USDA Forest Service
Matt Lechner-NEPA Coordinator
Shawnee National Forest
50 Highway 145 South
Harrisburg, Illinois 62946

Attn: Trails Designation:

            Having reviewed the Notice of Intent to prepare an environmental impact statement for the purpose of identifying additional miles of hiker/equestrian trails within the four watersheds, Lusk Creek, Upper Bay Creek, Eagle Creek and Big Grand Pierre Creek, and the restriction of equestrian use within these watersheds to system trails, I offer the following comments:

            This statement must be amended since any restrictions to use on designated trails will be made for equestrians only per the Shawnee Forest Service Supervisor, and Trail Manager.  Hikers will not be restricted.  Therefore, any mention will be as equestrian trail not hiker/equestrian.

                       Page 2 - Supplementary Information:    Purpose and Need for Action:
            “The Shawnee National Forest’s 1992 Amended Land and Resource Management
                         Plan (Forest Plan) anticipated an increased demand for trails----“
 

There is no mention of anticipated increase in demand in the 1992 plan unless the part of the plan that states: "all user created trails would remain open" is interpreted as such.  Had the 1992 plan been implemented as written, these trails would have been designated as system trails and maintained by the forest service for the last 10 years!  Had the FS done it’s job implementing it’s own plan for management, the existing problems may never have occurred.

            “In the years since publication of the Forest Plan, public demand for trails has grown without any additions to the Forest’s designated trail system.  The existing designated trail system does not adequately meet the need for public access…”

            This problem has been created by the Forest Service’s own failure to implement their 1992 Plan when it did not designate and maintain the user-created trails since 1992.  Historically, this Forest Service personnel has implemented parts of the 1992 Plan only when forced by the Federal Court to do so.  The money spent in litigation over the Forest Service’s implementation failure could have paid for the maintenance of these trails for the past 10 years. 

                        “…. agency policy prevents the forest from managing these trails with trail
      maintenance funds----“
Amended 1992 Plan, Section IV page 24, states, “that user created trails may be maintained with forest service approval.” 

             No specific statement is made in the 1992 plan about agency policy restricting maintenance to designated trails only.  Where and how is agency policy set?  This of course is a mute statement, since for the last 20-30 years the forest service has done very little maintenance on their designated trail(s).  The River-to-River trail has many more places that have caused resource damage from lack of maintenance than the user created trails. 

                        Proposed Action:
            1. Identify a number of miles of trail to add to the Forest’s designated trails system within the watersheds….
            All user created trails into the scenic areas should be constructed/reconstructed. There will be less of a user impact with a higher density since scenic area trails are the most frequently used trails.  The unique topography (especially the rock formations) of these watersheds is the main reason people travel from all over the U.S. to ride in the Shawnee Forest.  We have “little grand canyons” and they should be treated as such.  The tourism possibilities are enormous  - although the FS is not the one making any money off these attractions!  Campgrounds have suffered tremendous economic loss from the current Natural Area closures.  Word of mouth about closures and harassment from anti-access groups has reduced equestrian tourists since 1999.  The brunt of this economical loss is a direct result of the lack of implementation of the 1992 Plan by the Forest Service.

          2. Construct additional trailheads –

            Additional trails would greatly improve the access to the areas of the forest that are ridden only by locals.  But only locals will use these additional trailheads.  Those people who travel and are camping will not move their “rigs” to another trailhead to ride.  These vehicles are large and it takes effort to set them up level.  Once a camper is set, they do not move until they are ready to travel home.  Since money is listed as one of the reasons maintenance hasn’t been done to even designated trails, money used for additional trailheads would be better spent on existing trails in the heavy used area of the forest.  Tourists do not come to the Shawnee Forest to ride terrain similar to other areas of the country.  They come to ride the rock canyons and cliffs that are mainly present in the heavily used areas around the horse camps. 

            If additional trailheads are constructed, they should be large enough to allow access for several (at least 10) large and small trailers, with plenty of space for movement of vehicles.

            3. Amend the Forest Plan to restrict equestrian use in these four watersheds to system trails and roads;

           This is not acceptable or within the power of the Forest Service within any Wilderness boundary.  The Wilderness Act specifically allows for  “primitive unrestricted recreation”.
A well designed, signed and maintained trail system will prove there is no need for the restriction to designated trails. More than 99% of the users are tourist and will stay on the system trails for fear of getting lost and because signage will state that the trails will go to the scenic areas where they want to ride.

            Use of public and county roads within the forest continues to be the right of every equestrian, as the forest service did not buy these rights when the land was originally purchased, and no condemnation proceedings have been had to close the roads.  These roads should be not counted as part of the trail system because they are simply not part of the forest.

            4. Amend as required, the trail density standards -----

            Trail density standards are a useless, meaningless, figure in the Shawnee National Forest. Averages have no merit of their own and exist only as a standard for the forest service. Trails should be provided to meet the public’s demand for recreation and protection of the natural resources. 
           If there must be a density standard, then the trail density standard must be increased to reflect the area’s topography.  The standards that work in the western states are not pertinent to the Shawnee.   People can be on trails across the valley and not be aware of those on the opposite hill because of the dense foliage of this area.

           Scoping Process

            Part of the scoping process should include contacting those user groups that will be most influenced by any changes in management:
                         1. Campground owners regarding equestrian campers requirements and demands
                        2. Local equestrian groups (specifically trail riding associations) regarding their requirements and demands.
                        3. Forest service personnel from other forest that already have designated maintained trails for their expertise of successful trails.

