Shawnee Trail Conservancy
PO Box 44
Eddyville, IL

Forest Supervisor
Attn: Trails DEIS
50 Highway 145 South,
Harrisburg, IL 62946

Subject: Trails DEIS

The Shawnee Trail Conservancy takes the position that designation of trails is necessary so that the FS will maintain trails. It is the lack of maintenance that has caused what degradation has occurred and not horseback riding.

Properly designed and maintained trail systems minimize resource damage. As major stakeholders in the Shawnee Forest, local counties have had their revenue increased greatly as a direct result of access to the forest.

The STC disagrees that #2, the preferred alternative, provides the necessary requirements of the majority of direct stakeholders of the Shawnee Forest. Major stakeholders include residents of the various counties, a large percentage of whom have bought land just for the access to the Shawnee causing land values to triple in the past 10 years. Restricting access to private landowners will not only create personal hardship for the landowner, it will devalue their land prices therefore reducing revenues for the southern counties of Illinois.

Equestrian have lost many trails to the Natural Area closures which include the following: The Squeeze, High Point to Indian Kitchen Trail, Lusk Creek Canyon, Martha’s Woods , the crossings on the Lusk Creek - (Bowed Tree, & Salt Peter Cave), Rock House, Double Branch Hole, Jackson Hole, Bear Track Hollow, Oxlot Cave, Caine Barrens, Whoopie Cat Lake, Cave Hill Trail, Stoneface, Dennison Hollow, Bell Smith Springs (had many miles of horse trails before they were closed),Bulge Hole, Atwood Ridge. Restriction to designated trails will cause equestrian to loose even more access to the forest under the name of resource protection.

The below excerpts from the DEIS support the Shawnee Trail Conservancy’s position that trail designation is necessary, but restricting equestrians to these trails has no scientific study or peer review to support such restriction. This restriction is an arbitrary and capricious action with limited, if any merit.

Chapter 1. Purpose of and Need for Action

III. Purpose of and Need for Action. Pg 9

Chapter 3.

XIII. Required Disclosures

F. "There are no known irreversible effects on soil and water resources from any alternative. ………. Scale is an important factor in thinking about soil erosion. Trails occupy a small percentage of the project area.

X. Visual Effects

"Table 56. Area in wilderness visually affected by current use of all trails and

stock-confinement areas.

Alternatives Acres Physical Effect*

(Percent Area per Wilderness) 1 2 3 4

Garden of the Gods 0.5 % 0.3 % 0.3 % 0.2 %

Lusk Creek 0.9 % 0.5 % 0.7 % 0.2 %

Upper Bay Creek 0.4 % 0.4 % 0.4 % 0.2 %

* The areas that receive physical effects from trail use are calculated by adding total trail

acres. Trail acres include system trails (trail length multiplied by 8’ width), non-system trails

(Alternative 1 only) and stock-confinement areas.

Neither scientific evidence nor peer review is listed as part of the IDNR "surveillance report". This report lacks the scientific evidence necessary to be used as a basis for any action. The extent of these "adverse impacts" as stated in the Required Disclosure statement and Visual Effects Graph simply to not support the extent of limitations to equestrian riders that are part of Alternative 2, 3 and 4. The graph shows that all alternatives have less than 1% of land mass devoted to trails and stock-confinement areas in any one Wilderness.

VII. Issues. B. Recreational Experience

Issue Statement. Restricting equestrians to designated trails and closing trails could increase hiker-equestrian conflicts and limit recreational opportunities.

The STC fully expects more conflicts to be created while reducing a varied recreational experience for the equestrian user.

User conflicts have only occurred on trails frequented by hikers & rapellers in high use horse areas close to horse camps and developed recreation areas. No conflicts happen off trails or in areas away from these high use horse areas. The number of proposed trails is certain areas concentrates the usage which will increase the number of users to a smaller area.

Chapter 1. III. Purpose Of and Need For Action

……..In order for the project to succeed in the prevention or minimization of resource damage and the provision of a quality recreational experience for all users, the Forest Plan must be amended in several, though non-significant, ways. The restriction of equestrian use to an adequate designated trail system designed to prevent or minimize these impacts is essential.

