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  1. #1
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    Helena action alert

    The Helena Ranger District is working through the NEPA process on a project in the Helena area: the Tenmile-South Helena project. Late last year, they introduced an additional alternative to the planning process, Alternative 4. This one is a good idea since it includes some recreation planning, including some significant new trail corridors. The district has re-opened comment on Alternative 4 between 3/6 and 3/20. They are only accepting comments on non-motorized trails. This is the most specific trail-related comment opportunity I've seen here, and our comments (or lack of) will have a direct impact on what we're able to ride in the near future.

    The short version is that a small but organized and vocal group of hunters and anglers are pushing back on the trail development. They're in favor of limiting trails to old road corridors, rather than new alignments. The Colorado Mountain trail with the proposed closure date is an awesome fall ride. The 8/31 closure date is more about archery season than elk security. And maybe the biggest, but most subtle, change is the line limiting bicycles to designated system roads and trails. That needs to go. If the draft forest plan's suggested special recreation area around Helena comes through, I'd consider supporting that. But I don't see any reason to limit bikes to system routes with no other change in management.

    The project page is here. There is an Opportunity to Comment and description of the specific changes made to Alternative 4 here. And there is a map of the trails here.

    Here's how to comment:

    Helena action alert-hrd_tsh_comment.jpg

  2. #2
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    If i'm reading this correctly, the proposal is open to new trails but the small/vocal group wants that part removed?

  3. #3
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    Quote Originally Posted by fleboz View Post
    If i'm reading this correctly, the proposal is open to new trails but the small/vocal group wants that part removed?
    Not removed necessarily, but pushed into locations that aren't as favorable for recreation (hikers or bikers). For example, staying on road corridors, rather than new singletrack alignment. Or along an old ditch alignment, rather than along a ridgeline. And at the same time adding a line limiting bicycles to designated system routes. That's the most insidious part, because half the 'new' trails proposed in this project are existing non-system trails that people have been using for years.

  4. #4
    rth009
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    What exactly do you want us to say?

    That we oppose "limiting bicycles to designated system roads and trails." Anything else?

  5. #5
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    Quote Originally Posted by rth009 View Post
    What exactly do you want us to say?

    That we oppose "limiting bicycles to designated system roads and trails." Anything else?
    That's the big one.

    Comments on the nonmotorized trail system proposed are very important. The bulk of the comments received by the District are generally from wildlife advocates who are organized, motivated, and concerned about the impact of any recreation on USFS lands, and of mountain biking in particular. Therefore, it is imperative that the recreation community step up and tell the USFS that we strongly support expanding our nonmotorized trail network. The Montana Bicycle Guild has provided several talking points below. The most impactful comments will describe how important recreating on USFS lands is to you, and incorporate the thoughts below in your own words. Cut-and-paste comments don't carry much weight in the NEPA process.

    • We strongly support expansion of the nonmotorized trail network in the Tenmile-South Helena area. Nonmotorized recreation is an increasingly important aspect of Helena’s culture and economy, and the existing system is in need of expansion to accommodate it.

    • We strongly oppose the restriction of bicycles to designated system routes. This is at odds with travel policies elsewhere in the Forest, effectively creating a new management district, and a new class of regulated activity. There are many non-system routes in the project area with long histories of use by hikers, hunters, anglers, equestrians, and cyclists. Such a major and discontinuous change should not be folded into a fuels treatment project.

    • We do not oppose seasonal closures where appropriate. However, as closures are a means to protect wildlife, those closures should apply to all user groups. Closing the Colorado Mountain area to bicycles after August 31st does not protect wildlife. It is a recreation decision prioritizing other recreation uses over cycling. MBG opposes the currently proposed closure date which is too early and improperly limited to bicycles.