            These groups may not be on the mailing lists, but certainly would have the necessary knowledge of horses and trail riding that the forest service personnel lack.

            Preliminary Issues

            Anti-access groups who see increased usage of the forest as negative have given each of the issues listed below.  Each issue can be considered as subjective, there is no hard science to prove or disprove these issues as they relate to the Shawnee Forest.

            1) Designation and construction and/or improvement of additional system trails may cause increased erosion and soil compaction and adversely affect water quality:

            . Trail construction is supposed to cause less erosion by the virtue of the construction.  Certainly, the forest service has scientific evidence that their trail standard for construction causes less damage than the user created trails. (Although running a small dozer over a trail to move boulders and tree roots that have been buried by nature and are part of a user created trail certainly caused loosened soil and removal of those anchoring forces, which using common sense would be less invasion to the natural resources of the trail.) 

Even if every user created trail is designated, constructed/reconstructed, the total land mass used by the trails in the Shawnee is less than 1%.  It is not possible for the minute amount of land used for trails to affect the water quality.  The 30 years of prior trail use cannot even register on the same scale that one large rain can as it changes the land mass, disrupting soil and plant life within just a few short hours.  Heavy rain can totally revamp the waterways and creek banks, taking mass amounts of soil and plant life as that rain rages through the total land  (that is 100% of the forest).  Rain in one heavy downpour in one day can take more soil, rock, trees, and flowers than 30 years of horses riding 1% of the Shawnee Forest.

            2) Increasing trail-density standards may adversely affect wilderness and natural area attributes;

            Over 99% of the forest does not have trails in it, and none are being proposed in these areas.  Even if the designation of these areas is not wilderness, the attributes of wilderness are very strong in most of these areas.  Of the wilderness areas, only parts of Lusk Creek and Bay Creek have many trails in them, Burden Falls Wilderness has very few trails and is extremely unused by anyone but hunters.   Increasing the trail standards to include the existing user created trails will not change the experience that is now available.  Increasing trail density standards will allow the Forest Service to designate and maintain the user created trails that allow recreationists to experience Shawnee’s most unique and breathtaking wilderness and natural area attributes. Even with increased trail density standards, these wildernesses still have areas that have no trails.  Those people who are willing to venture off the trails can easily experience complete solitude.

            3) Use of additional trails may exceed the physical carrying capacity of the affected watersheds;

             Even if every user created trail is designated, constructed/reconstructed, the total number of acres of land mass used by trails in a watershed is very minimal.  It is not possible for the minute amount of land used for trails to exceed the physical carrying capacity of these watersheds.  The 30 years of prior trail use can not even register on the same scale that one large rain can, as it changes the total land mass, disrupting soil and plant life within just a few short hours.  Heavy rain can totally revamp the waterways and creek banks, taking mass amounts of soil and plant life as that rain rages through the total land  (that is 100% of the watershed).  Rain in one heavy downpour in one day can take more soil, rock, trees, and flowers than 30 years of horses riding in watershed of the Shawnee Forest.

            4) Designation of additional system trails may not provide quality recreational experiences.

            Quality recreation is a term with many perceptions and definitions.  The Forest Service should consider the actual numbers of each user group when trying to define this term.  The Forest Service has not quantified the numbers of each user group. Without any type of survey at all, equestrians certainly use the forest more than any other users group.  Their definition and perception of quality recreation should be given greater consideration than those of groups who rarely use the forest.

             The public attended a series of Master Trail Planning Workshops for over 2 years. This took a lot of time and effort as well as money spent by the public. This will be a total waste of time, effort and money, if the trails identified at these meetings are not designated. All user created trails should have been "Grand-fathered" in as part of the 1992 plan. This was the equestrian users goal. This is why these meetings were well attended and people worked diligently. Expecting that their participation would help this to happen.  Having more trails closed again to equestrian usage is unacceptable. If a trail must be closed because of resource damage, it should first be rerouted to provide access to that area.

      Maps:

            All the maps turned in by the Shawnee Trail Conservancy should be considered as part of the designation process, only so you as the Forest Service can’t say that maps of trails were not turned in.  But all user created trails need to be designated and your own maps have all these trails on them.
Once they are designated, then assessment of each trail and possible rerouting when resource damage shows major impact, can be done on each trail before maintenance of that trails is done.
      There are no "dead end" routes indicated on the proposed trail maps, such trails as the one in Jackson Hollow areas that goes over the railroad tunnel. The reason given was because the trail ended on private property and no “dead end” trails would be designated.  The Jackson Hollow trail has been used for many years and should be included on the map. Another example of trails that should be designated and are not, is trails leading to other private ownership or campground access trails.  These designated forest service "dead ended" trails are vital to the local landowners, which include the campgrounds who have millions invested in their business.  The Federal Judge stated he would have no part in closing horse camps, but if trails connecting the campgrounds to other designated trails are not done, campground will be closed.  These access trails from campgrounds and private land would eliminate the need for special use permits, which could become an administrative "headache". 

            It seems the hidden objective in the restriction of equestrian user only to designated trails is to either close the campgrounds down or collect money from the campgrounds with special user permits.  Both of these objectives will be done quite effectively when campers can only access the forest if the campgrounds pay for the special user permits.

      Priority Comment:

      There should absolutely be no additional trail closures, until a well designated, signed, trail system is in place. Additional Lusk Creek trail crossings should be immediately provided to allow for safety concerns and the livelihood of campground owners.

      Respectfully submitted,