Restricting equestrians to designated trails is a very significant change for this user group and it discriminates against them without any scientific facts to support this change.

Restriction of equestrian users to designated trails is an arbitrary action by the Forest Service to appease the few vocal activists that persistently keep the Forest Service in Court over their management of the forest.

There is no scientific basis that restriction to designated trails provides a quality recreational experience for all users. Proper design, signage and maintenance of trails are indicators of successful recreational experiences. Wilderness experiences of untrammeled, undeveloped, primitive and unconfined recreation are non-existent when users are restricted to designated trails.

Eliminating camping with stock would stop equestrians who travel on the River to River (part of The American Discovery Trail) from completing the entire trip across the State and across the Nation. Eliminating camping with stock will negatively impact a successful recreation experience for these users. There is no past history to support even the possibility of long term camping within the forest. Limitation of camping to one or two overnight stays at one location would allow continued use of the River to River trail and no adverse impact from long term camping in one specific location.

Wilderness management and stewardship – in the Wilderness Handbook states, " Provide for human use while preserving the wilderness character, provide outstanding opportunities for solitude or primitive recreation and unconfined recreation experience in each wilderness". "The freedom of the wilderness dictates that people should generally be free from regulation. Education is preferred over regulations". Wilderness access for equestrians is not to be restricted any more than any other user group. Equestrians have the right to seek solitude and are not to be singled out for restrictions over another group.

Clemson University, Clemson, S.C. trails conference – Jim Miller, Dispersed Recreation Manager, USFS-Washington, D.C. states:

It is not economically feasible to provide additional individual use trails. There are already hiker only trails in Bell Smith Springs, Pounds Hollow and Garden of Gods areas and all the Natural Areas with the Forest. Since hikers are not the largest user group in this forest, these areas provide more than adequate hiker only trails. The Shawnee Forest has a very small budget so wise use of this money dictates providing the most benefit for all users not just one type of user.

Chapter 2 B. Alternative 2 – Preferred Alternative

Stock confinement areas at Salt Peter Cave and Natural Bridge when relocated are not at these scenic destinations anymore. If these confinement areas can be reduced in size to meet standard and guidelines in alternative 3, they must be reduced and not relocated. Creating a buffer between the confinement areas and the creek could be used to meet the management criteria for these areas. Horses cannot be left unattended in stock confinement areas while people walk to these scenic areas, as this can be hazardous to the animal. Animals could fight if tied to closely to other horses or become tangled in their tethers, injuring themselves, needing immediate attending. That would be impossible if confinement areas are not located at the destination spots. Closing these areas is discriminatory towards horseback riders under the Disabilities Act, which requires equal access for handicapped individuals. Many people cannot walk but can ride a horse.

To alleviate the visual effects from stock confinement areas, visual barriers could be used between the scenic areas and the confinement areas. This would lessen the visual impact of the confinement area to non-equestrian users. A visual barrier would lessen the "view" of trampeled ground if such barrier were a few feet in height while still allowing equestrians the ability to monitor their stock for problems.

Wet weather related closures should not be defined by a certain time of year such as a month. Averages are just that, averages. Use of actual waterfall amounts would be a more accurate gauge for the type of conditions that may cause adverse impacts. As an example this past spring, 2005, was an exceptionally dry spring and the April rain in excess of 1-inch ran off much the same as it would have in July because the ground was so dry and hard.

The use of averages is an arbitrary decision. Wet weather closures should be based on the actual weather conditions.

The proposed, Alternative 2 prohibits use in the wilderness areas – Dec. 1^st – March 31^st, during construction and maintenance, stating that these are temporary closures (two years), yet the construction/maintenance timeline shows 5-6 years. It is doubtful that construction work will be going on in all three wilderness areas at the same time. The number of riders during this time frame is so minimal that their impact on less than 1% of the wilderness will be negligible for many years and certainly until the trails are up to standard. There are no obstacles created by the construction of a trail similar to the construction of a highway, to make this a justifiable decision. Closing the Wildernesses is an unnecessary and arbitrary action.