    Those are the major points. The other things for riders with local knowledge to consider are changes in alignment to some of the proposed trails. They moved Trail B from a ridgeline to an old flume. The flume could be kind of cool, but I think a ridgeline would be nicer. And they moved the Brooklyn Bridge trail (Trail E) to the north side of Skihi Peak, but that build will be difficult and expensive due to all the boulder fields. That alignment was considered and not chosen for that reason. We're willing to re-evaluate it, but want the potential to bring it back to the south of Skihi Peak, but passing below the identified elk security area.
    Last edited by evasive; 03-10-2017 at 03:14 PM. Reason: edited to reflect updated talking points

  6. #6
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    Thank you for posting this.
    Casey Greene - President, Board of Directors - Bikepacking Roots
    bikepackingroots.org

  7. #7
    rth009
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    Agreed. I submitted my comments.

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    done. thanks evasive!

  9. #9
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    Thanks for the heads up!

  10. #10
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    Thanks, guys. For Helena-area riders, we're having a brief Q&A to go over the proposals up for comment this evening (Wednesday). 6:00 at The Garage.

  11. #11
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    Working on a comment. The talking points here are excellent. Thanks for explaining the situation.
    I don't know what trail we're on, but at least it's getting dark

  12. #12
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    just received an emails from the forest service, they are extending the comment section. the email is below.

    The comment period for the Tenmile – South Helena Alternative 4 - Non-motorized Trail System proposal has been extended to March 22, 2017.

    A map and description of the Non-motorized Trail System proposal as well as additional Alternative 4 information can be reviewed in the attached documents and on the Helena – Lewis & Clark National Forest website at: http://www.fs.usda.gov/project/?project=45725

    Comments can be submitted by e-mail, fax, mail, or hand delivery to the following addresses:

    E-mail*: comments-northern-helena-helena@fs.fed.us
    *Please include “TSH” in the subject line.

    Fax: 406-449-5436

    Mail and Hand Delivery:
    Helena District Ranger
    ATTN: TSH.
    2880 Skyway Drive,
    Helena MT, 59602

    Additionally, an update to the Tenmile – South Helena project website has recently occurred that resulted in changing the appearance and layout of documents. Before the update, all documents appeared on the same website page. To locate documents on the updated project website, click on the Tabs (Scoping, Analysis, or Supporting). Documents for the Alternative 4 Non-motorized Trail System Proposal are located under the “Supporting” tab and are labeled:

    • (March 6, 2017) - TSH Alternative 4 Opportunity to Comment on the Proposed Non-motorized Trail System (pdf)
    • (March 6, 2017) - TSH Alternative 4 Proposed Non-motorized Trail System Map

    For questions please contact the Helena Ranger District at: (406) 449-5201.

  13. #13
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    I now can't locate the map online. Seems HLCNF has taken it down prematurely. I wanted to restudy the SkiHi Peak portion of the trail proposal. It looks like extraordinarily difficult terrain to put a trail in no matter what the alignment. At any rate, the bottom line looks like one group not wanting to share, and conspiring to muddle up a good plan.
    I don't know what trail we're on, but at least it's getting dark

  14. #14
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    Quote Originally Posted by GregB406 View Post
    I now can't locate the map online. Seems HLCNF has taken it down prematurely. I wanted to restudy the SkiHi Peak portion of the trail proposal. It looks like extraordinarily difficult terrain to put a trail in no matter what the alignment. At any rate, the bottom line looks like one group not wanting to share, and conspiring to muddle up a good plan.
    It's still there. They split the project page into different tabs. Look under the "Supporting" tab. The original Alternative 4 trails are on the map dated 11-15-16. That alignment wouldn't be that bad to build, especially if you used the hillside to the west above Cox Lake on the lower end - I've hiked it the whole way from the lake to the road.

    https://www.fs.usda.gov/project/?project=45725

    Here's the current map:
    http://a123.g.akamai.net/7/123/11558...T3_3963083.pdf

  15. #15
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    Thanks for the link, but when it's opened all that is there are scoping letters. At least now I can view the Alt 4 map. Yes it would be great to compare to the previous map, but I've been trying to locate that map for an hour with no luck.
    I don't know what trail we're on, but at least it's getting dark

  16. #16
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    Quote Originally Posted by GregB406 View Post
    Thanks for the link, but when it's opened all that is there are scoping letters. At least now I can view the Alt 4 map. Yes it would be great to compare to the previous map, but I've been trying to locate that map for an hour with no luck.
    Can you see the "Supporting" tab on your browser? Those links are under it.

