PROPOSED FOREST PLAN COMMENTS
Hurston A. Nicholas Forest Supervisor Attn: Plan Revision Comments 50 Highway 145 S Harrisburg, IL 62946 Re: Proposed Land and Resource Management Plan Dear Supervisor Nicholas: The Shawnee Trail Conservancy supports the Forest Services efforts to improve the ecosystem health, biodiversity, forest interior habitat, heritage resources, and visual quality. We also support:
The FS is mandated to maintain the forest for multipurpose recreation with the Multiple-Use Sustained-Yield Act of 1960 and the Small Business Regulatory Fairness Act. The FS must meet the requirements that their Plan provides for multiple use: management of all the renewable surface resources of the national forest to meet the needs of the American people. The Plan must not adversely affect small business owners. We want modifications to Alternative 2 regarding recreational management. We want restriction to designated trails only in the areas that have the heaviest impact upon the forest. These areas are all within a couple miles of the private horse camps. We want trails in these areas built to a standard that will support year round use without the need for wet condition or seasonal closures. Trails to this standard will help rural economic development that the Forest Service is mandated with fostering. Under present permits restriction, Lusk Creek Wilderness, the most heavily used area, has seasonal and wet condition closures and group size restrictions that have reduced customers for the private campgrounds that use the Lusk Creek Wilderness. The campgrounds that are not using the Lusk Creek have seen an increase in their customer base since these restrictions have been initiated. These restrictions are negatively affecting those small businesses located in the Lusk Creek area. The FS is charged with promoting small business. We want no restriction to group size in Wilderness
Areas. The FS has no study to prove
that group size increases the wilderness experience. The Shawnee National Forest Wildernesses are very small and are
Wildernesses in name only. The true
“Wilderness” of the Shawnee is in the outlying areas away from the equestrian
trails. In these areas, there is little
evidence of prior settlement and no network of trails, only nature without the
imprint of man. Restriction in
Wilderness will cause irreparable harm to the local horse campgrounds within
the vicinity of a designated
“wilderness” area. We want outlying areas to have open riding no matter which watershed they are located in. Obscure user created trails that are ridden by private landowners only or ridden only infrequently should be legal trails whether they are designated or not. Outlying trails do not receive the impact and need not meet the same standards as the heavily used areas around the horse camps. If outlying trails must be designated then we want all outlying trails designated with implementation of the plan. Then as time, money and manpower allow, individual trails can be moved or brought to the standard appropriate for their usage if they are causing resource damage. Once size fits all is not appropriate for trail standards, or for management of the entire forest. Non-restriction in outlying areas will also help the rural economic development by promoting the access that is now available from private land thereby continuing to support the land values that have increased dramatically in recent years. The economic impact on the local land value will certainly plummet if private landowners do not have free access to the forest. Local landowners, real estate agents, and County and State entities that now rely on the increased tax base will be irreparably harmed by this restriction. Restriction to designated trails and requiring permits by private landowners to access the forest will cause a logistic nightmare of bureaucratic paperwork contrary to the Paper Reduction Act and the Small Business Regulatory Fairness Act. The restriction to designated trails in outlying areas will create irreparable harm on local landowners. It will cause a financial burden on the private landowner who must: pay $75-90 for a yearly permit; pay for part of an environmental impact study for the forest property where a permitted private land trail is located; and pay to maintain the permitted trail to a FS standard. Hundreds of individuals will be forced to haul their horses to trail heads to access the forest. There is only one trailhead that can presently accommodate several rigs at this time. Budget constraints are evident throughout the plan; therefore the proposed new trailheads are not likely to be built in any near future. A gap between the need for access and ability to fill that need is created by this restriction of access by permit or trailhead only. Restriction to designated trails will cause increased trail usage on the limited number of trails that will be designated. Placing all horseback riders of the Shawnee Forest on a few designated trails will impact those trails and decrease the quality of recreation by concentrating large numbers of users on a smaller area. Using only system trails will reduce the opportunity for solitude for horseback riders and pedestrians. From our vast cumulative