Use of mechanical equipment to construct and maintain designated trails within the Wilderness is permission according to the Forest Service Manual.

It is certainly time to use this equipment in the Shawnee National Forest in order to get these proposed trails on the ground as quickly as possible. If the hypothesis of resource damage is true, then constructing trails should be done as quickly and efficiently as possible to mitigate such damage.

Limit of 10 or 20 people in wilderness has no scientific study or peer review to support this limitation. This is a subjective social preference of other wilderness users.

The social values, norms and preferences of other wilderness users should not be used as a reason to restrict. It is recognized that "there may be limited areas where the terrain is so fragile that recreational stock use may have to be restricted". This should be the exception and be determined by site specific analysis based on biological and physical criteria rather than subjective social preferences of other wilderness users.

Size limitation is an arbitrary limitation that does not change resource conditions. It is meant for visual effects and is based on faulty reasoning. Meeting several groups of 10 stretched over a longer period of time or one larger group for a shorter time changes or protects nothing. And does not change a visual experience either. As an example, consider a person trying to take a nap. Would 1 minute of 30 kids or horses disturb you more than 30 minutes of interruption and noise as the kids and horses are spread out in smaller groups? Every time that person started to fall asleep, he would be disturbed again instead of just once.

For those hikers seeking a solitary wilderness experience, visiting any of the natural areas, or less popular areas of the forest make such an experience extremely easy.

Chapter 3.

II. Soil and Water

A. Soil

One horse produces about 50 pounds of manure per day (Cherry Hill 1998, Colorado State 2005). ……These are critical nutrients for plant growth, and nitrogen and phosphorus are often limiting nutrients in streams, ponds and lakes.

The 50 lbs. is for 24 hours, 7 days, not for the short duration of time while being ridden in the forest.

ONE HORSE in one full 24-hour period excretes 50 lbs of manure of which 12.5 lbs is active solid. The rest is water.

II. Soil and Water

C Mitigation Measures for Soil & Water

7. Manure Runoff

There is no scientific study or peer review to support this statement.

FACT: One inch of rain on one acre of land provides 27,116.9 gallons of water.

Manure left in a loose heap in deposits on trails loses its nitrogen rapidly (New Hampshire 1990). Phosphorus and potassium are the trace constituents of most concern in horse urine. They bind to soil particles and may be eroded away into surface water bodies. They would be present only in the minutest of quantities in manure on trails. Horse manure effects are minimal only.

Bacteriological and nutrient effects (on water bodies) are seldom detectable except next to stables. (Williams et al, 1998). As part of the 319 (h) grants from the Clean Water Act, new data has recently become available in the SF Bay Area. In addition, some data is now available from watershed monitoring efforts. Here is some of what is known:

• USDA RCD Demonstration Project at Black Dog Ranch, Half Moon Bay
  This property is bisected by Pilarcitos Creek. Horse paddocks were literally on the edge of the creek bank. Water sampling taken spring of 2000 showed no nitrates, ammonia, P, or K above allowable limits.

Diluting the manure or urine a horse might deposit on a trail in the amount of rainwater deposited on that trail, shows that our equine's natural contribution is simply the proverbial drop in the bucket.

Reference: EnivroHorse The Real Poop: A Discussion of Horse Manure on Trails
By Cyla Allison, Ph.D

Chapter 3 – III. Aquatic Resources. A. Forest-Listed Aquatic Species

The least brook lamprey is a State of Illinois – threatened species listing. The Forest Supervisor is not required to follow state guidelines regarding such listings but has chosen to raise the level of protection for this species. Information and assessment is not current with new data being complied

Affected Environment and Environmental Consequences

Species Effects

4. Least Brook Lamprey

Seasonal stream crossings for protection of species (least brook lamprey) are proposed from March 15 – May 15^th in Alternative 2, 3 & 4.

There is no scientific study or peer review that horse or hiker have ever disrupted spawning activities, damaged spawning pits or physically altered spawning habitat. It is pure conjecture that any detrimental effects have occurred for the least brook lamprey by horses crossing streams.