    Helena action alert-noname1.jpg

    Here's the link to the original Alternative 4 trail/road closure map:
    http://a123.g.akamai.net/7/123/11558...T3_3906125.pdf

  17. #17
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    OK I'm an idiot at times. I finally found the tabs. Those shaded headers didn't appear as the type of tabs I'm used to seeing, so I was blind to them.
    I don't know what trail we're on, but at least it's getting dark

  18. #18
    rth009
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    Just got this email, looks like they chose Alternative 4:

    Dear Interested Party,

    The Helena Ranger District of the Helena – Lewis and Clark National Forest has released the Tenmile – South Helena Final Environmental Impact Statement (FEIS) and Draft Record of Decision (DROD). The DROD, FEIS, and other supportive material for this project are available to review online at the Forest’s project website: https://www.fs.usda.gov/project/?project=45725.

    The Tenmile – South Helena Project area including all ownership is approximately 61,395 acres in size and is located in the following drainages: Upper Tenmile Creek, Middle Tenmile Creek, Lower Tenmile Creek, Lump Gulch, Last Chance Gulch and Middle Prickly Pear Creek. The project is on the Helena Ranger District, located within all or part of the following: T10N, R6W Section 36; T10N, R5W Section 31; T10N, R4W Sections 31-32, 34-36; T9N, R6W Sections 1-2, 11-13, 23-26, 35-36; T9N, R5W Sections 1, 6-36; T9N, R4W Sections 1-24, 26-35; T8N, R6W Sections 1-2, 11-14, 23-26; T8N, R5W Sections 1-12, 14-22, 29, 30; T8N, R4W Sections 5-8; Lewis & Clark and Jefferson counties, Montana.

    The Forest Supervisor is planning to implement alternative 4 (Preferred Alternative) with minor modifications, which would treat 17,848 acres in the project area with a combination of improvement harvest (1,344 acres), precommercial thinning (353 acres), regeneration harvest (2,527 acres), private land buffers (4,787 acres), shaded fuel break (1,647 acres), and low severity prescribed fire (7,190 acres). Connected actions for the draft decision include 13 miles of temporary road construction (followed by full obliteration), 14 miles of road maintenance, 28 miles of road reconstruction, 59 miles of non-system road decommissioning/closure, improvement of 17 road/stream crossings, and 18.5 miles of new non-motorized trail will be authorized. Approximately 1/3-mile of Forest Service System Road 299 would be reconstructed in its current location and elevated to provide for improved road drainage and drivability as well as restoration work to an adjacent wetland. Also included is restoration of native westslope cutthroat trout in two tributaries of Tenmile Creek.

    This project is subject to 36 CFR 218 (The Objection Process). Objections will only be accepted from those who have previously submitted specific written comments regarding the proposed project during scoping or other designated opportunities for public comment in accordance with 36 CFR 218.5(a).

    Issues raised in objections must be based on previously submitted timely, specific written comments regarding the proposed project unless the issue is based on new information arising after the designated comment opportunities.

    The following address should be used for objections sent by regular mail: Objection Reviewing Officer, USDA Forest Service, Northern Region, 26 Fort Missoula Road, Missoula, MT 59804.

    Objections sent by private carrier or hand delivery must go to: Objection Reviewing Officer, USDA Forest Service, Northern Region, 26 Fort Missoula Road, Missoula, MT 59804. Office hours are Monday through Friday, 8:00am to 4:30pm, excluding Federal holidays, for hand delivery.

    Objections can be faxed to the Objection Reviewing Officer at (406) 329-3411. The fax coversheet needs to include a subject line with “Tenmile – South Helena” and should specify the number of pages being submitted.