experience of riding the Shawnee Forest, pedestrians do not get off trails. They expect their wilderness experience to happen on a trail. By getting off a trail only a few hundred yards, anyone can have a solitary experience anywhere in the forest. Restriction to designated trails will cause irreparable harm to horseback riders who need a solitary experience to communicate with nature in its truest form. The FS has made an assumption that there will be increased horse traffic in the future on system trails and non-system/cross-country trails, when they have no factual basis for this assumption. There have been no studies to indicate that this is true. The FS cannot rely on their opinion with no factual data. In fact, as prices climb for fuel, more regulations regarding animal travel are passed, and increased restrictions while using federal land occur, the amount of people visiting from other states may actually decrease. With horse campgrounds under permit, the FS can control any increase in use from campgrounds, new or old. The FS has not considered the cumulative effects created by restriction to designated trails. Quality of recreation will decline while the additional financial burden necessary to maintain the designated trails to control resource damage increases. The cumulative recreation social affect impact can not be known because this proposed forest plan is not a total forest plan but proposes management of just four watersheds. The FS has no study to show the user numbers and their impact upon designated trails once users are restricted to designated trails. No studies have been done regarding the effects on the quality of recreation caused by restriction to designated trails. From past experiences in other forests, especially the Hoosier forest, the FS will designate trails that are away from scenic rock formations and creeks drastically reducing the recreational experience that has become the cornerstone of the Shawnee Forest. Without access to these types of areas, horseback riders will no longer visit the Shawnee Forest with the same frequency. The local horse camps can verify that there has already been a reduction in horseback visitors to the forest since 1999 when the Natural Areas were closed to equestrians. The seasonal closures and wet weather conditions and group size from camps in the Lusk Creek have also caused a reduction in horseback riding in this area. Watershed management is another way to use the one size fits all concept. Watersheds are too large of an area for just one management type and should contain several levels of management instead. The area closest to creeks should be managed different from the area furthest from such creeks. Under the current forest plan, water quality has been proven to be excellent. Lusk Creek, which is the most recreated watershed, has excellent water quality using independent water testing results. The forest plan states I-4 “The highest quality, most scenic and most ecologically diverse streams in southern Illinois are in watersheds with a high percentage of national forest ownership.” The STC advocates the de-designation of the Lusk Creek Natural Area bank to bank. Even with the supposed increase usage of the Lusk Creek Wilderness in the past 10 years, this stream continues to have the highest water quality in southern Illinois. There is no study or factual basis to assume that the many water crossing used by horses over the past 30 years has done any damage to this stream. During the summer months when the stream is not flowing steadily, the water stirring created by the horses crossing the water is beneficial to the stream’s aquatic life by causing oxygenation of the water much like an aerator in a pond. The Lusk Creek would continue to be protected by the Wilderness designation while the Natural Area designation has only caused problems especially regarding stream crossings. The STC want trails in Natural Areas to allow more users of the forest to visit these unique areas. With proper signage and protection such as fence type barriers next to endangered species, trail use would not be detrimental to the Natural Areas. The STC wants ATV/OHM usage allowed on trails that are designed and maintained for that purpose. Limiting their usage to certain areas away from the more frequented areas of the forest would allow them the opportunity to use the forest also. With modifications to Alternative 2 for all weather trails around horse camps; no restriction to designated trails in outlying areas; de-designation of the Lusk Creek Natural Area; and ATV/OHM trails – the projected economical growth rate of Alternative 2 would change, and in our opinion increase to reflect closer to the numbers represented in Alternative 1 or 4. It is vital for southern Illinois to continue having the best tourism possible and it is mandated that the FS promote rural economic development.
Horseback riding has occurred for centuries, it freed man by giving him mobility. A horse in the forest is as natural as any of the other wildlife. Man’s taming of the horse allows man to witness and participate in nature at a level not achieved in any other manner.
Respectfully submitted, Shawnee Trail Conservancy By Linda Granneman, President |