No scientific study has proven either of these "perceived threats" to be valid. Information given about horse manure in our preceding comments shows that it would take many horses stabled next to the creek before any significant change in the water would occur.

The Least Brook Lamprey is widely distributed throughout the eastern half of the U.S. and is native to 16 states (NatureServe 2004). In Illinois, this species has a relatively small historic range and is currently listed as "threatened".

Due to the expansion of the population and spawning activity at least 15 ft from the crossing, we feel this seasonal closure is completely unnecessary. Damage to spawning sites would require horses to physically touch the actual spawning site while crossing a creek.

Informative natural signs should be placed at the crossing to alert riders to cross streams in a straight line and away from riffles.

For the trails designation project to provide a quality recreational experience for equestrians and other users, trails need to make loops and a follow a logical traffic pattern. The designated trails in Alternative 2, 3, and 4 fail to make logical traffic patterns in several areas, which causes trail use to be in more oncentrated areas. Mapping and marking of trails must to be done by the Forest Service in a professional manner that makes it easy to see the markers yet are unobtrusive in the Wilderness.

The following comments are directed to specific trail designation or lack thereof.

All trails are marked with a green highlighter and the corresponding number on enclosed maps.

1. Trail that is old roadbed from the Blanchard (New Liberty) Church that travels in a westward direction crossing the Lusk Creek and up to the County Road that runs into the Coyote Club and on to the Natural Bridge area. This trail needs to continue across the road staying on the top of the hill and then along a gully until it would connect with the trail that travels North from Natural Bridge crossing to the Coyote Club road. This trail is necessary for all users to have access to the West side of the Lusk Creek, North of the Coyote Club. This trail would allow access to Natural Bridge area from the North. The only other trail West of the Lusk and North of the Coyote Club is over 1 mile West of the Lusk and users must travel almost 2 miles North to cross the Lusk Creek to complete a loop from the other side of the Lusk. This creates too much distance for users to travel in order to complete a loop trail experience. This trail is not within visual distance of the trail on the East side of the Lusk Creek.

This is a very scenic trail that provides the ability to ride a high trail along the Lusk Creek. Most of the trail is not visible from the trail on the East side of the Lusk Creek and will help disperse users for more of the solitary Wilderness experience required by the Wilderness Act.

3. Trail from Oak Rd to Little Lusk Creek. This trail is needed to connect the North Lusk Creek trails to the trails that are in the Williams Hill area. Without this trail there would be too much road riding on hard surface roads that are a safety hazard to horses and humans alike.

River to River trail running through the Wilderness. This trails needs to be given year round access to allow for travel through the Wilderness for access to trails located outside the Wilderness. If this trail is closed during the winter closure, it is impossible for anyone living on the West side of the Wilderness to have access East, North or South of the Wilderness.

4. Trail from River to River from Mule Hole along the top ridge of bluff line to old road that leads to Maxwell Ford. Said trail continues over old roadway East through a hollow and along private property over ridge to the Hanging Tree and Fern Cave area. This is a very scenic trail that allows that alternative of riding a "high trail" along Bay Creek and creates a middle trail to Sand Cave area. This trail is needed to provide an additional loop on the East side of Bay Creek and a way to reach Maxwell Ford without traversing the rocky trail that follows the Bay Creek below the bluff line.

5. Trail above bluff line from River to River and back to River to River just South of Eddyville along the East side of Hayes Creek. This trail provides the scenic qualities that have become the hallmark of the Shawnee Forest. An easement may be necessary for the small private property area that is located on the South end of this trail. It also provides a shorter distance to travel than the River to River to the Petticoat Junction area.

6. Trail at the end of roadbed East of Jackson Hole that follows above the bluff line along the ridge heading south to Petticoat Junction area. This trail is preferable over the proposed designated trail that is located in a pine stand just to the West of this trail. This trails stays dry all year while the pine trail is wet and would require more maintenance than this ridge trail.

7. Trail to follows along the West side of Little Bay Creek North from the Tin Whistle to the northern most trail located in Jackson Falls area. This allows people the ability to access to both Jackson Falls and Jackson Hollow and have a loop experience without having to access other trails to return to trail heads or campgrounds close to this area.