    Electronic objections must be submitted to the Objection Reviewing Officer via email to: appeals-northern-regional-office@fs.fed.us, with “Tenmile – South Helena” in the subject line. Electronic submissions must be submitted in a format that is readable with optical character recognition software (e.g. Word, PDF, Rich Text) and be searchable. An automated response should confirm your electronic objection has been received.

    The objection must meet the content requirements of 36 CFR 218.8(d), and include the following information: 1) the objector’s name and address, with a telephone number or email address, if available; 2) a signature or other verification of authorship upon request (a scanned signature for email may be filed with the objection); 3) when multiple names are listed on an objection, identification of the lead objector as defined in 36 CFR 218.2 (verification of the identity of the lead objector shall be provided upon request); 4) the name of the project being objected to, the name and title of the responsible official, and the name of the national forest and ranger district on which the project will be implemented; 5) a description of those aspects of the project addressed by the objection, including specific issues related to the project and, if applicable, how the objector believes the environmental analysis or draft decision specifically violates law, regulation, or policy; suggested remedies that would resolve the objection; and supporting reasons for the reviewing officer to consider; and 6) a statement that demonstrates the connection between prior specific written comments on the particular project or activity and the content of the objection, unless the objection concerns an issue that arose after the designated opportunity for formal comment. With certain exceptions (36 CFR 218.8(b)), all documents referenced in the objection must be included with the objection.

    An objection, including attachments, must be filed with the appropriate reviewing officer within 45 calendar days following publication of the legal notice of the objection filing period in the newspaper of record (The Helena Independent Record). The publication date in the newspaper of record is the exclusive means for calculating the time to file an objection. Objectors should not rely upon dates or timeframe information provided by any other source. It is the objector’s responsibility to ensure timely filing of a written objection with the reviewing officer pursuant to 36 CFR 218.9. All objections are available for public inspection during and after the objection process. Responses that do not adhere to these requirements make review of an objection difficult and are conditions under which the reviewing officer may set aside an objection pursuant to 36 CFR 218.10.

    Hard copies and/or CD copies of project documents (DROD and FEIS) are available upon request at the Helena Ranger District, Helena, Montana (2880 Skyway Drive, Helena, MT, 59602). If you have any questions regarding the project’s FEIS, DROD, or the objection process, please contact Helena District Ranger Heather DeGeest at (406) 449-5201.

    Sincerely,


    Forest Service Shield
    Allen Byrd
    Interdisciplinary Team Leader / NEPA Planner
    Forest Service
    Helena and Lewis & Clark National Forests
    2880 Skyway Drive
    Helena, MT 59602
    www.fs.fed.us
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    Caring for the land and serving people

  19. #19
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    Alternative 4 with modifications. Looks like they wont restrict bikes on trail segment A during archery season, at least right away. They want time to research bikes on that trail. Meanwhile they are continuing to restrict bikes, within the project area, to approved roads and trails. No access to unapproved trails or off-route travel. They have cited wildlife concerns and creation of unapproved trails. My gut feeling is that they are removing bikes from off-route travel based upon faulty logic. We have 45 days to craft our objections to this draft decision.
    I don't know what trail we're on, but at least it's getting dark

  20. #20
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    The USFS got some interesting comments:



    We're putting our heads together to come up with objections to the bicycle travel order. The basic problem is that it assigns blame and responsibility for all non-system routes on bicyclists. That's clearly not the case when you look at aerial imagery of the forest margin and most adjacent properties have trails leading into NFS lands. Anyway, such a major step shouldn't be taken without an inventory and analysis of all the non-system routes within the specified area. Many of them are used, and the USFS recognized the value of adopting several of them in this proposed action.

  21. #21
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    I'm looking forward to a logical and strategic set of points to address this biased and problematic plan. I look forward to any new guidance you can provide, hopefully not at the last minute. I need to comment by the end of September, as we will be traveling in early October. Good and clear points are made, but there may be much more to it.
    I don't know what trail we're on, but at least it's getting dark

  22. #22
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    Quote Originally Posted by GregB406 View Post
    I'm looking forward to a logical and strategic set of points to address this biased and problematic plan. I look forward to any new guidance you can provide, hopefully not at the last minute. I need to comment by the end of September, as we will be traveling in early October. Good and clear points are made, but there may be much more to it.
    Here are the basic points the MBG will make. I'll make it as simple as possible so that everyone can write their objections in their own words, so I'm freestyling this and not copying from our draft letter.

