

FOBOS is most concerned about impacts of the proposed trails on wildlife and their habitats. Because of the lack of systematic monitoring of many critical ecologic factors in anticipation of the proposed routes, data are inadequate to assess with accuracy some of the impacts on species such as elk, bear, cougar, turkey, raptors, and owls.

Finally, FOBOS believes that this trail-building plan could be improved in many respects to bring trail alignments into compatibility and consistency with the stated purpose that protection of natural resources is the paramount issue and concern in the HCA. Many of the OSMP options on the table seem to favor the human visitor over the permanent residents of this HCA.