8. Trail that travels North of private property where Peter Cave is located. This is a proposed designated trail that needs to be moved slightly north. Adjusting this trail slightly North would allow users to access the private land to Peter Cave without getting off a designated trail.

In addition, the tether line at Sand Cave needs to be moved so that it is underneath the power line that intersects with Sand Cave. The power company brush-cuts the right of way under this power line so any fragile fauna could not survive in this area.

We are in complete disagreement with the Forest Service Supervisor closure order at the Garden of the Gods Recreation Area and object strongly due to the following:

A Notice of Appeal – 03-09-0029was filed per 36CFR215 on this trail on July 19, 2003.

Garden of the Gods Ecological Area- trails 108E and 108G

The ALRMP corridor map showed the trails as hiker/equestrian. The Record of Decision in the Natural Area Trails Project designated these trails as hiker only. Congressman’s Poshard’s trail committee walked this area on 07/05/94 and was advised by Forest Service Personnel that these were hiker/equestrian trails

Donna Hepp, Director recreation, Wilderness and Heritage the appeal officer, issued in her statement: The appellants raised a number of issues in their appeals of the Record of Decision for the Shawnee Natural Area Trails Project. "I am recommending a Reversal of this decision----"

Randy Moore – Regional Forester – "After, a careful review of the project file and the appeals, I concur with the Appeal Review Officer’s recommendation and adopt her rationale as my own."

This trail has been used by equestrians for over 30 years and should continue to be managed as a hiker/equestrian trail. The condition of the trail is excellent. The trail tread is mostly rock with user impacts barely visible. It allows the user to ride in close proximity to large rock formations and scenic vistas that are no longer available in other areas of the forest with Natural Area Closures.

10. West of Garden of Gods, Trail from River to River to Balance Rock and back through Moccasin Hollow to River to River.

This trail allows people to view another unique attraction, Balance Rock that has been a favorite of equestrians for years. The East part of the loop trail has minimal resource impact and follows an old roadbed through Moccasin Hollow.

11. High Knob, Trail that travels along rock bluff from High Knob area to NoNo Rock. This is more scenic and has a better base than the proposed designated trail that enters NoNo Rock from the South off of the River-to-River trail. It would be a drier trail and more scenic.

12. Top Trail at Hurricane Bluff. This trails travels the southern part of Hurricane Bluff along the top of the bluff along the ridge. It provides a scenic vista and rock trail surface.

13. A trail/roadbed that travels Northwesterly from the Empire Mine area across the Gap Road crossing the Grand Pierre just South of the Grand Pierre Lake. The road continues on West into the forest. This road stops on the designated trails map in the forest property instead of continuing to the Gap Road. The road is picked up again on the map leaving the Gap road. The Forest Service must be consistent mapping the roads within the forest. The Herod/Golconda road would be the only public access for people who own property between Grand Pierre Lake and the Gap road.

14. Rocky Top trail. This trail has designation proposed for the South half only. The trail continues along the bluff line further north. Continuing the trail North where it intersects the River-to-River trail provides better trail stability than the proposed North end, which travels straight down the hill.

A provision for additional designated trails that may become necessary for future permitted campgrounds should be included in the trail designation. These trails should be in a very limited number and may only be short distances to provide reasonable access for future permitted campgrounds.

Old roadbeds that are accessible for riding under the 1992 plan and are not specifically designated as a trail need to be designated as a trails. The forest plan allows riding of old roadbeds, yet many of left off of the trail designation map. These roads must be included on the maps and shown as designated trails so that people know they can ride them. Designating them as trails will allow continued access if at some time the roadbed would be decommissioned or no longer recognized as a road by the Forest Service.

Designation of trails is necessary and any objections raised in our comments deal only with limitations or restrictions that according to the DEIS are necessary. No objections raised are intended to stop designation of trails. The STC welcomes the long awaited designation, maintenance, marking and mapping of trails to protect the resources and provide a worry free recreational experience for trail riders.

Respectfully submitted,

Linda Granneman, President