We have the following comments on the EA for the referenced project:

1.  The Environmental Assessment (EA) is not clear why Alternative 2 is
selected over Alternative 3, resulting in the exclusion of mountain bikes
on the proposed re-route.  Although the intent of the CDT is primarily for
hiking and horseback riding, biking may be allowed “if the use is
consistent with the applicable CDNST unit plan and will not substantially
interfere with the nature and purposes of the CDNST (FSM 2353.42)”.  The EA
does not detail the CDNST unit plan nor document substantial interference
with the nature and purposes of the CDNST that provides justification for
not selecting Alternative 3 as the preferred alternative.

2.  Negative impacts of mountain bikes are identified in the impacts on
hikers and horseback riders, but negative impacts of horse use, and to a
lesser extent, hikers, are not similarly identified.  The principal impacts
of mountain bikes that are identified are related to trail tread impacts
and potential negative encounters with other users.  The impacts of
mountain bikes to trail tread seem somewhat overstated and ignore similar
impacts from horses.  In addition, the impact of all user groups is a
function of the number of users and the EA includes observational data that
indicates that the number of users is relatively limited.  Given the remote
location of the segment and the lack of high scenic features, it is
unlikely that the proposed re-route will see a significant increase in any
user group due to the re-route, alone.  Therefore, the potential impacts of
mountain bikes to the trail tread would seem to be limited.  The potential
negative encounters between mountain bikers and other users again is a
function of the number of users.  It can also be mitigated by using good
trail alignment to control mountain bikers’ speed and avoid “blind”
corners.  None of the impacts of mountain bikes appear to be significant or
incapable of being readily mitigated and it could be argued that the trail
tread impacts are no worse than those from horses.

3.  It is unclear why Alternative 3 does not include the proposed trailhead
improvements at North Pass that is included in Alternative 2.  The
inclusion of mountain bikes does not preclude the trailhead improvements
and would seem to be of benefit to all trail users if mountain bikes were
included in approved uses.

4.  Long distance self-supported mountain biking (bikepacking) and
supported mountain biking is increasing in popularity and the proposed
re-route provides an opportunity for this activity.  The fact that the
re-route would also be coincident with the Colorado trail, a popular
bikepacking route, for this segment, adds to the appeal.  In general,
biking a well constructed singletrack trail is preferred by mountain bikers
over biking on a dirt road.  Therefore, the proposed re-route would improve
the experience for bikepackers. 

In summary, there does not appear to be adequate justification for not
selecting Alternative 3 as the selected alternative.  The impacts of
mountain bikes to the environment and other users are minimal and can be
readily mitigated.  No significant reasons for not allowing mountain bikes
on the re-route are provided in the EA and allowing mountain bikes would
provide benefit to an additional non-motorized user group.

Sincerely,
Brent Adams
Anne Englert
17584 Road 27.9
Dolores, CO  81323
ravens@frontier.net

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