Eddie Taylor,
District Ranger
Attn: Angelina Motorized Trail Project
Angelina National Forest
111 Walnut Ridge
Zavalla, TX 75980
Dear Mr. Taylor,
I am writing in regards to your subject notice of May 9, 2008 regarding the public comment phase of the Environmental Assessment (EA) for the trail system anticipated as part of the Angelina Motorized Trail Project. I want to thank you for considering my comments. As both a citizen and the President of the Texas Motorized Trails Coalition (TMTC), I am in favor of establishing a permanently marked trail system on the North Angelina as described in the EA and associated documents. I have attended public meetings on this subject over the last few years and appreciate this opportunity to voice my approval of the Forest Service efforts.
However, I have a number of concerns with the proposed project:
1. Trail Length -As I stated during the 2007 meeting in Zavalla, the proposed trail length of 28 miles is my main concern. Depending upon the ability of the rider and the challenge of the system, I anticipate that the system will not be of an adequate size to attract riders from beyond the local area. Many of the private riding areas that I am familiar with have extensive trail systems that allow riders to justify the expense of the trip to the park. In that operation and maintenance of the system is a justifiable concern of the Forest Service, I am concerned about the negative impression of creating only 28 miles of trail. Even doubling the mileage to account for the two way design does not necessarily create enough trail to attract users. At 85 miles (counted only one way), the Sam Houston system stands between the Angelina and the majority of the population base in Houston. My question is will they come?
Is the trail length being driven by available land or available funding? I believe it to be prudent with starting small, but please do not allow perceived conflicts and geographical boundaries to limit the potential for growth should the trail system become the success we envision.
I would propose that it would be a worthy expense of time to inform the adjacent landowners and towns people of the potential economic impact that a trail system could bring to the area. There are published studies covering the economic impact of the Hatfield-McCoy Trail System in southwestern West Virginia as well as Barnwell Mountain Recreational Area (BMRA) near Gilmer. TMTC stands ready to provide copies of the reports should review be desired.
2. Infrastructure - Establishment of two trail heads will be detrimental to the ability of a potential concessionaire to oversee the collection of fees within the trail system. Additionally, construction of paved parking areas is not in keeping with the overall nature of minimal impact on the environment. The run off from rainfall on an impervious surface is significantly higher velocity than an unpaved surface, adding to the potential sediment issues for streams. Detention ponds can be provided, but again they add to the overall impact to the environment, thereby adding to the negative connotations of the trail development. A properly graded gravel parking lot can achieve the goal of providing adequate parking along with minimizing impact on the ecosystems. Much can be learned from the mistakes being dealt with in the Sam Houston.
3. Trespass - The issue of trespass in the south Angelina is mentioned a number of times throughout the EA. Our experience is that trespass and illegal riding decreased following the opening of BMRA near Gilmer. We anticipate a similar result in Ozona with the opening of Escondido Draw Recreational Area (EDRA). Legal riding areas help reduce the likelihood of trespass. In our experience, we continue to have problems with locals and education and enforcement are the two most effective ways to deal with this problem. Reducing the threat of trespass, by constructing a challenging and interesting trail system will also protect biological and archaeological resources in the area by avoiding contact with identified nesting sites, habitat and cultural resources.
4. Camping - TMTC strives for a family environment at our parks and in keeping with this theme, providing trailhead camping areas or direct access to adjacent camping areas will provide important incentives for families to enjoy the trail system as well as educate their children regarding nature and responsible stewardship of the environment. I respectfully ask that you consider adding this feature to the finalized version of the EA.
5. Sound - Sound is perhaps the overriding issue facing the OHV community. In a number of areas throughout the EA, 99 dB is referenced as the standard. I would urge you to lower the standard to 96 dB. Not only is 96 dB achievable, in that the decibel scale is logarithmic, 96 dB is significantly lower than 99 dB. The 96 dB level is becoming the industry standard as it has been adopted in California. TMTC is beginning the process of requiring our members to adhere to that standard as well.
The last paragraph in 3.10.2 states:
“The noise associated with OHVs and dirt bikes would probably preclude any other type of recreation use from occurring within the trail area.”
TMTC is actively working to build bridges between the motorized and non-motorized trail enthusiasts. In the spirit of cooperation, we will provide the assistance necessary to further that goal on this trail system as well.
TMTC is dedicated to the process of rider education and we are working with Steve Thompson, Texas Off Highway Vehicle Program Manager for Texas Parks and Wildlife Department (TPWD) to further the education of LEOs as to how to address enforcement. Speaking for both groups, we stand ready to help in the National Forests.
6. Hunting - I believe there is a conflict in the report as Appendix C, Issues Worksheet, item 6 states trail may be closed during hunting season. In other parts of the document, it says there will be a safety zone, either 300’ or 450’ around the trail. This needs further thought and consideration, as closure for hunting season would eliminate trail use during cool weather when a user counts would likely be highest. Such a closure would negatively affect the financial sustainability of the trail system. Perhaps lessons learned from operation of the trail system in the SHNF can help guide the final solution.
7. Lake Access - I am personally disappointed that there is no direct access to the lake or a lake overlook. One of the real pleasures for trail riding is stopping along the trails at nice vistas and enjoying both the views and the companionship of both nature and friends. Access to the lake and /or overlooks would also offer opportunities for the Forest Service to educate riders about the ecosystem they are in. TMTC is planning such signage at EDRA for all vistas and trail heads. Educated users are more likely to participate in the protection of the ecosystem and cultural resources present.
In closing, I want to thank you for this opportunity to comment on the EA. There clearly has been a great deal of input put into the completion of the document. The National Forests are an important resource for Texans and all Americans. Responsible stewardship, access and education of all citizens will protect the forests for future generations. The Texas Motorized Trails Coalition stands ready to be a partner in the progress of this important development.
On a personal level, as an Architect, motorcyclist and a lifelong resident of Texas, I stand ready to personally provide any assistance required to help with design, construction and maintenance of the trail system. Having attended the Trail Design and Construction Class and Sweco Certified Operator Training offered by Trails Unlimited, I have come to understand the mantra of sustainable design. Sustainable design will protect the ecology of the forests, minimize the expense of operation and provide a safe and enjoyable environment for recreation.
Please keep me informed on the status of the proposed trail system and anything I can do to assist in the construction of this important asset.
Sincerely,
Texas Motorized Trails Coalition
W. Anthony Eeds
President, 2007 - 2009