    We object to the draft decision's limiting bicycle travel to system trails and roads within the designated area. There are several reasons for this:

    The DROD singles out bicycles as the cause of a proliferation in nonsystem trails. It states that the restriction is needed to deal with that problem (page 17). But it doesn't recognize or address the fact that other modes of travel, and other users create and maintain nonsystem trails. We are willing to help the USFS address the issue of nonsystem trail creation in an outreach effort targeting all users and adjacent landowners, but singling out bicyclists does nothing to address the problem. In terms of raw mileage, I'm certain there are more miles of nonsystem trail leaving adjacent private properties than there are rogue MTB trails. You don't have to spend long on Google Earth to see them.

    Also, there are many existing nonsystem routes with years-to-decades of established use. The USFS is clearly willing to incorporate such routes into the system (as demonstrated in this DROD with Trail A). The cross-country restriction shouldn't be enacted without a comprehensive inventory of nonsystem routes and their uses.

    Specific trail route comments-

    We remain concerned about routing Trail E north of Skihi Peak. The boulder fields in that area will make trail construction very difficult and costly. We still prefer an alignment south of the peak.

    We support the proposed relocation of Trail C's northern terminus to the Park City (AKA Mount Helena Ridge) trailhead. This is a good move for taking traffic off the road.

    We support the concept of an additional connection from the bottom (eastern end) of Switchback Ridge Trail 348 to the north, above the private parcels, and ultimately hitting Rimini Road near the border of NFS lands in Section 9.

    Thanks-

  23. #23
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    Quote Originally Posted by evasive View Post
    Here are the basic points the MBG will make. I'll make it as simple as possible so that everyone can write their objections in their own words, so I'm freestyling this and not copying from our draft letter.
    Thanks-
    Thanks Evasive. I'll be writing a careful comment in the next couple days. From what I see, 41 people have read this thread, so I expect at least 41 unique and thoughtful comments to be sent to Helena-Lewis and Clark National Forest!

    I thinks it's important that we fight these subtle or not so subtle forms of inequality with our collective voices.
    I don't know what trail we're on, but at least it's getting dark

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    Thanks Evasive, i'll comment this weekend. if you are ever in the Bozeman area beer is on me

  25. #25
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    Quote Originally Posted by fleboz View Post
    Thanks Evasive, i'll comment this weekend. if you are ever in the Bozeman area beer is on me
    Woohoo! Actually, I'll be down on the 7th for the Montana Enduro Series party at Wildrye.

    Seriously, we appreciate the support.

  26. #26
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    I should have added this to my earlier post:

    I think most readers understand that you have to have commented in March in order to have standing to object to the draft decision. There are some additional requirements in order to have your objection considered:

    1) Name and address, with a telephone number or email, if available;
    2) signature or other verification of authorship upon request (e.g. scanned signature for email);
    3) when multiple names are listed on an objection, identification of the lead objector;
    4) the name of the project being objected to, the name and title of the responsible official, and the name of the national forest and ranger district on which the project will be implemented;
    5) a description of those aspects of the project addressed by the objection, including specific issues related to the project and, if applicable, how the objector believes the environmental analysis or draft decision specifically violates law, regulation, or policy; suggested remedies that would resolve the objection; and supporting reasons for the reviewing officer to consider; and
    6) a statement that demonstrates the connection between prior specific written comments on the particular project or activity and the content of the objection, unless the objection concerns an issue that arose after the designated opportunity for formal comment. With certain exceptions (36 CFR 218.8(b)), all documents referenced in the objection must be included with the objection.

    If you're objecting to the bicycle travel restriction, make note of the fact that it is being implemented 'in response to concerns' about effects that bicycles 'may have' on big game. Page 17 of the DROD.

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